Irish Maritime Directorate Strategy - Public Consultation Submissions by Recipient
1. Commander John Jordan
Received 13 November 2020
Dear Sir,
From 1952 to 2000 I served on Irish and British Merchant ships, including 32 years in the Irish naval Service, and finally 8 years mainly with Commissioners of Irish Lights and some with Dundalk shipping and British and Irish Containers on MV Wicklow. I would have entered and used all Irish Ports except Wicklow, Dundalk ,Drogheda and Sligo. In Naval days I was liaison officer to the Survey and charting for Burtonport Fishery harbour and served in command of 5 naval ships.
Comments
Core 1. In the overall our response to Maritime safety is reactive as we have NO hands on 24/7 view, or control of maritime traffic. With the loss of manned lighthouses and reliance only on Radio channels in competition with Cell and satellite phones there has been a loss of the Surface Picture and of discipline among users. Most busy sea traffic areas, other than Ireland, are now controlled and interrogated by VTS . Recent incidences offshore and over the years has shown our weaknesses in the event of ship breakdowns that culminate in towage and/or rescue. There are no dedicated Emergency Towage vessels. Regulations will not solve or provide a solution to an actual incident.
Core 2. Some of our Ports are in planned disarray. There is a certain loss of control in that traditional town based berthage is being repurposed as development lands while linear losses of berthage, are not being met at down river sites. It is commercially untidy, and unsightly, to have Bulk, Container, Timber, Miscellaneous, and passenger vessel traffic packed into the same harbour area. From a naval point of view, no harbour has suitable access berths for visiting ships especially the larger foreign vessels. In the overall harbour Boards often provide facilities for special cargos that have no longevity and impose costs to repurpose. Our biggest shame is the loss of our own flag ships and our deep sea tonnage with a consequential loss of independence. Tiering ports is a means of perpetuating the non-development of existing small ports or building new ones. We need a clear estimate of linear and depth requirements for multipurpose ports and we need to resurrect our ability to provide repair facilities for all our port users including vessels up 250/300 metres length. The Naval Service alone would need 700metres of berthage to put all their fleet alongside individual berths. Lastly in the green age it is now a necessity to provide all ships with shore power to run all services and shut down diesels in harbour.
Core 3. Again effective response requires obvious assets and manpower. Their is the need for aircraft for patrol and top cover, Intervention surface craft and helicopters with ranges perhaps to 350/400nm. Vessels capable of towing up to cruise liner sizes. Vessels capable of dealing with an oil pollution, or chemical pollution incident at sea.
Core 4. The initial requirement is to ensure that all vessels entering harbour have a waste handling system on board. That there is a system available in harbour to handle ballast water, waste oils, ship rubbish/dunnage, and domestic waste from ships. Fuelling ships should be notified and supervised for safety measures before and after fuelling. Inspection is key, including maritime flights looking for pollution at sea.
The remaining matters are organisational, the bigger challenges are providing the infrastructure and not allowing preferences to misplace urgent needs to attract traffic, and Industry by increasing all ports capacities.
regards John Jordan
2. Leslie O' Hora, Past President, Glenans Ireland sector
Received 13 November 2020
Dear sirs.
The idea if an island nation without a sail training vessal is appalling.
It's some years now since the Asgard sunk and its subsequent insurance payout
As a national training vessal, the Asgard proved in its lifetime to be a vital part of breaking down barriers amongst to youth in our society as well as teaching them maritime skills and a love of offshore nature.
Surely now is the time to replace her when the youth of Ireland need to live full lives again following the pandemic.
It's worth noting that Les centre nautique des Glenans was founded after the second world war to nuture French youth who had lived through those turbulent times.
Your sincerely
Leslie O Hora
3. Maurice Fitzgerald
Received 14 November 2020
I, Maurice Fitzgerald, XXXXXXXXX, make the following submission in relation to a public consultation on the Development of a Strategy for the Irish Maritime Directorate.
Core Objective 1: Enhance Maritime Safety through effective regulation, implementation and compliance.
Recommendations for inclusion in Maritime Strategy:
1. Develop a roadmap which includes priority legislative requirements at international, domestic and EU level. The roadmap should be risk based on priorities having regard to deadlines for implementation of EU legislation, the configuration of the Irish fleet and an analysis of ships calling at Irish Ports.
Answer: Our naval service in addition to the coast guard is only a paltry token force. Any road map would need strong enforcement – otherwise legislative improvements would be a moot progression. We would need a far bigger enforcement mechanism for any legislation to be effective. A maritime traffic control system could also be established at EU level if it hasn't already, however all vessels would have to have a transponder, like aircraft.
2. Establish a methodology to ensure effective implementation and enforcement of relevant international mandatory instruments.
Answer: Again, we only have a tiny token maritime enforcement mechanism and any effectiveness would have to come about with a much larger fleet of vessels.
3. Ensure reporting requirements are met with regard to the implementation of international conventions.
Answer: no answer.
4. Promote greater communication with all relevant stakeholders on legislative and regulatory developments impacting on the sector.
Answer: Every vessel in our waters should have access to a Departmental website where all relevant maritime laws and regulations are available. All vessels should be registered, pleasure craft included. Registration should mean that owners of such vessels understand their obligations. The coastguard could also publish television and radio ads providing information to sea goers.
5. Provide for enhanced engagement with international organisations such as IMO, ILO, EU Commission and EMSA to ensure Ireland’s interests are represented and ensure early input into the development of legislation impacting the maritime sector.
Answer: Set up an international telecommunication mechanism with audio and visual links for discussions, with language services if necessary.
Core Objective 2: Facilitate Maritime Trade and Connectivity
Recommendations for inclusion in Maritime Strategy:
1. Ensure the appropriate policy framework is in place so that ports are enabled to provide, in a timely manner, the necessary capacity to meet the needs of the economy.
Answer: We must make sure that any port development is not conflicting with residents interests, such as Ringaskiddy in Cork, where port development has been allowed to come extremely near residents homes. Port development must also make sure that port facilities do not take precedence over recreational areas which are vital in promoting people's health. Planning must be careful in not damaging residential areas when ports are developed. New ports away from residential areas could also be built. We seem to be getting carried away with existing natural ports and not looking to build new ones, which would allow more flexibility in design and increase this country's connectivity.
2. Enhance Ireland’s maritime connectivity by exploring the development of a policy framework that supports the creation of new routes and services.
Answer: There are apparently no transatlantic passenger routes by sea. We have concentrated on European connectivity; chiefly Britain and France. This very narrow position needs to change. Discussion should begin with far more countries about bringing passenger services far beyond where they are now – which is only token. We have really failed to exploit our island national which is very sea accessible.
3. Promote the adoption across the maritime transport sector and agencies of emerging technologies to improve performance, economic competitiveness and sustainability.
Answer: Every maritime vessel should have an email address. Delays and uncertainty in giving and receiving information cost money.
4. Explore the options available to DOT that would further promote and facilitate the development of Offshore Renewable Energy projects.
Answer: This question needs more definition and is hard to answer. Our energy needs should not be that great with a small population and we should not get caught up in inter-country rat race to provide cheaper power to the EU grid.
Core Objective 3: Deliver an effective Emergency Response (SAR and maritime casualty & pollution response)
Recommendations for inclusion in Maritime Strategy:
1. Ensure an efficient and effective SAR coordination and response service in the Irish Search and Rescue Region, along the coasts and cliffs of Ireland, on inland waterways for which responsibility is assigned to IRCG, and in support of An Garda Síochána on major inland lakes and remote areas.
Answer: Water safety is not taken as seriously as it should in this country and we are without doubt some of the most accident prone people in the world. Fishermen are a common casualty, who risk the lives in rough and dangerous seas unnecessarily – so they can beat their rivals. Maritime law should allow the government to ban vessels from going to sea by government directive on radio and television. Prevention is better than cure. Cliffs and other remote areas should have warning signs clearly posted for those who want to take unnecessary risks.
2. Provide strategic coordination, guidance and leadership for Ireland’s National SAR system as part of the National SAR Committee (NSARC), report to the Minister for Transport on an annual basis and address specific issues that may arise.
Answer:
3. Provide for effective stakeholder engagement including development and delivery of MOUs between the three SAR Coordinators and between SAR Coordinators and SAR Providers.
Answer: There must be clear roles established for all SAR operators and an (agreed sequence of events). And, an auxiliary response in case of failure. There should not be too many relays of SAR communications. An effective centre of operations is key direct to pager devices etc.
4. Ensure Ireland has an efficient and effective ship casualty/pollution preparedness and response coordination service within an integrated system incorporating stakeholders and other relevant Government organisations, achieved via the Implementation of the National Maritime Oil Spill and HNS Contingency Plan (NMOSCP) via the 2020 road map and supported by the establishment of the two key stakeholder fora.
Answer: There must be clear roles established for all SAR operators and an (agreed sequence of events). And, an auxiliary response in case of failure. There should not be too many relays of SAR communications. An effective centre of operations is key direct to pager devices etc. Establishing liability seems to get in the way of clean-up operations for oil spills. It should be accepted that the owners of vessels or those renting or leasing are vicariously and immediately liable for any spills, and costs to the state for clean up operations. All vessels should declare their insurance and its adequacy before entering Irish waters.
5. Similar to the National SAR Plan, develop a number of national key performance indicators inclusive of a response capability matrix associated with the NMOSCP and its successful implementation, resulting in a fit-for-purpose maritime incident response system providing effective response and recovery for national maritime incidents, minimising social and economic harm.
Answer: An effective response must be immediate and sequenced in detail with all responders on the same page.
6. Develop and maintain enhanced relationships across government (national, regional, local), with the wider community and with industry to ensure efficient coordination in major incident readiness and response.
Answer: And agreed, sequenced, response is key to tackling any incident. Local, national and regional teams would have to be on the same page.
7. Continue to maintain and support the stakeholder engagement arrangements anticipated and required by the National SAR Plan.
Answer: Email stakeholders with communications on arrangements regularly
8. Ensure the effective and efficient implementation of the NMOSCP 2020 by establishing the stakeholder engagement arrangements prescribed within that Plan.
Answer: An agreed and 'sequenced' response to any disaster at sea is the only way. Figuring out what to do when an event has happened is too little too late.
Core Objective 4: Protect the Environment from Ship Source Pollution.
Recommendations for inclusion in Maritime Strategy:
1. Explore policy options on the use of infrastructure in ports associated with onshore power supplies and alternative fuels.
Answer: This question lacks definition and is vague. It is hard to know what is required by way of answer.
2. Explore policy options on the introduction of an Irish Emission Control Area.
Answer: Vessels should not be allowed to 'tick over' unnecessarily while berthed at our docks with heavy diesel emissions. Craft should undergo an emissions and noise pollution test, just as a car or van test.
3. Consider environmental objectives as part of the development of any policy on acceptance criteria for joining the Irish flag.
Answer: Regarding flags. All foreign vessels in this country entering our waters should have clear origin flags on their stern. Many of these flags are worn and unreadable. These vessels should be stopped and boarded to establish where they came from. Foreign vessels joining our national flag should be subject to the highest criteria. There is high abuse of "the flag of convenience".
Core Objective 5: Strive for Organisational Excellence.
Recommendations for inclusion in Maritime Strategy:
1. Reinforce the role of IT as a driver of organisational excellence, by ensuring IT innovation is embedded, encouraged and resourced at business planning level within the IMD, with strong project management structures in place.
Build a performance review mechanism across all the objectives for the IMD which gathers data in relation to KPIs and provides for a consistent approach to identifying lessons learnt and implementing corrective action plans across the organisation through continuous learning and development and ensure that adequately trained and skilled personnel are in place to deliver on the objectives of the IMD.
Answer: The system needs to be bigger and better. International shipping will be key to our future. A ad hoc system which is fragmented will not do and will be subject to decadence and wanton neglect.
3. Ensure that adequately trained and experienced personnel are in place to deliver on the IMD’s objectives based on a systematic approach to continuous professional development.
Answer: Much of the maritime system we have in this country is done by volunteers and part-timers. The whole maritime/marine sectors needs a radical update, which is sure-footed. i.e. a place for everything and everything in its place. Regional and local IMD offices should also be considered for commission.
Core Objective 6: Focus on Customer Service and Stakeholder Engagement.
Recommendations for inclusion in Maritime Strategy:
1. Develop a communication strategy for the maritime sector to establish more formal structures to engage with relevant stakeholders regularly and systematically.
Answer: All vessels should have a valid and verified email address for communication. A register should be established for government purposes regarding this. Email is a very effective way to communicate over long distances and impart high levels of information.
2. Ensure a more proactive and systematic approach to communicating with stakeholders particularly in relation to legislation / regulation developments.
Answer: A Irish maritime handbook should be produced and widely available in all shops and online. Use of television, the press, radio for promoting such material could be an option.
3. Develop a “who does what” for the maritime sector providing clarity to stakeholders and allowing for better engagement.
Answer: The existence of this question is some proof of the ad hoc nature of Irish maritime responsibility. We are a great little nation for passing the buck and transferring responsibility to other agencies and departments when questions or responsibilities come. A stakeholder should go from the general public who mainly engage in pleasure and recreation activity to the highest level of the commercial merchant navy.
4. Develop or utilise existing IT tools in order to better communicate with stakeholders. This may include the use of webinars and e-Newsletters and could result in the more effective targeting of Marine Notices.
Answer: All water users should have a valid and verified email address and other contact details. There is the possibility of commissioning more permanent stationery and advanced marker buoys to enhance the international rules of the road for shipping. More information gathering equipment could be installed on these buoys and they could be GPS fixed if not already. These buoys would have artificial intelligence and report all kinds of information and be able to send it. GPS reporting could advise of any drift of the buoys which would be immediately identified and remedied. All buoys should be able to broadcast whether they are dysfunctional in any way, if they have not that ability already.
All buoys could have in future extra power backup for illumination with wind and tide power gathering apparatus. We should also look at having more markers and buoys, especially inland and cut down on the need for pilot boats.
We should also look at whether our channel buoys differ in any way from international practice regarding colour coding, placement, etcetera. And also whether these buoys are misplaced because of sediment shift. Our shipping channels should be radar swept annually or earlier to ascertain whether they are sufficient for passage, and whether buoys are located correctly in respect thereof.
Despite the age of GPS, weather conditions can be so bad sometimes that digital technology fails. I believe that lighthouses are vital backups in such situations and lighthouse foghorns should be used if such conditions render GPS navigation ineffective or useless in emergency situations. Or there are language/linguistic/electronic/digital problems in keeping a ship away from rocks. I believe it could be very shortsighted indeed to make lighthouse fog horns totally redundant and the policy should be reviewed in the case where visibility is zero. Let's imagine a gas or oil or petroleum ship falling onto rocks
because of thick fog. Foghorns could certainly be used in an emergency situation where the results of a crash would be very serious.
'Automatic' safety audio transmissions on ships frequencies and languages could also come from lighthouses on the approach of any ship, and other appropriate or regulatory information. The IMD's website could be included in such information ; reporting requirements and other instructions. Morse code could also be broadcast from lighthouses and buoys warning of approaches issued from a central location master location with weather infomation when other technologies fail.
The use of new technology is always welcome, but it can fail and digital can be very unreliable in heavy weather. Digital requires an uninterrupted signal and when it doesn't it scrambles. Backup systems – even though they are dated – can still provide lifesaving utility in rough weather and should not be abandoned or forgotten for the utility they gave in the past.
You may publish this submission in full.
Maurice Fitzgerald.
4. Paal Janson, CMM Chairman, Irish Marine Federation
Received 16 November 2020
Re. Development of a Strategy for the Irish Maritime Directorate.
Dear Sirs,
I write to you on foot of your recent publication of the draft maritime strategy for the IMD. I am the Chairman of the Irish Marine Federation, the national trade association for the leisure marine sector, which incorporates the network of coastal marinas / yacht harbours under the ‘Irish Marina Operators Association’.
Our marina membership is derived from private owner operators, Local Authorities, Fisheries harbours and Yacht Club’s. It is our collective experience that this sector is now established as a significant resource for the wider maritime sector. Our marinas are used by Government agencies and organisations such as Geological Survey Ireland, Revenue Commissioners, Irish Naval Service, An Garda Síochána, BIM, RNLI, etc. etc. There are a myriad and growing of workboats and smaller vessels unsuitable for commercial harbour docking and who do not require access to cargo handling equipment and space, as is the norm in commercial shipping. These vessels are very easily and comfortably accommodated in the many marinas located around the coastline.
In addition, there is a growing demand for offshore renewable industry support. Marinas provide an interesting and serious opportunity to accommodate the windfarm service vessel fleet.
We strongly believe that marinas and commercial boatyards should play a key part of the national infrastructure when this strategy policy is being considered. While often viewed as a purely leisure and recreational resource, the reality is that the commercial and NGO sectors are coming to value the safety, security, convenience and professionalism of Irish Marine Federation member facilities.
In addition, this same network of coastal marinas and boatyards form a vital asset to marine tourism where access to the sea for land-based tourists is of equal importance to the thousands of overseas and domestic leisure craft that arrive under their own power and go largely unrecorded in any official statistics. Marinas act as a gateway and facilitate these tourists and allow them to tour the coastal locations and communities of Ireland. The employment, trade and investment in this sector is significant and noteworthy, especially so in the smaller coastal communities and harbours. Yet Ireland has failed largely to capitalise in any meaningful or overarching way, as other European countries have done.
Our neighbours in Scotland has developed a highly effective and powerful marketing brand; Sail Scotland, that embraces marine and boating tourism to deliver a range of strategic marketing activities to grow their sector. When considering the Tourism Ireland Regional Cooperative Marketing Fund, and similar funding opportunities, there exists scope to deliver the same strong message to a variety of targeted and meaningful markets for Irish shores. Our membership has already done some work in this area and we feel that we could contribute still more to the topic.
We would also support the concept of a national and central boat registration for all leisure craft. We understand that this is something that has been discussed previously but still remains a concept rather than an active policy under consideration. We lag behind other European countries on this issue and would recommend that due consideration and resources are given to correcting this anomaly.
On behalf of the Irish Marine Federation, I wish to submit these matters and our experience to the IMD for their attention and we would be happy to have input into any future stakeholders’ groups or advisory committees to ensure that the flow of information between industry and Government is maintained and refreshed.
Yours Sincerely,
Paal Janson
Chairman - Irish Marine Federation
5. Dr. Robert McCabe, Coventry University
Received 27 November 2020
Ireland is a small island state with a limited maritime surveillance and enforcement capacity. It is dependent on sea transport routes, particularly via the United Kingdom, for economic well-being and is responsible for regulating and securing an Exclusive Economic Zone more than ten times its landmass.
The Irish maritime sector and national security apparatus are required to operate in an environment that is increasingly contested and complex both domestically and internationally. Concerns such as attacks on critical shipping and marine information systems through cyber assaults; the trafficking of people, weapons and drugs across borders; declining ocean ecosystem health; as well as the potential security and governance uncertainties arising from Brexit, mean that maritime security needs to be considered in the strategy for the Irish Maritime Directorate alongside broader maritime safety concerns. In addition, the Covid-19 pandemic has reiterated the importance of the unhindered movement of maritime trade and the need to address threats to this passage, not just in territorial waters, but internationally given the interconnectedness of the maritime supply chain.
National and international maritime security strategies recognise that the sea will remain a source of conflict, competition, and instability, as well as a conduit for transnational challenges that will impact on Irish and European prosperity and security. Indeed, the updated White Paper on Defence of 2019 highlighted how events internationally impact increasingly on Ireland’s political, social, economic, and environmental well-being, in ever more complex ways and patterns. However, if developed in a sustainable, inclusive, and secure manner, Ireland’s blue economy has the potential to generate massive revenue for the state through sectors such as seafood, tourism, oil and gas, marine renewable energy, and new applications for health, medicine and technology. This implies that an Irish maritime strategy must be holistic and cross- sectoral in approach with the security agencies of the state cooperating and sharing information with the maritime sector more broadly defined.
This does not simply pertain to military or policing matters but implies a more comprehensive approach to Ireland’s domestic maritime strategy that recognises the multifaceted and interlinked nature of human, economic, and environmental security and the need for the Department of Transport (DT) to work more closely with the defence sector to build resilience, and surveillance and enforcement capacity, to mitigate future shocks. For example, one of the issues with the Marine Planning and Development Management Bill (2019) and the National Marine Planning Framework is what agency will undertake inspections and enforce new regulations. If a new agency is established (as has been proposed) it would have to cooperate closely with the Irish Naval Service (INS), An Garda Siochana and the Coast Guard. This multiagency approach to the governance of maritime zones has the potential to lead to duplicity, overlap, informality and unclear assignations.
The alternative is to build the capacity of the INS and Coast Guard - already possessing the required skills and expertise - to undertake these duties, potentially as part of their ‘aid to the civil power’ remit. Offshore renewable energy will become an increasing area of importance in the coming years and improved technology will see infrastructure move further offshore than heretofore. This will further increase surveillance, inspection, and enforcement requirements. The recent case of the MV Alta washing up along the south-west coast is likely to cost the state upward of €10 million in salvage costs. While increased surveillance is unlikely to have spotted this ship, it does demonstrate the need for improvement.
Ireland, through the INS, has already shown leadership in addressing maritime security threats both domestically and on the international stage. Despite its size, the INS has, for example, deployed vessels to the Mediterranean to counter human trafficking as part of EUNAVFOR MED Operation Sophia, and contributed to the protection of shipping against the threat of piracy as part of EUNAVFOR Operation Atalanta off the Horn of Africa. Closer to home, the INS has interdicted massive quantities of drugs destined for Ireland, the UK and Europe; enforces fisheries regulations and combats the smuggling of people and illegal firearms though monitoring and surveillance operations.
There is a need to increase the capacity of the INS and Coast Guard to effectively meet the maritime security demands of the future. This will be particularly salient post-Brexit when the responsibilities of the INS will likely increase notably in relation to monitoring, surveillance and patrolling; fisheries protection; drugs interdiction, and countering criminal and terrorist networks that use the maritime domain to move weapons, people and narcotics. In addition, the Coast Guard will likely become increasingly involved in pollution response.
Recommendations
Enhance Maritime Safety through effective regulation, implementation and compliance
• Maritime security should from part of the narrative here as distinct, but complementary to, maritime safety. For example, to effectively address issues such as marine waste, ghost nets and illegal dumping, there needs to be effective enforcement mechanisms in place to monitor and surveil these activities, detain offenders, and liaise with the appropriate authorities ashore (e.g. the Marine Planning and Development Management Bill). • There is scope for the creation of a mechanism to ensure Irish laws are kept up to date through ratification and implementation of International Maritime Organization (IMO) conventions and other regulations.
Facilitate Maritime Trade and Connectivity/ Customer Service and Stakeholder Engagement
• Potential for the creation of a Contact Group on Maritime Governance between UK and Ireland to act as a single point of contact to foster more sustainable ‘east-west’ collaborations post-Brexit. The Contact Group format implies a more open, informal collaborative mechanism operating in parallel to - and informing the work of - formal governmental and diplomatic meetings. Formal groups tend to include senior policy and planning officials at the exclusion of other impacted stakeholders such as industry representatives, security practitioners, civil society groups, academics, and research and development scientists. This is a gap a Contact Group can fill. • There is a need for continued participation and pursuing leadership opportunities in global organisations such as the IMO, Paris MoU, International Telecommunication Union (ITU), and the International Association of Marine Aids to Navigation and Lighthouse Authorities (IALA); as well as EU bodies such as the European Maritime Safety Agency (EMSA), and the European Global Navigation Satellite Systems Agency (GSA). • Development of the blue economy should be sustainable, inclusive, and secure and approached in a holistic manner with the security agencies of the state cooperating and sharing information with the maritime sector more broadly defined. • Note the risk posed by reliance on Global Navigation Satellite Systems (GNSS) for position and, more importantly, timing. There is a need for contingencies and to understand how Critical National Infrastructure will operate if GNSS is lost.
Thank you for considering my comments.
Yours sincerely,
Dr. Robert McCabe
6. Captain Patrick Galvin, Association of Marine Pilots of Ireland
Received 4 December 2020
Development of a Strategy for the Irish Maritime Directorate
Our Aims: Over the past number of years we have endeavoured to liaise more effectively with the Department of Transport maritime bodies. For this reason we are delighted to have the opportunity to make this submission as we believe the objectives outlined in the consultation to develop a strategy for the Irish Maritime Directorate are very similar to what AMPI hope to achieve in the near future:
Enhance Maritime Safety through effective regulation, implementation and compliance The codifying of a standard of training and operational procedures for Marine Pilots in all Irish Ports is paramount to ensure the safety of lives, the protection of infrastructure and protection of the Marine Environment.
Protect the Environment from Ship Source Pollution As pilots we believe we are a key part to achieving the above objectives we are the first point of contact for ships reaching these shores and make an assessment on the condition of the vessel and risks which may be posed to the environment, vital port infrastructure etc. For this reason we take a keen interest in regulations, policies etc. which may affect our ability to carry out our roles.
Focus on Customer Service and Stakeholder Engagement Ideally we would like to have a more direct stakeholder involvement with the various maritime agencies within the Department of Transport. To give a recent example we have endeavoured to be included in communications in relation to Covid 19 policies in Ireland, we did not have any success in this. We have the relevant experience amongst our membership to allow us to make a significant and positive contribution.
What is Pilotage and who are Pilots A Marine pilot is typically a professionally licensed ships officer who navigates ships safely through domestic waterways while ensuring safety of the environment, people, and trade. A Pilot is not part of the ship's crew but an expert in ship handling, which possesses local knowledge of the port the ship is visiting. Pilots are highly trained experts in navigation and ship handling, with highly specialised skills and extensive knowledge of local environment and conditions. Gaining these skills usually takes many years of training. Pilots operate under local and national legislation.
A pilot occupies one of the most important positions in the maritime industry, yet remains the least- known. Pilots are an indispensable cog in the transportation system of every maritime economy as their work prevents traffic congestion and accidents that could impair navigation in and out of ports, safety of lives, protection of the maritime environment, and port infrastructure.
Association of Marine Pilots of Ireland We are the professional body for Marine Pilots in Ireland where one of our main goals is to promote industry best practice among Pilots in all Irish Ports. We work closely with, and are members of the International Maritime Pilots Association and the European Maritime Pilots Association. The aim of these Associations is to exchange and promulgate information to members with the goal of improving professional and technical proficiency at an International and European level. We have members from all of the main ports in Ireland and some smaller ports.
Our Association aim’s to consult and liaise with the Minister, and Government Department responsible for marine affairs, and any other appropriate Minister or Government department and the maritime institutions in the European Union and in the International Maritime Organisation on current or proposed maritime legislation and policy affecting pilotage with regard to the practice of the profession, provision of services, safety, protection of the public, property, the environment and competitiveness of maritime trade.
Pilotage in Ireland Pilotage in Ireland is legislated by the 1996 Harbours Act and Local Port Byelaws. There are two methods prescribed in the Harbours Act in how pilots are engaged by Port Companies. They are either employees of a Port company, or are licenced by a Port company. We are an extremely important link in the supply chain. As an island nation 90% - 95% of our imports and exports are by sea. This trade is facilitated by pilots. There are between 45-50 pilots in all of Ireland.
It is the view of our association that pilots are best seen as public servants. We fulfil the obvious role of getting ships from one position to another during what is classed by the Marine Insurance Industry as the riskiest part of a ship's voyage. But we do this in a manner which protects the marine environment, port, and civil infrastructure.
Training of Pilots in Ireland At present there is no uniform way in which Pilots are trained in Ireland. Some ports take training of their Pilots very seriously by following industry best practice, while others do not. The 1996 Harbours act does not prescribe a minimum standard of qualification desirable to become a Pilot in Ireland. Nor does it specify a minimum standard of training that a Pilot should meet to be deemed qualified to fulfill the role in a professional and responsible manner.
Tier 1 ports like Dublin & Cork have a prescribed training and continuous professional development program for their Pilots which follows industry best practice. While other ports have non existent training programs. Some ports supply a pilotage service, while not falling under the legislation of the 1996 Harbours Act.
When a ship arrives from sea to an Irish Port, whether that be Fenit, Greenore, or Dublin, the ship's Captain and owners expect that the Pilot coming onboard is trained to a level that would meet industry best practice. That is not always the case!
It is in the interest of the safety of Marine Pilots, public safety, port infrastructure, and the protection of the marine environment that this practice needs to stop. Ships calling at Irish Ports carry anything from thousands of cruise passengers, coal, oil, and chemical products. We should not wait until an accident happens with potential loss of life and an environmental disaster to make necessary changes? These disasters usually make international news, it was only a few months ago that a ship grounded on the island of Mauritius and created an environmental disaster by leaking its fuel into the ocean. It is classed as the worst environmental disaster ever in Mauritius. The Shannon Estuary is a special area of conservation, imagine if such an oil spill, or chemical spill was to happen there.
It is the view of our Association that a minimum standard of training, and operational procedures for Maritime Pilots should be codified in Irish Law that covers all ports and persons that supply a pilotage service.
1996 Harbours Act Part IV of the Harbours Act of 1996 applies to pilotage. This section of the act evolved from the Pilotage Act of 1913. The world has evolved in an unimaginable way the writers of the 1913 Pilotage act could not have foreseen. The Maritime industry had just evolved from the days of sail, and were embracing steam power at the time of writing the 1913 pilotage act. With mechanical diesel engines only coming into mainstream use in the 1960’s. The advancement of technology and how seafarers are trained has moved on at an unprecedented rate in the last 20 years.
Typically a Pilot in Irish Ports would have been a Master Mariner (A ship's Captain, without any limitations on size of ship). In 2010 the International Maritime Organisation (IMO) introduced the Manilla Amendments to the International Convention on Standards of Training Certification and Watchkeeping. This amended regulation made it compulsory for all Mariners to complete continuous professional development every five years, or lose their qualifications. The logic behind this move was to keep professional Mariners training up to date as technology and operational procedures advance. As a Pilot is not part of the Ship's crew, there is currently no legal requirement for Pilots to keep their training, or knowledge of advancements in technology up to date. With this in mind, parts of section IV of the 1996 Harbours Act are anachronistic when relating to what the maritime industry would deem a modern and professional pilotage service.
EU Port service regulation EU 2017/352
I would like to draw the reader's attention to some relevant parts in the EU Port Services Regulation which came into force in March of 2019.
EU 2017/352
Recital (39) According to Resolution A.960 of the International Maritime Organization, each pilotage area needs highly specialized experience and local knowledge on the part of the pilot. Moreover, pilotage is generally mandatory and often organized or provided by the Member States themselves. Furthermore, Directive 2009/16/EC of the European Parliament and of the Council (10) entrusts a role to pilots in reporting to competent authorities apparent anomalies which may prejudice the safe navigation of the waterborne vessel, or which may pose a threat to or may harm the marine environment. In addition, where safety conditions allow it, it is important that all Member States encourage the use of Pilotage Exemption Certificates, or equivalent mechanisms, in order to improve efficiency in ports, in particular to stimulate short sea shipping. In order to avoid potential conflicts of interests between such public interest functions and commercial considerations, Chapter II of this Regulation should not apply to pilotage. However, Member States should remain free to decide to apply Chapter II to pilotage. If they decide to do so, the Commission should be informed accordingly, in order to ensure the distribution of relevant information.
I would also like to draw the reader's attention to article 14 of this regulation;
Article 14
Training of staff
Providers of port services shall ensure that employees receive the necessary training to acquire the knowledge which is essential for their work, with particular emphasis on health and safety aspects, and that training requirements are regularly updated to meet the challenges of technological innovation.
IMO A960 is acknowledged in rectal 39 of EU2017/352. Although pilotage has been exempted from Chapter two (market access), we have to comply with article 14 (training of Staff). When complying with article 14, the question must be asked, what constitutes a trained Pilot?
The Port Service Regulation covers Dublin, Drogheda, Waterford, Rosslare, Cork and the Shannon Estuarial Ports. Ideally all Irish ports should come under a unified regulation compelling pilots to be trained to a minimum standard. Our Association was informed early in 2020 that DTTAS would be auditing ports on compliance with the port service regulations. To date no pilot has been asked about training.
IMO A960
IMO Resolution A960 (attached), is the Recommendations on Training and Certification and Operational Procedures for Maritime PIlots. This document is a recommendation of the IMO.
Ireland is a member of the IMO and therefore we are expected to implement their recommendations. This document is designed as a framework for the establishing a minimum standard of training and operational procedures for maritime pilots.
Should there be an accident involving a pilot, this document will be used by the accident investigator as the measure to ascertain if the pilot was adequately trained.
The implementation of this document in Ireland would play an important role in promoting maritime safety and protecting the maritime environment.
It is the recommendation of the European and International Maritime Pilots Association that all pilots are trained to the minimum standard prescribed within IMO A960.
ISPO
The ISPO (International Standard for Maritime Pilot Organizations) is a standard of best practice for pilots and pilot organizations, improving safety and quality. Providing self-regulation and transparency in pilotage standards to all port related stakeholders. Port of Cork Pilots have been a member of ISPO for a number of years and are audited annually in order to maintain the required standard. Through ISPO Port of Cork pilots regularly liaise with the other members of ISPO in order to maintain best practice and keep up to date with changes in pilotage. To date the Port of Cork is the only ISPO accredited Port in Ireland.
The recommendations of AMPI Maritime pilots are one of the most important cogs in the global shipping industry. We are there to ensure that ships move safely, efficiently, and in a manner that will not harm the marine environment. In completing this role keeping our knowledge and skills up to date with developments in technology and industry best practice is paramount.
• Not all pilots in Ireland undergo continuous professional development. This needs to change to ensure the continuing success of all ports, the safety of all pilots, and the protection of the marine environment. We are proposing that a minimum standard of training for pilots be established for all Irish ports. • In terms of stakeholder involvement we believe we can make a significant contribution. Across our membership we have a broad range of experience working
in various ports and on different types of vessels. We can liaise with the authorities on a variety of topics with the objective to keep our ports running effectively and in a safe and environmentally friendly manner.
7. Noel O'Regan, Promara Ltd
Received 9 December 2020
A Chara,
Thank you for the opportunity to comment on the Strategy for the Irish Maritime Directorate
The opening paragraph of Marine Notice 53 of 2020 creates the impression that the main reason for this review of Department activities is an impending IMO Audit. The proposed strategy seems to be weighted towards the International arenas. From my perspective Stakeholders external to Ireland are less important than the following Stakeholder groups in the Irish Maritime Sector:
a. Operators of vessels engaged in International trade b. Operators of Domestic Passenger Vessels and Passenger Boats c. Operators of Fishing vessels d. Operators of Workboats e. Workers in the Irish Maritime Sector including IMA Surveyors.
The IMA Should focus most of its efforts and Strategy on serving these groups while taking care of Ireland’s international obligations.
1. Enhance Maritime Safety No right-minded stakeholder can argue against the noble objective of “enhancement of Maritime Safety through effective regulation, implementation and compliance”. However, all of the recommendations seem to relate to the Maritime Safety Policy Division with little focus on activities of the Marine Survey Office who have considerably more opportunity to help develop the sector.
Maritime safety can be improved by education and engagement with stakeholders. I recommend that the IMA examines how this can be achieved.
Marine accidents are seldom investigated by the Irish Maritime Administration. A person that causes a maritime accident has little fear of investigation or sanction by the IMA and can go on to repeat those same errors. In practice there is no question raised about such a person’s suitability to hold Maritime qualifications. The absence of sanctions or prosecutions is regrettable and contributes to lower levels of compliance. Only the MCIB carries out visible investigations of Maritime accidents.
2. Facilitate Maritime trade and Activity Ireland’s trading position does rely heavily on maritime transport yet Ireland’s Maritime Sector has been in decline for a long time. A new redirected focus is needed at the IMA with sufficient vision, expertise and self-confidence to help the sector to grow and prosper.
Brexit has caused increased direct maritime traffic from Ireland to the continent. Ireland will be more geographically remote than ever before. Would it not be a worthy aspiration to attract international shipping to register in Ireland and to contribute to the economy? There has never been visible cooperation between the IMA and bodies such as the IMDO to try to increase the number and value of vessels on our Flag.
Ireland has no Workboat regulations. Workboats that operate in “smooth and partially smooth waters” are effectively unregulated while Workboats wishing to operate around our coast are hugely inconvenienced by the absence of a Workboat Code. These vessels must comply with Loadline Regulations and Passenger Vessel regulations which are inappropriate for such vessels and their crews who are used to operating throughout other parts of the EU under better-suited Workboat Codes.
The offshore wind industry is about to arrive in Ireland in earnest with opportunities for investment, employment and a meaningful contribution to the Irish Economy; Offshore operators will be met by restrictive Regulations that are at variance with other EU countries.
Our Passenger Vessel regulations are peppered with inconsistent one-off restrictions. A set of enigmatic “draft regulations” are unpublished with no statutory basis yet they inform many decisions made by the IMA. Many illogical and unwelcome requirements are placed on vessel Owners without statutory foundation and are then foisted on everyone else on the basis of that precedent.
There is a tendency for Passenger Vessel operators to move to modern, larger vessels. Existing skippers benefit from generations of experience yet they are not qualified to command newer larger vessels. A pathway for these people to develop their skills and qualifications to continue in their traditional roles must be developed. A bespoke arrangement will be needed to suit the responsibilities associated with increased speeds, passenger numbers and compliance but does not need to deal issues that do not arise in the operation.
EU Passenger Vessel construction regulations no longer apply to vessels under 24m; some of these expired regulations are clearly unsuited to such vessels yet the complete EU wording is apparently being transposed to Irish Statute without meaningful review or industry consultation. This action of introducing new Statutes with requirements that are universally known to be inappropriate is an illogical action that has a significant negative impact on our industry.
3. Deliver effective emergency response I suggest increased use, and further development of, expertise within the IMA in supporting the Coastguard in their emergency response duties.
I also suggest that the provision of an Emergency Towing Capacity on the West Coat be re-examined with a focus on how such a service can be provided perhaps as a integral part of routine towing operations.
4. Protect the Maritime environment from ships pollution
5. Strive for organisational excellence In my opinion the IMA falls well short of organisational excellence particularly as it should apply to Maritime Affairs. The recommendations proposed are relevant to every Government Department. This plan should seek to focus on the IMA’s Maritime activity.
I perceive a widespread lack of respect for the Organisation, its Structures and for its way of working. The details of this widespread concern along with constructive suggestions from Stakeholders could
be successfully gathered and published in a consultation process but only if is a truly independent assessment. A Past attempt to address stakeholders views failed.
6. Focus on Customer Service and Stakeholder engagement We, in Ireland, are looked on a outliers by our Industry colleagues across Europe. This strategy should work towards:
a. Harmonisation of interpretations of EU regulations to create a level playing field across Europe. b. Building of co-operation with other Flag States in day to day operation to help Irish Maritime enterprises. c. Building of relationships with Stakeholder through consultation and cooperation to promote the interests of both parties. d. Allowance of interpretations and exemptions, as provided for in regulations, where they are safe, logical and useful. e. Framing of Domestic Irish regulations in line with EU wide standards to allow transfer of sound vessel between member states
In my opinion the IMA does not currently focus on Customer Service. Each sector of our Maritime Industry has valuable expertise that can complement IMA expertise but this resource appears to be ignored by the IMA. More than half of all fishing vessels are surveyed, on behalf of the IMA, by a panel of independent Surveyors yet their opinion is shunned by the IMA.
The scope and required standards of Survey Inspections should be transparent to ensure consistency across the IMA and to assist stakeholder in preparing for Survey. This would be beneficial to both Surveyor and Vessel Operator in preparing for survey. These guides to Survey must be created with common sense and consultation so as to avoid hard and unrealistic implementation.
8. Phoebe Duvall and Ian Lumley, An Taisce
Received 10 December 2020
Re. Development of a Strategy for the Irish Maritime Directorate
To Whom It May Concern,
An Taisce welcomes the opportunity to comment on the Development of a Strategy for the Irish Maritime Directorate. Our submission focuses on Core Objective 4 for the proposed Strategy: Protect the environment from ship source pollution. We note the three current recommendations under this Core Objective:
1. Explore policy options on the use of infrastructure in ports associated with onshore power supplies and alternative fuels.
2. Explore policy options on the introduction of an Irish Emission Control Area.
3. Consider environmental objectives as part of the development of any policy on acceptance criteria for joining the Irish flag.
We submit that reducing the greenhouse gas emissions and air pollution impacts of maritime transport should be an explicit objective of the Strategy.
An Taisce is the Irish affiliate member of the Brussels-based, European-wide NGO, Transport and Environment (T&E). T&E’s brief includes shipping and advancing clean energy solutions for maritime transport to address greenhouse gases and other air pollutants from shipping fuel.
From 2007-2012, shipping accounted for approximately 3.1% of annual global CO2 emissions (approximately 1,000Mt of CO2 per year)1. T&E projects that this could increase to 10% by 2050 if current growth rates continue.
Shipping also has a significant air quality impact through emissions of sulphur dioxide (SO2), nitrogen dioxide (NOx) and particulate matter (PM2.5) in particular. MARPOL and EU restrictions imposed in recent years have substantially reduced SO2 and NOx emissions in Europe’s marine area, but increases in shipping transport volumes may threaten this progress2. It is notable that NOx limits also only apply to new ships, and that NOx emissions from shipping in the European area are on course to exceed all land-based NOx emissions in the EU by 20303.
Black carbon, particles released through the combustion of marine fuels, is also particularly problematic and accounts for 21% of CO2e emissions from ships4. It also has significant air quality and health impacts, including causing heart and lung disease.
1 Transport and Environment, “Shipping and climate change”: https://www.transportenvironment.org/what-wedo/ shipping-and-environment/shipping-and-climate-change 2 Transport and Environment, “Shipping’s impact on air quality”: https://www.transportenvironment.org/whatwe- do/shipping-and-environment/shipping%E2%80%99s-impact-air-quality 3 Ibid. 4 Ibid.
Shipping emissions are excluded from the Paris Agreement. However, at international level, the International Maritime Organisation (IMO) is engaging in both the greenhouse gas and pollution issues, including advancing proposals for greenhouse gas mitigation measures and alternative power sources. We would highlight an October 2020 statement from T&E highlights the complete inadequacy of current IMO climate mitigation and air pollution mitigation action (see Appendix 1 attached).
In light of the above, the Strategy for the Irish Maritime Directorate should include mitigation of shipping emissions as an overarching priority. This should also take account of cruise ship emissions, as these ships have a disproportionate impact on climate and air quality given the energy requirements of the accommodation and leisure facilities.
Ireland as a maritime island nation needs to take international leadership and engage with the IMO in significantly increasing the ambition for greenhouse gas mitigation to align with the Paris Agreement and for the development of alternative ship fuels and power sources. This will have a major parallel benefit in reducing marine area air pollution.
Please acknowledge our submission and inform us of any further consultation periods.
Yours sincerely,
Phoebe Duvall Planning and Environmental Policy Officer An Taisce – The National Trust for Ireland
Ian Lumley Head of Advocacy An Taisce – The National Trust for Ireland
9. Gerald Aherne Brigadier General
Received 11 December 2020
Core Objective 3: Deliver an effective Emergency Response (SAR and maritime casualty & pollution response)
The Irish Maritime Directorate should ensure a plank is developed in conjunction with DTTAS and DOD to integrate existing state resources into and national SAR plan.
Land SAR is recorded as a devolved tasking of AGS in the National SAR Plan, The SAR helicopter contract is primarily focused on the maritime and littoral domains. What plan exists to leverage existing state structures to develop capable Land SAR infrastructure and have DOD been consulted to leverage existing State assists for same?
EMSA retains significant UAS/UAV technology which has been deployed in support of European nations. The IMD needs to develop closer links to EMSA, specifically in relation to the deployment of UAS/UAV into Irish waters, whether in a training capacity, or on an operational deployment, in order to develop a knowledge base in this area. This is key to building corporate knowledge in systems that will take centre stage in maritime surveillance for both SAR and Pollution Support Operations in the coming years.
A closer relationship between DTTAS, DOD and DPER should be fostered for the development of a state sponsored Maritime Helicopter SAR Service. There should be a long-term plan developed to transfer the existing outsourced Helicopter SAR contract into state operation over a period of 10 years. This strategic plan should form a key part of the next SAR contract due to be awarded in 2023.
Core Objective 5: Strive for Organisational Excellence
The Irish Maritime Directorate should seek to engage all web-based IT resources in order to present how it does its business to the general public in an open and honest way ensuring public engagement with its SAR services. Examples of such IT systems are effectively being employed by the MCA in its tender process for UKSAR2G. Openness and visibility of IRCG operations within the SAR domain will highlight its operations and thus promote the concept of high-quality value for money public services.
10. Harry Hermon Chief Executive, Irish sailing
Received 10 December 2020
Introduction
Irish Sailing
Irish Sailing is the National Governing Body for recreational and competitive activities involving engine and sail powered craft in Ireland. As national governing body, Irish Sailing promotes participation and co-ordinates activities in Ireland on both inland and coastal waters. Irish Sailing constantly monitors and reviews developments in sailing and boating and represents the interests of its members and other sailing and boating enthusiasts, with Government and international agencies.
Irish Sailing also develops and administers a range of training and other services to support both members and others involved in sailing and boating of all types, which currently includes:
• Dinghy sailing • Cruiser sailing • Motor cruising (Coastal and Inland Waterways) • Powerboating • Windsurfing • Personal Watercraft
Irish Sailing’s training schemes are formally recognised by the Department of Transport, and in addition Irish Sailing is responsible for the training and accreditation for the International Certificate of Competency and the Commercial Endorsement for Passenger Boat Drivers on behalf of the Department.
Irish Sailing has 20,000 members and represents the interests of an estimated 143,000 participants in the various types of craft mentioned.
Irish Sailing has a network of 320 Clubs, Training Centres, and other Affiliated Organisations.
Our organisation welcomes the opportunity to submit our views on the Development of a Strategy for the Irish Maritime Directorate. Our aim is to work proactively to support the Maritime Safety Directorate within the Department of Transport in the promotion and development of safe and responsible participation within the marine leisure sector.
Irish Sailing Vision for a Strategy
An inclusive strategy that improves the access to, and facilitates the use of, inland and coastal waters for recreation - a strategy that does not unnecessarily restrict participation.
Irish Sailing Priorities
Irish Sailing’s priorities to be addressed in the strategy in relation to Marine leisure activities include:
a) Use of regulation only where necessary, appropriate, and enforceable b) Education and Awareness Programmes c) Small Vessels Register d) VHF Licensing for Handheld Radios. e) ComSail Rules
a. Use of regulation only where necessary, appropriate, and enforceable
In recent years, more and more people are recognising the natural asset that is our coastline and inland waterways. This has led to a significant increase in numbers taking to the water, and the growth of an industry providing much needed employment in small businesses in rural areas around our coastline and inland waters.
Until recently boating activity has been allowed to take place in a relatively unregulated environment, and it is this unregulated environment that makes it affordable, accessible, and enjoyable. As numbers of people taking to the water increases, there has been pressure to respond to incidents involving recreational craft by introducing regulation.
Due to the nature of the activities and the extent of our coastline and waterways, it is very apparent that ‘blanket’ regulation does little or nothing to improve safety standards, unless it is appropriate and enforceable. Regulation generally serves to restrict responsible boat owners from participating in their chosen activity and has little impact on the irresponsible participants.
Before introducing regulation to manage water-based activities we would ask the Department to:
• Carefully consider the costs and complexities of effectively enforcing regulation • Consult with stakeholders (who have knowledge and expertise) to identify the real issues and self-regulating solutions • Assess whether any proposed regulation genuinely fulfils the objectives to improve safety standards, without unnecessarily restricting responsible participation.
b. Education and Awareness Programmes
In general people involved in boating activities have a desire to participate responsibly. They have respect for their own safety, the environment, other water users and people who may be affected (directly or indirectly) by their activities. This culture exists as a result of a well-structured awareness and education campaign driven by Irish Sailing, and other agencies with an interest in watersports. The majority of those who behave irresponsibly do so through ignorance and/or a lack of training.
We would like to see the department supporting this policy of education delivered by agencies such as Irish Sailing, as a cost-effective means of improving safety standards whilst at the same time increasing participation.
c. Small Vessels Register
Maritime Safety Strategy 2015-2019 published by the IMA. Action item 17:
“Implement provisions under the Merchant Shipping (Registration of Ships) Bill 2013 to require jet skis and fast powered craft to be registered.”
This was due for implementation in 2017 to improve safety and security, however it was never delivered.
We would like this registration system to be developed as a simple, accessible, and cost-effective voluntary register. Irish Sailing had for a number of years been operating a register of such vessels, and we would like to offer our support in helping the department to implement this action item.
d. VHF Licensing for Handheld Radios
Currently the licencing for use of VHF is organised through the Department’s examiners. This is an exam that qualifies operators in the use of ships radios and in our view requires a significantly higher level of knowledge, training, and competency than needed by the vast majority of people organising marine leisure activities using handheld VHF radios. The complexity and cost of this licence, along with the development of mobile technology is a deterrent to pleasure craft users from obtaining a VHF license and/or engaging in training for the same.
In the interests of Safety, we would like the department to:
Develop a shorter more accessible course and assessment for operators of handheld radios.
e. ComSail Rules
The majority of Irish Sailing practical cruising schools are operating on a restrictive P6 ComSail Inshore licence. This dictates that school vessels proceed to sea a maximum distance of three miles from nominated points of departure.
It is not possible to operate within these restrictive plying limits: if school boats venture out of this area they are in contravention of the regulations and outside the cover of their Insurance.
The reason the school boats cannot gain a coastal area of operation (plying limit up to 30nm from coast) is down to the structural design and constructions requirements laid down by the ComSail regulations.
Section 4.4, does give Equivalency approval methods however this is also problematic as there is no agreement on what is acceptable by the MSO. In its current format the majority of schools using a production boat cannot meet the requirements of the P6 ComSail coastal licence.
This has significant impact on Safety, as there is no provision to provide offshore experience for sailors in a training environment under the current regulations.
Irish Sailing would like to request ComSail regulations to be amended to allow production boats to be used for sail training in Ireland. We are proposing the removal of the P6 ComSail Inshore licence and editing of the P6 ComSaill Coastal Licence.
We would like the
Harry Hermon
Irish Sailing Chief Executive
10th December 2020
11. Aileen Van Raemdonck, European Maritime Pilots' Association
Received 11 December 2020
EMPA Response to the Strategy for the Irish Maritime Directorate
The European Maritime Pilots’ Association (EMPA) would like to express their support for the development of a Strategy for the Irish Maritime Directorate (IMD).
Pilotage is a service of public interest ensuring efficiency, safety and security in the passage of ever- larger vessels, often in heavy traffic during the most hazardous part of their voyage. Maritime Pilots bring specialist ship handling skills necessary to navigate in restricted and shallow waters, while taking into account weather conditions, currents and tides, in order to avoid the danger of collision, contact or running aground, which may cause serious incidents and pollution harming the environment. A high level of expertise is required to become a maritime Pilot as the channels thorough which the ships move from or towards the port are usually narrow and shallow for the size of the ships, with the stopping distance being only a few nautical miles. Safety and security lie at the heart of all activities related to pilotage and should never be compromised.
In cooperation with one of our members, the Association of Marine Pilots of Ireland (AMPI), we hereby take the liberty to provide feedback to some of the Core Objectives of the draft maritime strategy to be developed by the Irish Maritime Directorate.
Enhance Maritime Safety through effective regulation, implementation and compliance Article 14 of the Regulation (EU) 2017/352 establishing a framework for the provision of port services and common rules on the financial transparency of ports clearly states that “Providers of port services shall ensure that employees receive the necessary training to acquire the knowledge which is essential for their work, with particular emphasis on health and safety aspects, and that training requirements are regularly updated to meet the challenges of technological innovation.” The Regulation also refers to IMO Resolution A.960 on the Recommendations for Training and Certification and Operational Procedures for Maritime PIlots.
We therefore call upon the Department of Transport to implement the Regulation and this article in particular by creating a standard of training and operational procedures for Marine Pilots in all Irish Ports.
Protect the Environment from Ship Source Pollution As explained earlier, a Pilot is familiar with the local requirements and unique conditions prevailing in the port area and contributes to the overall safety at sea, thereby including the protection of the environment. In the event of an accident, high pollution is a serious risk. This is why compulsory pilotage is considered to be the most effective and important form of navigation safety regulation.
Focus on Customer Service and Stakeholder Engagement We regard it as essential for the Department of Transport to establish and maintain good relations with relevant stakeholders in order to receive direct information and feedback regarding the practical realities.
EMPA, the European Maritime Pilots’ Association, is available to further explain their views on the Strategy.
12. Anna Classon, RNLI
Received 11 December 2020
To – Maritime Strategy Consultation
Thank you for the opportunity to comment on the Maritime Strategy for the Irish Maritime Directorate, on behalf of John Payne Lifesaving Operations Director of the RNLI and his colleagues , we have two comments:
• The focus of the report is on maritime safety and legislation. We would welcome the need to improve data collection and analysis into fatal coastal fatalities (drownings) which have helped to focus efforts in lifesaving activity in other jurisdictions . • The other area of interest is the requirement for data gathering and performance review in Core Objective 5. This could be a great point for a discussion around KPIs, lessons learnt and data collection and sharing between IRCG and RNLI
Kind regards
Anna
13. Delio Belmonte, Rosetti Marino Spa
OBJECT: Development of a Strategy for the Marine sector - New sources of energy - Research and development program for clean energy solutions to reduce air and water pollution in the Ports using H2 and Fuel Cells to design, build and operate the first H2 powered tugboat to enter service in an EU Port: Dublin
Invitation for consultation to provide comments on below Core objectives:
4) Protect the Environment from Ship Source Pollution
Dear Sirs,
We are responding with this letter to your invitation for consultation on above Core objective 4 We are an Irish - Italian consortium of technologically advanced Companies in the field of:
• Design, construction, management and operation of advanced vessels and structures for the Offshore and Maritime Industry. • The Irish Company, Purple Water Towing Ltd is the new (2020) licensed towage provider in Dublin Port, where it has brought to service the III generation Tugboat Giano tug, the most technological advanced ship-handling and Escort tug operating in Europe. www.purpletowing.com • The Italian Company Rosetti Marino Spa is the leading private shipyard in Italy specialized in Energy infrastructures, the constructions of specialized vessels for the Offshore industry, ferries, and tugboats, with a century long history in high quality marine industry’s products and projects worldwide, focused on conventional (oil and gas) and new source of energy. https://www.rosetti.it/company/ • The Consortium is open to new European partners (Public and Private companies, Universities and spin offs of Polytechnics) that can bring their knowhow and cutting-edge technologies in the field of Hydrogen (H2) to be used as fuel to power small-medium ships. We will also take advantage of the unique experience acquired in the last 20 years from the German and Italian Navy in their AIP (Air Independent Propulsion) new class of submarines using H2 and Fuel Cells (FC) for their power train.
OUR COMMENTS AND REVIEW:
4) Core Objective 4: Protect the Environment from Ship Source Pollution
The EU at large, and some European countries leading the field of green energy, are in the process of producing a giant effort to become fossil fuel free by 2050. The financial means to accomplish this goal have been set up within the ‘’Next Generation EU’’ plan, of which 50% will be addressed to Research and Innovation within the program Horizon Europe.
Ireland as a country has interest in producing a longer-term plan setting out how to take advantage of the massive potential of offshore energy on the Atlantic Coast. This plan should consider the circular economy, whereas the renewable energy sources can produce effective advantages in reducing pollution of air and water, especially in the transport by road and by sea, taking advantage of the technological improvements that are continuously offered by the Companies active in the energy industry.
The two most important segments of this program will be:
• To improve the technology to produce “green” Hydrogen out of the available energy produced by the renewable sources.
• To use Hydrogen as the fuel of the future in automotive, light, medium and heavy means of transport, including shipping.
Today “green” hydrogen, produced by using renewable energy to power electrolysers, can cost several times the standard hydrocarbon version. To help the world meet zero-emissions targets, the cost of green hydrogen — as opposed to the kind made with fossil fuels — needs to come down, and faster than it did for wind and solar. That means scaling up the technologies and infrastructure involved.
We, as a consortium of established companies in the field of shipbuilding and of the Oil and Gas energy sector, have interest in the second part of this program.
By teaming up the necessary competency and experience in this field we are confident to be able to advance the marine transport industry through a program of research and development finalized to the production of the first ever H2 powered tugboat to enter the service at the end of a 3 year program. We are in a privileged position to reach this goal because:
a) We can take advantage of ROSETTI MARINO Spa capability in producing vessels for the oil and gas industry servicing the port and marine infrastructure in almost 100 years of activity. https://www.rosetti.it/shipbuilding/
b) We work in an environment of high-tech industries in Northern Italy where a cluster of Companies are active in the field of components for the Hydrogen industry, thus being able to add qualified high tech partners to our program. https://lnx.arco-fc.com/ https://omb-saleri.it/
c) Under a special agreement with the Italian Navy, we will have the unique opportunity to seek the competent advise by specialized personnel and Officers of the Italian Navy that together with the German Navy have the sole experience in producing and operating the AIB Submarine project A212 powered from Fuel Cells since the late 90’s. The following Officer has been authorized to act as our advisor:
Commander Vincenzo Azzollini
The 20 years of experience in producing and operating the only 10 submarines sailing the oceans using Hydrogen as fuel, will be paramount to accelerate our program, as the power train of the A212 submarine is similar in power to the one of a tugboat and also of a small ship of about 10.000 DWT (about 3000 KW) https://en.wikipedia.org/wiki/Type_212_submarine https://engineered.thyssenkrupp.com/en/new-fuel-cells-for-submarines-fourth-generation-high- tech-propulsion/
d) We have secured the scientific and technical support to our program of Professor Paolo Piccardo of Genoa University, one of the leading researchers in chemistry and metallurgy working on improving the new generation of Fuel Cells. https://hydronews.it/a-genova-universita-e-aziende-private-collaborano-allo-studio-delle- fuel-cell/
e) We can take advantage of Purple Water Towing Ltd (IE), our operational partner and ship design Company’s unique experience and position, that will make available the patents and the operating experience of the III generations most advanced tugboat operating in Europe, being the new (2020) Towage provider in Dublin port. Purple Water Towing Ltd, owns the patents and design rights of the Giano Class tugboats. https://www.youtube.com/watch?v=RhM5xWGqAPI
This will allow the consortium to develop the power train and ancillary equipments on an existing advanced commercial platform in order to develop an H2 propulsion system to be tested in ship handling service in parallel with an existing diesel powered conventional system, but without the high level of air pollution. www.purpletowing.com
THE IRISH MARINE DIRECTORATE AND IMDO AS THE BEST PARTNERS TO OUR PROGRAM
Ireland is an energetic country with a solid, reputable, and transparent financial system and where we already have substantial interest and investment.
Our program, if adequately supported within the NEXT GENERATION EU can produce substantial technological improvements to the Energy industry, being a first example of a commercial H2 powered small ship entering service in a European Port: Dublin. The experience acquired during such program will be invaluable and will put our Consortium of Irish/Italian Companies in the leading position to produce tugboats and small vessels with ZERO emission, available in a short time to the European market.
14. Ruadhán MacEoin
Received 11 December 2020
Re Maritime Strategy Consultation
Dear Sir or Madam,
I wish to make an observation regarding the forthcoming maritime strategy. In media reports it has been said that a core aim of the strategy is to
Review potential to expand passenger and cargo capability at all of our ports, prioritising rail connections and interchange.
Work with the ports and ferry companies to increase the number of foot and cycle passengers.
Accordingly, it is suggested that consideration be given to using the Irish Rail lines at Dublin Port into passenger use for foot passengers using ferries.
The Phoenix Park tunnel railway was unused for passenger traffic for many years; similarity the Irish Rail link to Dublin Port - now the only passenger ferry port - remains idle, despite the port typically carrying circa 2 million passengers in non-Covid times.
A service from the ferry terminals could be routed via Drumcondra to Heuston, where platform 11 would provide service in one direction - with another platform required opposite.
Further development of the existing Irish Rail network in the Dublin City Council area could see services from the Dublin Port to stations at Croke Park, Dublin Zoo, and other destinations, such as across the island.
I am grateful for consideration being given to this observation.
Yours sincerely,
Ruadhán MacEoin
15. Ian Spice, Director Purple Water Towing Ltd
OBJECT: Development of a Strategy for the Marine sector – Maritime safety at sea and in the Ports - Invitation for consultation to provide comments on below Core objectives:
1. Enhance Maritime Safety through effective regulation, implementation and compliance
Dear Sirs,
We are responding with this letter to your invitation for consultation on above Core objective. We are the Company Purple Water Towing Ltd the new (2020) licensed towage provider in Dublin Port, https://www.dublinport.ie/wp-content/uploads/2020/03/09.1-2020-Towage.pdf where we have brought recently to service the III generation Tugboat Giano tug , the most technological advanced ship-handling and Escort tug operating in Europe, fully compliant with EMSA recommendations for Fire Fighting tugs and the rules of IMO resolution MSC 415 (97) IS 2008 for Escort tug that entered in force on the 1st January 2020. www.purpletowing.com
OUR COMMENTS AND REVIEW ON : Core objective 1 - Enhance Maritime Safety through effective regulation, implementation and compliance –
The Core Objective 1 is stating, as a priority of the Irish Maritime Directorate, to enhance Maritime Safety, and as a consequence, the safety of operations at the Oil Terminals, as an accident at these industrial sites may result in uncontrolled spills, fires and explosions, potentially leading to the loss of human life or to a major environmental catastrophe and to the disruption of a vital supply chain.
Such objective goes in the same direction of our recent proposal sent to Dublin Port Company, suggesting to the Managing Body of Dublin Port, to implement the new available Fire Fighting technology in their Oil discharge identification and risk assessment and management plan.
Port of Dublin, is, in our opinion, exposed to a high risk, being an Oil Port not adequately protected under the standard and recommendation of Economic Commission for Europe 2015 and EMSA 2012, as reported in our Addendum to our letter to DPC dated 3rd December 2020, because an external ‘’water borne’’ fire system – a tugboat as specified by the EMSA with Class ‘’Fire Fighting Ship 1 water spray’’ - is not provided by the Oil Terminal Operators, that are relying only on a fixed land based fire extinguishing system, subject to vulnerability to disruption during an emergency, nor by the Managing Body of the Port - directly or by a towage service provider, in case of fire or explosion during the unloading operations of oil tankers, where external ‘’water borne’’ qualified instruments will be most needed to provide: an uninterrupted and powerful source of water to extinguish the fire with the capability to tow away the damaged tanker.
Fi Fi Class 1 Tug in action
EMSA specifications:
• Firefighter / FiFi Class I Active protection, giving it the capability to withstand higher heat radiation loads from external fires: minimum capacity of 2.400 m3/h divided on two monitors with minimum throw length of 120 meters in still air. The minimum throw height is 45 meters measured from sea level and 70 meters away from the nearest part of the vessel. In addition, the vessel has to be equipped with a spray system for self-protection.
Dublin is among a very small number of oil ports in Europe where such type of vessel, compliant with the recommended EMSA standards, able to effectively fight a large fire on board an unloading tanker, assist the crew under protection of his water drenching system, and in case of explosion tow away the casualty, is not available 24/365.The reason lies most probably in the fact that, never the less the high quantity of oil distillate unloaded in Dublin and the closeness of the oil terminal to the City (about 4 million tonnes per year) there is no refinery in the proximity that normally contracts the towage company to provide this service in compliance with the above standards ( e.g. Cork, Milford Haven, Liverpool, Southampton etc.)
It is worth reminding that a single accident, like the explosion of the tanker Beltegeuse.in Bantry Bay oil terminal in 1979, that blocked for years the operations at Whiddy Island, could be a national disaster if it blocks Dublin Port, or the fire and explosion of MT Haven in Genoa in 1991, causing the worst oil pollution that ever happened in Mediterranean.
In our view, the Competent Authority ‘’DUBLIN PORT COMPANY’’ is delegated with the power and capability to perform the function of oversight of the operation of an oil terminal, and may, after the Regulation (EU) 2017/352 cover such costs , under Article 7 – Public service obligations with a port service charge due by the oil tankers unloading oil products at Dublin Port, in order to ensure ‘’The safety, security or environmental sustainability of port operations’’, thus avoiding to add any extra cost to the Administration and securing the appropriate service 24/365.
Core Objective 1 - time schedule to upgrade Dublin Port to safety standards and recommendations of EMSA and ECE:
Immediately active, after the implementation of the provisions of a Fi Fi Class 1 Tug Water Spray, in the Emergency Plan, and the publication by the Dublin Port HM of the relevant Notice to Mariners containing the port service charge, due for the safety and security of the operations of the oil tankers unloading oil products at Dublin Port. Above will ensure appropriate resource allocation to meet the goal.
RELEVANT DOCUMENTS
EMSA Technical report and specifications of Fire Fighting tugs operating in dangerous zone- 2012 http://www.emsa.europa.eu/news-a-press-centre/external-news/item/1429-just-published- technical-report-safe-platform-study-development-of-vessel-design-requirements-to-enter-a- operate-in-dangerous-atmospheres.html
United Nations Economic Commission for Europe, safety guidelines and good industry practices for oil terminal - 2015 http://www.unece.org/fileadmin/DAM/env/documents/2015/TEIA/publications/1519196_ECE_CP_T EIA_28_Anglais.pdf
The European Parliament and the council regulation (EU) 2017/352 establishing a framework for the provision of port services and common rules on the financial transparency of ports. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017R0352&from=EN
We remain at your disposal for any clarification and further information on above comments.