The Coastguard, Emergency Towing Vessels and the Maritime Incident Response Group

House of Commons Transport Committee

Sixth Report of Session 2010–12

Volume II Additional written evidence

Ordered by the House of Commons to be published 25 January, 22 March, 29 March, 26 April, 3 May, 10 May, 18 May, 24 May, 7 June and 14 June

Published on 23 June 2011 by authority of the House of Commons London: The Stationery Office Limited

The Transport Committee

The Transport Committee is appointed by the House of Commons to examine the expenditure, administration, and policy of the Department for Transport and its Associate Public Bodies.

Current membership Mrs Louise Ellman (Labour/Co-operative, Liverpool Riverside) (Chair) Steve Baker (Conservative, Wycombe) Jim Dobbin (Labour/Co-operative, Heywood and Middleton) Mr Tom Harris (Labour, Glasgow South) Julie Hilling (Labour, Bolton West) Kwasi Kwarteng (Conservative, Spelthorne) Mr John Leech (Liberal Democrat, Manchester Withington) Paul Maynard (Conservative, Blackpool North and Cleveleys) Gavin Shuker (Labour/Co-operative, Luton South) Iain Stewart (Conservative, Milton Keynes South) Julian Sturdy (Conservative, York Outer)

The following were also members of the committee during the Parliament.

Angie Bray (Conservative, Ealing Central and Acton) Lilian Greenwood (Labour, Nottingham South) Kelvin Hopkins (Labour, Luton North) Angela Smith (Labour, Penistone and Stocksbridge)

Powers The committee is one of the departmental select committees, the powers of which are set out in House of Commons Standing Orders, principally in SO No 152. These are available on the internet via www.parliament.uk.

Publication The Reports and evidence of the Committee are published by The Stationery Office by Order of the House. All publications of the Committee (including press notices) are on the internet at http://www.parliament.uk/transcom. A list of Reports of the Committee in the present Parliament is at the back of this volume.

Committee staff The current staff of the Committee are Mark Egan (Clerk), Marek Kubala (Second Clerk), David Davies (Committee Specialist), Tony Catinella (Senior Committee Assistant), Edward Faulkner (Committee Assistant), Stewart McIlvenna (Committee Support Assistant) and Hannah Pearce (Media Officer).

Contacts All correspondence should be addressed to the Clerk of the Transport Committee, House of Commons, 7 Millbank, London SW1P 3JA. The telephone number for general enquiries is 020 7219 6263; the Committee’s email address is [email protected]

List of additional written evidence

1 Independent Light Dues Forum (LDF) Ev w1 2 Angus MacNeil MP Ev w4 3 Save Stornoway Coastguard Campaign Team Ev w7, Ev w8, Ev w12, Ev w23 4 Steve Sim Ev w23 5 Coastguard Officer Ev w24 6 Denis McCallig Ev w25 7 Paul Kirby, PCS Branch Secretary for Liverpool Coastguards Ev w25, Ev w27 8 Serving coastguards at MRCC Falmouth Ev w28 9 Jean Hendry Ev w30, Ev w32, Ev w33, Ev w34 10 Liz Hustler Ev w35 11 Coastguard Watch Officer Ev w35 12 Clyde Coastguard Ev w36 13 Karen Paradise Ev w37 14 Simon Davey Ev w38 15 Grahame Thompson Ev w38 16 Les Jenkin Ev w38, Ev w39 17 Stephen Hennig Ev w41 18 Kathy Grant Ev w41 19 Katrina Hampson Ev w41 20 Lynne Fry Ev w42, Ev w100 21 John Steer Ev w42 22 Roger Davis Ev w45 23 Andrew Cattrell Ev w47 24 Bob Skinley Ev w50 25 Ian Graham Ev w60 26 Serving Coastguard in Aberdeen Ev w60 27 Karen Thompson Ev w61 28 Shetland Coastguards Ev w61 29 Guy Boily Ev w61 30 Eric Greenough Ev w62 31 Michael D Cowsill Ev w63 32 Blundellsands Sailing Club Ev w63 33 AN Sulaire Trust Ltd Ev w65 34 Shetland Youth Voice Ev w66 35 David Cairns MP Ev w67 36 Letter from the Office of the First Minister and Deputy First Prime Minister Ev w71 37 Coastwatch (Redcar) Ev w72 38 Scottish Government Ev w72 39 Murdo Macaulay Ev w73 40 David MacBrayne Ltd Ev w75 41 Liverpool Coastguard Ev w79, Ev w81 42 Gill Palmer Ev w82

43 Robin Ward Ev w84 44 MRCC Clyde Ev w84 45 Matthew Mace Ev w85, Ev w87 46 The MacGregor Family Ev w88 47 James Wiseman Ev w89 48 Eileen Thomson Ev w89 49 Brixham Coastguards Ev w89 50 Operations Room Staff at MRCC Clyde Ev w93 51 Greg Albrighton Ev w98 52 Serving operational Coastguard officer Ev w104 53 Country Standard Ev w109 54 British Ports Association (BPA) Ev w110 55 MRCC Belfast Watchkeeping Staff Ev w111 56 Mike Lacey Ev w113 57 Louise Pooley Ev w116 58 Ivan Fabian Ev w118 59 Simon Hart MP Ev w120 60 Hampshire Fire and Rescue Service Ev w121 61 Shetland MRCC Ev w124 62 Anthony Byrde Ev w126 63 Mairi Murray Ev w126 64 Martin Collins Ev w127 65 Strathclyde Fire and Rescue Ev w130 66 Irene MacRitchie Ev w131 67 TOTAL E&P UK Ev w132 68 North Wales Fire and Rescue Service Ev w136 69 International Group of P&I Clubs Ev w138 70 Andrew Cotterill Ev w140, Ev w143 71 Les Watson Ev w143 72 Colin Small Ev w152 73 The North Sea Foundation Ev w155 74 Save Shetland Coastguard Steering Group Ev w156 75 Wendy Mallon Ev w161, Ev w162 76 Shetland's volunteer Coastguard Rescue Service (CRS) Ev w163 77 Outer Hebrides Coastguard Task Group Ev w168 78 Northumberland Fire and Rescue Service (NFRS) Ev w172 79 Kent and Medway Fire and Rescue Authority Ev w174 80 David Pockett Ev w175 81 Outer Hebrides Community Planning Partnership Ev w176 82 Chartered Institute of Logistics and Transport UK (CILT) Ev w180 83 Holman Fenwick Willan LLP Ev w182 84 Coastguards at MRCC Thames Ev w185 85 Andrew J Mahood Ev w187 86 Kevin Rogers Ev w189 87 Dominic Lonsdale Ev w192

88 Save Milford Haven Coastguard Campaign Ev w193 89 Dorothy Mackinnon Ev w208 90 Highlands & Islands Fire & Rescue Board Ev w208, Ev w210 91 Dr Stephen Bailey Ev w211 92 Tina Rogers Ev w212 93 Jim Green Ev w212 94 Convener Sandy Cluness Ev w213 95 Coastguard Rescue Service Station Officer Ev w214 96 Harry Edmondson Ev w215 97 Operational Coastguard Officers from around the UK Ev w218 98 John Hope, ex PCS Section President Ev w218 99 Sheryll Murray MP Ev w220 100 Jim Nicholson MEP Ev w222 101 Serving Coastguard Ev w222 102 C A Kay Ev w223 103 Joint submission from Save Stornoway and Save Shetland Coastguard Ev w224 104 Devon County Council Ev w226 105 Zoe Moore Ev w226 106 Kevin Bird Ev w227

List of unprinted evidence

The following written evidence has been reported to the House, but to save printing costs has not been printed and copies have been placed in the House of Commons Library, where they may be inspected by Members. Other copies are in the Parliamentary Archives (www.parliament.uk/archives), and are available to the public for inspection. Requests for inspection should be addressed to The Parliamentary Archives, Houses of Parliament, London SW1A 0PW (tel. 020 7219 3074; email [email protected]). Opening hours are from 9.30 am to 5.00 pm on Mondays to Fridays.

Save Stornoway Coastguard Campaign Team Nautilus International Coastguard Officer John Whitford Dennis Laird The Chief Fire Officers Association KIMO UK Coastguard Watch Officer Andrew Cattrell Jack Hawker Amanda Darling Eileen Bell Philip Tilley Bob Paul John Morrison Simon Rabett

Jenny Robertson George Henry The Scottish Wildlife Trust Small Isles Community Council Margaret Mackay Stein Moorings Association Office of the First Minister and Deputy First Prime Minister Royal Yachting Association Port of London Authority Scottish Government Murdo Macaulay Aberdeenshire Council MRCC Aberdeen The Hyperbaric Medical Centre (Diving Diseases Research Centre) Welsh Assembly Government Cornwall Council Fal and Helford Special Area of Conservation (SAC) Management Forum Cornwall Council Harbours Board Humber Coastguard Oil and Gas UK National Coastwatch Institution MRCC Belfast Watchkeeping Staff David Smith David Mantripp Carol Collins The Highland Council UK Harbour Masters' Association Mr Davy Thompson, Senior Operational Coastguard Officer for North Wales and the Northwest Area Coastguard Staff at Solent MRCC The Conference of Yacht Cruising Clubs Front line staff of MRCC Falmouth Operations room and other staff at MRCC Stornoway and MRCC Shetland Dick Holness James Ralston Peter W Brown Bruce Lack Coastguard Staff at MRCC Holyhead Don't Sink the Coastguards UK Maritime Pilots Association British Marine Federation RNLI Devon County Council Gill Palmer

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Written evidence

Written evidence from the Independent Lights Dues Forum (ILDF) (MCA 01) 1. This submission is made by the Independent Lights Dues Forum (ILDF) and focuses on the three general lighthouse authorities (GLAs), the Department of Transport’s actions over the past eight years related to the GLAs and the future arrangements of the aids to navigation service (lighthouses, buoys and beacons) around the British Isles. 2. The ILDF’s members include APL (UK), Hyundai Merchant Marine, “K” Line (Europe) Ltd, Maersk, Mitsui O.S.K., NYK Line (Europe) Ltd, NYK Line Ltd, the Grimaldi shipping lines, Wallenius Wilhelmsen Logistics and EUKOR and contribute about 60% of the annual light dues revenue. 3. Aids to navigation (lighthouses, buoys and beacons) around the British Isles are funded by a levy—known as light dues—on merchant ships calling at British and Irish ports. This is a tonnage-based levy, subject to a cap on the maximum chargeable tonnage and on the number of port calls that are chargeable in any one year. In nearly all other countries, this is funded by governments. 4. Light dues are paid into a central fund, the General Lighthouse Fund (GLF), from which they are disbursed by the Department for Transport (DfT or Department) to the three GLAs in England, Scotland and Ireland. 5. The three GLAs are Trinity House (TH—for England, Wales and other British territorial waters with the exception of Scotland, the Isle of Man and Northern Ireland), the Northern Lighthouse Board (NLB—for Scotland and the Isle of Man) and the Commissioners of Irish Lights (CIL—for Ireland). 6. Over the past decade the ILDF has spearheaded a campaign to ensure shipowners calling at the UK and the island of Ireland get a fair and equitable level of light dues. The ILDF recognises the high quality services provided by the GLAs, but believes the cost is too high.

The three concerns with the GLAs and the DfT’s performance 7. The three issues that remain a constant concern for the UK shipping industry are as follows. The inability of the Department of Transport to impose clear cost and value controls on the GLAs in line with other Government departments and agencies; the inertia that surrounds the progress on the GLAs tendering out more of their services to commercial entities focused on cost control and quality outcomes; and the failure to cease the subsidy paid to the Republic of Ireland for the upkeep of Irish’s aids to navigation. 8. All of these points were identiﬁed by the Department of Transport commissioned Atkins report, Assessment of the Provision of Marine Aids to Navigation around the United Kingdom and Ireland, published in March 2010.

The need for better regulation 9. As the Transport Select Committee will be aware in the UK rail industry, the Government is a poor regulator. In rail, independent regulation can claim most of the credit for Network Rail being required to reduce its costs by 50% in 10 years, whilst at the same time improving performance. 10. The Department has shown themselves to be an inadequate regulator in the ﬁeld of the provision of aids to navigation. This failure was acknowledged in the text of the Atkins report and as a result the Joint Strategic Board (JSB), under the stewardship of Chris Bourne was set up, July 2010. 11. Good progress is being made by the JSB, but reservations are held about the appointment of the chairman, Chris Bourne. As well as holding the post of JSB chairman, he is also a non-executive director of Trinity House, one of the GLAs he is holding to account, which is an undesirable situation and may impact on his effectiveness. 12. This is compounded by the chairmanship of the Department’s historically chosen industry representative body, the Lights Advisory Committee, which is also chaired by an elder brother of Trinity House, Michael Everard CBE. 13. This web of GLAs’ inﬂuence over their scrutineers is a concern, but of far greater worry is the Department’s complicity or indifference to the situation until recent times. 14. A few examples demonstrate the GLA’s disregard for the appropriate governance standards in relation to their use of the GLF. The GLAs have been managed at arm’s length by the Department who preferred not to intervene and, until pressed through written parliamentary questions, failed to tighten up governance standards. (i) On 24 July 2002, the Minister for Transport, David Jamieson MP, admitted that the GLF had lent £1 million to Trinity House for the refurbishment and marketing of their lighthouse cottages in order for them to operate holiday homes without direct sanction from the Department or the shipping industry. This was almost certainly unlawful. (ii) Between 2007 and April 2010, close to £1.6 million was spent on the e-Loran project (a radio- navigation system which enabled ships and other users to determine their exact location) without cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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direct sanction from the shipping industry, let alone any demand from shipowners for this service at all. (iii) In March 2010, 14 GLA delegates were sent at great expense to the International Association of Lighthouse Authorities Conference in Cape Town. The delegates spent a total of £9,966 and €3,525 on ﬂights, £11,981 and€4,244 on accommodation, and £1,548 and€442 on subsistence, without the Department’s knowledge or sanction. (iv) At the start of the summer 2010, NLB attempted to appoint public affairs consultants to “lobby” their parent department, again, without the Department’s knowledge or sanction. 15. These examples give a feel for the endemic inability of the DfT to impose cost and value control. 16. This poor regulation was compounded when over the past two years the light dues increases were announced—an initial 67% followed up by a second increase of 26% (an increase from 35p per net registered tonne to 41p) at the worst possible economic time.

Potential for commercial income and use of the private sector being squandered 17. The potential for commercial income is constantly (and understandably) resisted by the GLAs. One area where no income is derived currently is third party inspection of offshore oil, gas and renewable energy structures to ensure they are fit for purpose. At present the tenders, THV Galatea and NLV Pharos, spend time in the North Sea undertaking such work, with the costs met solely by the GLF. As the Atkins report highlights, the time spent by the tenders as a percentage of overall time in a 12 month period was 31.4% (with a proportion of this related directly to the inspection of third party lights—about 2% of their time). 18. This current practice of GLA superintendence and inspection of third party aids to navigation is symptomatic of the problem that engulfs the service: the conflict between the GLAs’ perceived role, the need for policy and planning clarity, and the web of legislation and departmental responsibilities which make the pursuit of commercial activity difficult. 19. This is compounded by the free consultancy now being provided to the Department of Energy and Climate Change in relation to siting of offshre renewable installations. The ILDF members feel that this is a profligate use of GLF resources and is incompatible with the oft-repeated “user pays” basis for GLA activities. 20. As the Committee will well know, the DfT’s partial response to this, the draft Marine Navigation Bill, is still in draft and although scrutinised by the Transport Select Committee in the last Parliament, has yet to be brought before either Houses. Therefore, there is a legitimate question to ask: what is the Government doing to bring the Bill forward in this Parliament and what is the timescale? 21. As the Atkins report identifies, with a change in legislation, this activity could impose a charge on the developers and operators of these structures and therefore benefit, rather than diminish, the current payers of light dues. This would further consolidate the user-pays principle that the Department is committed to and offer much needed policy clarity for the GLAs in this area. 22. The business case for the replacement of one of the GLA tenders, THV Patricia, and, in particular, the construction of a business case and the nature of the market testing used is a matter of serious concern. 23. In order for the GLAs’ fleet to retain and, importantly, gain further operational flexibility, the ILDF members believe that the spot charter market would offer an affordable alternative emergency provision to supplement the remaining GLA fleet capacity (five tenders plus THV Patricia), rather than purchasing or leasing a straight replacement vessel. 24. The spot charter market offers good and operationally adequate alternative that could provide greater emergency cover and depth of provision. However, questions about the impartiality of TH’s business case and the strength of the market analysis conducted in the summer and autumn 2010 remain. These concerns centre on the specifications used when the market as tested and the lack of oversight by the Department. It is understood that the specified provision drove up the price unnecessarily and thus delivered a result that favoured straight replacement and/or refurbishment of the THV Patricia i.e. the price was given for the use of one vessel on permanent standby. 25. In the end, TH’s business case concluded that the spot charter market did not offer the best financial and operational option. Instead, TH recommended (and DfT accepted in December 2010) a scaled back refitting of the tender from the initial estimate of £3 million to £535k. 26. Although it is far from clear what the original £3m figure included over and above the proposed new dynamic positioning system, modification of buoy working deck and chain handling system and reconfiguration of the dining rooms. 27. A further area which has hitherto been ignored is the potential for a 50% reduction in GLA operating costs if the aids to navigation services were put to the market, as evidenced from the experience of Clive Davidson, former Chief Executive of the Australian Maritime Safety Authority (AMSA), who achieved such a saving when he was responsible for the Australian aids to navigation service. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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28. Even with prompting, the Department has yet to make meaningful contact with Clive Davidson since March 2010. Unlike other Commonwealth countries with similar aids to navigation and light dues systems, the UK is missing out on an opportunity to reduce the burden on shipping calling at the British Isles (and therefore on the UK consumer as costs are transferred through the supply chain), while neglecting an opportunity to improve the operational efﬁciency of the system.

29. Any modernisation process will always be resisted by those who have a vested interest, but as light dues payers, the members of the ILDF have a stronger interest to see the highest standards of quality, use of modern methods and efﬁcient practices. ILDF members acknowledge that the GLAs currently provide an important service, but modernisation has the potential to greatly reduce light dues. Even if we saw a 25% reduction in light dues—half the amount that AMSA achieved—it has to warrant investigation and is so far being ignored without reason.

The Irish subsidy and CIL’s costs

30. Much to the bewilderment of the shipping industry and politicians alike, the UK pays for the Republic of Ireland’s aids to navigation. The cost currently stands at £11.8 million per annum.

31. A parliamentary answer on 12 January 2009 established there are no legal or constitutional reasons why the UK government cannot withdraw immediately from the 1985 agreement on the funding of the Irish aids to navigation.

32. In November 2004, the then Secretary of State for Transport, Rt. Hon. Alistair Darling MP, pledged to end the subsidy. In 2005, the subsidy was recognised by the European Commission as an oddity and akin to state aid. The Atkins report recommended that the subsidy should end. And, ﬁnally, in a written ministerial statement on 26 July 2010 by the Parliamentary Under-Secretary of State for Transport, Mike Penning MP pledged to establish a timetable for ending the subsidy with the “costs within the Republic of Ireland to be covered wholly from Irish sources”.

33. The shipping industry remains hopeful that the UK government will end this outdated, state aid which currently places an unnecessary burden on the ships calling at the UK. An end to the subsidy would free up £11.8 million from the GLF and would amount to a decrease of 6p per net registered tonne alone.

34. This may seem an inappropriate time to resolve this anomaly, although there is a precedent in the health sector. The funding of the Irish aids to navigation from the GLF could be stopped in the same manner as the Department of Health when they ceased funding for health care for Irish pensioners under an agreement made between the two governments in 1971. This move last year saved a much larger ﬁgure of€600 million and was done with minimal political bargaining.

35. It is important to note that there is no reason to assume that if the cost of the Irish aids to navigation was fully transferred to the Republic that it would be borne by the Irish exchequer.

36. The ILDF strongly believes the ceasing of the subsidy and the drive to increase GLA efﬁciency are two separate and distinct work streams that can be completed in tandem. The subsidy has undoubtedly allowed the CIL to operate in an even most expensive fashion than the other two GLAs. Therefore, tackling CIL’s inﬂated costs—both per head and per buoy—has to be a priority.

37. As the Atkins report highlighted, the CIL is overstaffed, with 33% more staff per aid than NLB and 25% more than TH, and extravagantly paid, with an average cost per person 70% higher than NLB and 68% higher than TH. In terms of its payroll, CIL therefore costs more than twice as much per aid to navigation as the other GLAs. This is inexcusable, as is the fact that the CIL’s board is paid more than all the executive directors of TH and NLB combined.

Conclusion

38. The ILDF believes that the public sector maritime services suffer from a lack of robust leadership from the Government and devolved administrations. After much pressure, attempts are being made to resolve the situation with the setting up of the JSB.

39. In an industry driven by results, the ILDF members are yet to see any measurable outputs to date. As a consequence, we remain undecided about whether the situation has improved in relation to the Department’s aspirations to impose genuine cost and value controls over the GLAs. January 2011 cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Written evidence from Angus MacNeil MP (MCA 03) As you are no doubt aware, the Government is undertaking consultations on the closure of Coastguard stations throughout the UK. Under these proposals, the UK Government has decided that the entirety of Scotland is to have one full time coastguard station based in Aberdeen and, one daytime coastguard station manned during daytime hours based in Stornoway or Shetland. That would mean two manned coastguard stations during the day and one at night for over 7,000 miles of Scottish coastline a number that jumps to over 10,000 miles when just a few of the islands are included. I feel that this places the mariners of Scottish waters at a great risk. In my constituency MCA Stornoway has been responsible for an increasingly large number of rescues since the mid-1980’s; as of 2009 that number totals over 3,000 rescues. Other stations around the UK have experienced a similar increase in utilisation. To assume that one station will be adequate to deal with potentially 300 rescues a year in the waters between: the Orkney and Shetland Isles, the Outer Hebrides and, mainland Scotland requires evaluation from a number of sources. Therefore, I implore your committee looks at these proposals and produce a report relating to the consequences of the UK Government’s potential actions and, the reasoning and methodology behind these proposals. January 2011

Further written evidence from Angus MacNeil MP (MCA 03a) 1. Executive Summary 1.1 As the MP for one of the most remote parts of the UK, I find the Coastguard modernisation proposals dangerous in the extreme. That point notwithstanding, I understand that upgrades to the ICT infrastructure of the Coastguard must be conducted. As the Maritime Rescue Co-ordination Centre in my constituency is under threat I must fight for it to stay open but I feel that to leave all of Scotland, which contains 60% of the UK’s coastline, with two watch stations during the day and only one at night would leave Scotland severely undermanned should the worst happen. The Search and Rescue area for the UK extends to the middle of the Atlantic Ocean and covers 10,500 nautical miles of UK coastline. The Maritime and Coastguard Agency is responsible for half of the UK’s Search and Rescue response force. 1.2 With most of the coastline lying in Scotland I cannot, in good conscience, agree with these proposals as the Outer Hebrides and the entirety of Scotland will be left severely deficient.

2. Loss of Tugboat Capacity 2.1 Since the consultation was announced the Anglian Earl Emergency Towing Vessel has participated in the rescue of a Royal Air Force Tornado ﬁghter/bomber1 and a French ﬁshing vessel.2 The Anglian Prince ETV, based in Stornoway, rescued a grounded Royal Navy nuclear submarine, the HMS Astute.3 Without these tugboats able to save the vessels and lives of the people these incidents could have ended very differently. 2.2 In the case of the French Fishing Trawler, the incident took place at night in a heavy gale off the coast of Rum. In the proposed new order of the Coastguard the French Trawler would have had to send out a distress call to Aberdeen who would have then had to coordinate with volunteers based at Mallaig Coastguard station. Of course it is unclear if the team would have had to wait for a trained Coastguard to oversee the operation. Additionally, without the local tug capacity it is unclear how the boat would have been removed.

3. Loss of Nimrod Aircraft Coverage 3.1 While the Coastguard is not responsible for the operation of the Nimrod Aircraft its services are required as part of international agreements regarding international search and rescue guidelines. With these vital aircraft in service the consultation has not properly described how it intends to properly monitor the 1.25 million square miles of sea that the UK is obligated to cover. 3.2 As the Maritime and Coastguard Agency is part of the United Kingdom Search and Rescue Strategic Committee these proposals should have been part of the consultation process as well as the risk assessment. 3.3 With the closure of RAF Kinloss aeronautical coverage that could be provided by the United Kingdom has been severely depleted according to an answer to a Parliamentary question from Angus Roberson MP for Moray, a fish factory ship that was on fire off of the coast of the Isles of Scilly had to rely on French aircraft to provide a communications link with the United Kingdom because the current fixed wing assets based at RAF Lyneham were insufficient in providing the same level of service. 1 http://www.bbc.co.uk/news/uk-scotland-highlands-islands-12301802 2 http://ww.hebrides-news.com/14-saved-off-jack-abry-1211.html 3 http://www.bbc.co.uk/news/uk-scotland-highlands-islands-11606046 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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4. Communication Resilience 4.1 The outdated system of paring should be changed. In 2010 the current communications system suffered 201 network wide faults and private circuits were down for approximately 69,000 minutes.4 4.2 This consultation failed to take into account the difficult situation that occurs when one tries to communicate in rural areas. In 2009 in my constituency mobile coverage was down in one area for six weeks. As some people, including volunteers, use mobile phones as their main means of contact the MCA would have to provide them with a more resilient form of communication. This was not addressed in the consultation document. In fact the document stated that the Coastguards would become more dependent on the work of volunteers while, the risk assessment stated that relying on volunteers from flank stations leaves the Coastguards open to the threat of volunteer “non-availability”.5 The risk assessment determined to reduce this threat by .5 a professional officer should be available 24 hours a day seven days a week. It can only be inferred that particular reference means that a trained coastguard must be present or be able to travel to the incident scene to oversee the problem. Anything less would not suffice.

5. Potential New Scottish SAR Responsibility 5.1 According to international obligations the United Kingdom is responsible for monitoring 1.25 million square miles of ocean. As I have already examined the loss of SAR assets and the impact they will have on SAR coverage I now turn to Scotland. 5.2 Under these proposals Aberdeen and Stornoway/Shetland are going to be responsible for monitoring and responding to 60% of the UK’s SAR responsibility which comes to approximately 750,000 square miles. During the evening, the responsibility extends even further south as Aberdeen will become responsible for all of the coastline and sea area extending from Liverpool to an area as far north as the Faroe Islands. 5.3 These proposals are based on the number of incidents and ships that travel around the UK’s waters and have focused on the South of England where a majority of the UK’s shipping industry lies. However, if more ships were to come to Scotland then the situation could require more stations monitoring the waters around Scotland. Additionally, the nature of emergency incidents in Scotland is of a different nature than in the southern part of the United Kingdom. Emergency operations in Scotland can take hours to complete in harsh weather conditions over vast amounts of sea with little recourse to back-up should that be necessary.6 I am reminded of the Braer incident in 1993. This is directly related to the more industrial nature of Scotland’s coast than the more tourist-centred southern coast. 5.4 Five stations currently monitor the Scottish portion of the UK SAR region. Under new proposals that number will be cut by three leaving the two remaining stations to coordinate a response. Leaving the loss of local knowledge to one side, the distance between mainland Scotland and the islands indicate that ALL coastguard personnel tasked with overseeing volunteers will have to come from Stornoway to Shetland or vice versa. At night they will have to travel from Aberdeen to the incident location. Of course, in the event of bad weather there will be no way for trained Coastguards to travel and oversee the problem. This means that a major function of the new order of the Coastguards will be lost because they are not based near their volunteers. 5.5 Again, I will address the issue of communication in rural areas of the islands. In the Outer Hebrides as, with the Northern Isles, communication is intermittent at best in the most remote areas. Therefore, the current proposals make no way to adjust this problem or create a solution.

6. Two Base Solution 6.1 As the Member of Parliament from Na h-Eileanan an Iar my ﬁrst priority is to MRCC Stornoway. Since this consultation stated MRCC Stornoway has played a pivotal role in several high proﬁle rescues. Incidents relating to the grounding of the HMS Astute as well as the crashed Tornado are a testament to having a local station open both during the day and night. In 2009, MRCC Stornoway participated in nearly 200 missions. These were possible because of advancements SAR helicopter technology.7 While I think that MRCC Stornoway should remain open I also support keeping MRCC Shetland open as well. The distance between Stornoway and Shetland is over 200 nautical miles. The distance between MRCC Stornoway and the proposed MOC Aberdeen would be over 150 nm. During “daylight hours” one substation would be partially for the Outer Hebrides, north coast, west coast and, the northern isles of Scotland. During the evening Aberdeen would be responsible for half of the Coastline of the UK as well as the northern half of the Atlantic Ocean. If Stornoway were lost, the whole west coast of Scotland which suffers the worst of the UK weather would be left naked.

7. Daylight Hours 7.1 The term daylight hours has not been properly described by the MCA. Under my questioning in Stornoway it was clear the MCA ofﬁcials had not given any thought as to how “daylight hours” related to time 4 FOI Request. 5 MCA Risk Overview Table Page 1 Ref 9. 6 http://www.pressandjournal.co.uk/Article.aspx/2182378 7 http://www.dft.gov.uk/mca/mcga07-home/newsandpublications/press-releases.htm?id=9884ED3D1EBF3267&m=1&y=2010 cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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on clock given changing length of day. How will the MCA decide what daylight hours are? In the summer months sunrise occurs nearer to 04.00 and sets around 23.00 while in the winter the sun rises around 09.00 and sets around 15.00. Therefore, the arguments relating to proper use of staff are lost because staff could be working for five hours in the winter and nineteen hours in the summer. 7.2 In order for a “daylight hours” station to be useful to the North of Scotland it would have to open when daylight hit the first part of the SAR area which would be around 03.00. 7.3 I am aware that MRCC Belfast and Liverpool are under a similar threat however this situation is not the same. MRCC Stornoway and MRCC Shetland are located on two islands within a large and fairly isolated area. The Outer Hebrides is the length of Wales and the most Northerly Island of the Northern Isles reaches further north than Stavanger, Norway. To think that one station can monitor this area is mindboggling and has not been proven by the consultation paper. As the consultation is focused on reducing the amount of staff working for the MCA and, potentially, building a new facility in the South of England I urge that the MCA look at the case for keeping these two stations open. The MCA is not solely responsible to the South of England or the area where the largest amount of shipping occurs. The Coastguard is a UK-wide resource and should be equally apportioned throughout. If this proves to challenging then a more localised solution should be considered. I shall discuss this later in my response. 7.4 I believe these plans severely hamper the amount of local knowledge that is retained by the remaining stations. Watchkeepers in Stornoway cannot by definition have good local knowledge about the entire coastline of Scotland. Maps can only go so far. Secondly, it will be imperative that a significant percent of the on-call staff at Aberdeen speak fluent Gaelic. Sixty per cent of Hebrideans speak Gaelic and it is also spoken in the Highlands of Scotland as well. Third, a single MOC for all of Scotland will easily succumb to the serious mobile telephony issues we have in the Outer Hebrides. 7.5 A recent incident in Lerwick shows illustrates my point. At 02.13 a 999 call came into MRCC Shetland relating to a boat that had broken free of its moorings in hurricane force winds. MRCC Shetland informed the local Harbour master in Scalloway. The local team was able to address the issue with a trained Coastguard on scene. 7.6 In the new system proposed, the call would have gone to an Aberdeen based Coastguard who would then phone the Scalloway Harbour master who would then alert all necessary parties to retrieve the boat. As the nearest on-call Coastguard would either be a sleep at home because their station was closed or, in Aberdeen. A trained Coastguard may or may not be available. The consultation paper does not address this type of scenario at all. Considering that a trained Coastguard in Aberdeen may only have a map to draw her/his knowledge from, the local volunteers would have to “fill in the blanks” in local knowledge. This can reduce the necessity of having a Coastguard at all. If the Coastguard do not have the intricate local knowledge of their area their usefulness will invariable come into question.

8. Loss of Local Knowledge Tests and the Further Implications 8.1 The MCA plans on eliminating the current local knowledge tests8 and replacing them with an, as yet, unknown system. The current system test MRCC’s staff local knowledge of their coastline every two years. Phillip Massey, Chief Executive Director of Maritime Operations at the MCA,9 indicated that the local knowledge tests were a historical hangover and they are not as important in our day and age. 8.1.1 Philip Naylor: The arrangements that we have for local knowledge at the moment are, I think it is fair to say, drawn from the past when our coastguard organisation was very widely distributed around a large number of very small stations, which essentially were look-out posts with a coastguard looking out to sea with a telephone and a bell. Many of the procedures that we have still relate to the way we did business in those days. What happened was radio came along and that allowed us to concentrate our coastguards into a smaller number of larger centres. The work that they now do in those rescue centres is not to look out to sea. They are not actually surveying the coastline in any meaningful sense. They tend to be waiting for calls to come in by 999 or by radio. 8.2 I disagree with him. Local knowledge tests should be the very basic requirements of a local coastguard. The entire reason a Coastguard exists is to guard the coastline and sea areas. If they do not know that area intricately then their usefulness comes in to question. Communities expect their police ofﬁcers to know their neighbourhoods and constituents expect their MPs to understand the delicate social balances of their communities. I think that we should expect the same from our Coastguards. How can this be maintained in the proposed system?

9. Areas for Improvement 9.1 I think that improvements could be made in the system such as ensuring that Gaelic speakers are placed in areas where Gaelic is the predominant language. 8 http://www.publications.parliament.uk/pa/cm201011/cmselect/cmtran/uc752-i/uc75201.htm 9 http://www.publications.parliament.uk/pa/cm201011/cmselect/cmtran/uc752-i/uc75201.htm cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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10. Amount of Gaelic Speakers in Scotland 10.1 As of the 2001 Census, a majority of the Scots Gaelic speakers resided in the Western Isles, Highlands and, Argyll and Bute.10 Therefore, staff at ALL Scots MOCs and sub-centres stations will need to have a working knowledge of Gaelic. Having a phonetic translation of place names will not work in an emergency situation. 10.2 On 8 February 2011 the Chief Executive of the MCA told the House of Commons Transport Select Committee what commitments the MCA currently has to having staff that speak Gaelic. 10.2.1 “Sir Alan Massey: I will concede that point and, clearly, no offence meant. The point is that we are a polyglot organisation. At the moment we do not have speciﬁc processes that say we need to have Gaelic speakers in Stornoway or we need to have Gaelic speakers in Shetland.”11 10.3 From this statement it is clear that the MCA has not been focusing on the needs of the UK as a whole. It should already be mandatory that Gaelic speakers work at MRCC’s in the north of Scotland and the islands. According to the consultation document there will be no provision for having such speakers there and therefore this must be addressed before the MCA continues with any plans. Clearly MCA, as a management, have been blind to some of the valuable skills their current workforce possesses.

11. Future of the Coastguard in Scotland 11.1 I have suggested several times in the House of Commons that the Coastguard service for Scotland be devolved to the Scottish Government. The Coastguard is already enforcing Scots Law however; it is not directly accountable to the Scots Parliament or Government. Decisions such as the ones under consideration should be taken at a local level. Current savings plans state that the Maritime and Coastguard Agency will save £125 million over 20 years. That amounts to what the Coalition Government currently spends on the debt interest payments every day. Therefore, I cannot believe that these proposals are seeking to improve the entire Coastguard service. By giving the funding and operation control to the Scots Government they can take the best decisions for Scotland and free the MCA of penny pinching and management agendas which are in danger of “spoiling the ship for a ha penny worth of tar” and in short, undermining our Maritime Insurance Policy. 11.2 These proposals centralise the Coastguard around the South of England leaving Scotland with two centres for over 750,000 square miles of SAR responsibility. I urge the Transport Select Committee to seriously consider my proposal for devolution. This will not require a large amount of Parliamentary action to take effect. With the support of the Committee and the MCA my measures can help bring an amicable solution to this situation. Many UK organisations and agencies are already devolved to Scotland surely this can continue to be a success story. 11.3 In my opinion this consultation has been made to suit Whitehall bureaucrats and treat the MCA like a business. It focuses on cost-savings and directing the remaining resources to the greatest area of need. This area is deﬁned by amount of sea trafﬁc and perceived importance to the UK economy. This is where the Consultation goes wrong. As the Coastguard is our Maritime Insurance Policy we need to ensure that it is everywhere. To focus on the south at the expense of the north and Scotland is reckless. The serious concerns relate to the ageing ICT systems not the staff or placement of MRCCs. If the MCA and the Coalition Government cannot understand that difference than I implore them to devolve the powers to Scotland so we can make the best decisions for the safety of our mariners and the resilience of our economy. When the next major incident occurs in the North and West involving submarines, tornados or fuel carriers, those making decisions now will be viewed carrying a heavy weight of responsibility. I hope that they will have acted wisely. April 2011

Written evidence from Save Stornoway Coastguard Campaign Team (MCA 05) We would like to urgently request that the Transport Select Committee examine the current Government/ MCA Proposals for the future of the Coastguard service, a document entitled “HM Coastguard Proposals for Modernisation Consultation 2010”. We, along with all other coastguard stations have had very little in the way of answers since the consultation document was released. This large scale deep reorganisation of HM Coastguard is not backed by any details on how such massive changes are to be safely made to the service. We have deep reservations with this plan. MCA management seem either unable or unwilling to answer our questions on how these proposals will be implemented. This is very worrying given the scale of what they propose. One of our key arguments has been, and must continue to be loss of vital local knowledge—particularly in the ﬁrst few minutes of an incident. However, it is the case that the MCA refuse to even entertain this argument. This is of extreme concern to the majority of coastguards, not just ourselves in Stornoway but nation wide. You will have seen the piece circulated recently where Mike Penning MP argued strongly against the 10 http://www.gro-scotland.gov.uk/press/news2005/scotlands-census-2001-gaelic-report.html 11 http://www.publications.parliament.uk/pa/cm201011/cmselect/cmtran/uc752-i/uc75201.htm cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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regionalisation of fire control rooms from 46 to 9 in England and Wales and his argument centred exactly on the loss of local knowledge. Building on the recent media attention on scrapping of fire brigade regionalisation plans being scrapped at immense cost to the tax payer, we must ask the question why the MCA is pressing ahead with even greater reliance on untested IT systems. Our communications mix is more complex and our units involved are more diverse, so why do they think this will be any more “resilient” or even that they will be able to implement it. There are, of course, other spectacular large scale IT failures such as the National Programme for IT in the NHS (NPfIT). Co-ordination of incidents on scene by volunteer Coastguard Rescue officers is also mentioned. At the moment these people selflessly dedicate their time to rescue others in distress. The current training allocation is only 22 hours per person in order to maintain a complex mix of competencies. Yet these volunteers are expected to replace a dedicated control room and do so with only one radio and a mobile phone. These are only the tip of the iceberg, but we are facing frustration from an MCA management team who refuse to answer how they have arrived at this proposal and even who was involved, even more incredible is the fact that the answers to the consultation document will be examined by one of the team involved in the formulation of this plan! Furthermore, Honourable Members will recall, that the then Select Committee on the Environment, Transport and Regional Affairs, also examined the last such proposals with respect to the Coastguard in 1998, unfortunately this was after much of the proposals had already been implemented. But the Committee roundly condemned both the proposals and the consultation process which they described as a “PR exercise”. The current proposal is much more wide reaching but the consultation exercise almost mirrors what was examined in 1998. In light of this, and we know that MPs from affected stations are also seeking this, we feel that we must ask you to examine this proposal in depth in order to gain full independent scrutiny BEFORE any decisions are made and the consultation closes in order to ensure the same mistakes are not made again. January 2011

Further written evidence from Save Stornoway Coastguard Campaign Team (MCA 05a) Please find below a list of comments from members of the public, professional mariners, boat operators, coastguards, lifeboat and helicopter crews from our petition site: (http://www.ipetitions.com/petition/savestornowaycoastguard/signatures). We have removed names from the list, but otherwise not edited the comments at all. At the moment, we hold 14,500 petition signatures opposing our closure or downgrading and will formally present these at a date TBA. I have looked at the Coastguard map, and compared the distances between stations, for instance along the English Channel (yes, I know a lot of traffic goes through that but there is also a lot of traffic via the north west coast of Scotland too—and the distance across the Channel isn’t the distance into the North Atlantic) and rather than close either Stornoway OR Shetlands, I would have thought they could have done with another one on the isle of Barra, to “fill the visible comparison gap”. Yes there are a few more bases on the RNLI station’s map, which I also looked at (remembering it is a voluntary/charitable organisation) but the Coastguard fulfils many other things including advice to “travellers”. If I was one of those “travellers” I would want someone who is likely to be more familiar with the local area than someone miles away in Belfast or the Shetlands. I know that is important to save money as organisations have to make ends meet, but I think that ultimately it is more important to save lives than money. Surely there must be another way to make a saving than by closing or minimising the usage of this very important base. My son-in-law flew the Stornoway Coastguard helicopter for five years, and I know from him how important it is to have local people coordinating search and rescue on the west coast. We encounter problems with Ambulance Control in Inverness who sometimes send emergency ambulances to the wrong part of Skye (the name may be similar) because of lack of local knowledge. There is no strategic rationale behind this move, local knowledge saves lives and the position of Stornoway makes it difficult to replace without endangering lives and shipping. The cost to the environment from a preventable accident will far out-way any spurious savings from consolidating the resource. Shetland is thus equally valuable. Total Madness to consider closing Stornoway & Shetland With thousands of miles of intricate and complicated coastline it defies logic to even consider contemplating closure of either of the stations in question. The waters of the Minch, Pentland Firth, Orkney, the Outer Hebrides are the cross roads of the world in maritime terms. Are we really paying for those that make such ridiculous decisions. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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I live near the coast in the south of England and hope to move to the Islands later this year. I am an active sea kayaker and understand the importance of the coastguard and paddle secure in the knowledge that they are there for me if something goes wrong. They are the real fourth emergency service and must be treated as such by the current government. Cost cutting cannot be done at the risk of costing lives Reduction of any aspect of HM Coastguard cover in the area of The Minch is unwelcome, unwarranted and potentially dangerous. Closure of Stornoway goes even further and is totally unacceptable in an area busy with large commercial shipping, fishing vessels, ferries and the massive amount of yachts. No closure! Local knowledge is absolutely essential in correctly identifying locations in an area where place names which are gaelic or of gaelic origin can easily be confused. This essential feature can be provided only by Stornoway coastguard. There are many other areas in which money can be saved but this would be a real danger to life. The recent incidents involving the ditched Tornado etc show how vital it is to retain a full time local presence with the local knowledge thus available together with speedy response. The events over the last few weeks has all but proved that the Western Isles MUST retain this vital emergency service who do a fantastic job 24 hours a day 365 days a year. The lads and lassies who provide the service in the Western Isles be it in the air or on land are worth more than their weight in gold and any so-called MPs trying to run this country! Having a friend break her leg two thirds of the way up Sgurr Choinich (Torridon) in winter conditions we were EXTREMELY grateful to Stornoway Coast Guard and the helicopter crew who got her off quickly and efficiently. The planned closures leave big holes in the cover and ability of the remaining locations to offer a comprehensive service. Centralising the Coastguard stations can only lead to disaster. The local knowledge makes a huge difference, and the technical challenges with centralisation could mean that many incidents will not get the support they would now. I was rescued by the coastguard a couple of years ago, and the local voice made a huge difference. The government should not forget that we are a maritime nation and the coastguard service should be sacrosanct. Stornoway coastguard must be open day and night as traffic does not stop at night. An accident of a major scale would cost much more than the savings now. I have a business that takes the public on sea trips in the area covered by Stornoway coastguard, if it was to be reduced or even worse closed my safety and the safety of my passengers would be greatly effected along with all other sea farers, I understand that money has to be saved but the closure would without a doubt cost LIVES, don’t let people die for a budget!! I believe Stornoway Coastguard should be saved as it covers a coastline of disproportionate length and is involved in the routing and support of vessels through some of the UK’s most treacherous waters. Furthermore the team in Stornoway are multilingual which is important when dealing with both Gaelic and English place names. I have always found the team in Stornoway to be helpful in providing information to me as we have sailed the Minch. I am a local sea kayaker and former Coastguard employee. He planned closures will directly affect the safety of recreational sea goers. The local knowledge within existing MRCCs has been responsible for the swift resolution of countless incidents, which otherwise may have turned out less fortunately. When I worked at MRCC Stornoway, the most difficult calls to handle were the ones that came from outside our patch- local knowledge made all the difference. The watches at MRCC and round the country are dedicated, professional and work long, antisocial hours for little pay. What do they give in return? A world-class maritime SAR service that has saved so many lives. Regardless of any financial incentives to do so there is NO substitute for local knowledge. Please give this decision your fullest consideration and listen to the people who currently offer a superb service. My grandson works on one of the fishing boats and I would be horrified to think that such a centre of expertise as the Stornoway coastguard station was going to be closed. If the people who sit in offices making these decisions spent just a day with the people who rely on the current services, they would not dream of axing them. What evidence exists that operational testing of the proposed new systems for Scotland have taken place. What happens if the new systems fail when operated by only one remaining centre. The importance of local knowledge being retained cannot be overstated and the absence of this knowledge can make the difference in a life or death situation. The Stornoway coastguard station should not have its level of service reduced and should be retained as a 24 hour operation. Stornoway coastguard have proved their local knowledge to be indispensable when our club had its only call out of 12 years. I doubt that someone in Aberdeen would have been able to piece together the hypothermic ramblings of a distressed paddler and have worked out where they were on the multi-indented coastline of Skye so quickly without local knowledge. A helicopter saved his life. With all respect to the professionals in Aberdeen, our member may well have died that day. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Taking the public out to sea every day through the summer it is good to know we have back up from our local coast guard if we needed it. The local knowledge of the Stornoway coastguard is such an asset to us and the whole Island which is dependant on the sea for many jobs, tourism and even just travel to main land. We need to know we’re safe at Sea by having people with experience and knowledge of where we are not the other side of Scotland. The government proposals to chop so many coastguard stations is astonishingly short-sighted and distinctly life-threatening. They seem to forget the UK is an island with only one tenuous land link to the Continent. The nation requires as many eyes and ears as possible to watch over our seas and coasts, especially in these years of terrorism events and threats. I feel this is penny-pinching for its own sake. As regards closing either Stornoway or Shetland, where’s the local professional backup for 24/7 RNLI & CG Helicopters based there? They MUST keep both stations 24/7 as they cover the largest—and some of the most dangerous in the world—sea areas and coastlines of the UK. Now they want to replace professionals with electronics and beefed-up volunteers. Have you told them about the VHF black spots in your areas, and as for mobile phones ... we all can’t afford Immersat sets. Having sailed up and down the west coast of Scotland, and beyond, for the last 30-odd years in a number of yachts—the last 20 out of Ullapool—it is ALWAYS reassuring to hear the local CG station on the radio and to know if you are in difficulty, and you need help or rescue, they will know where to find you with their specific local knowledge. Again, we don’t all have DSC sets yet. If the worst comes to the worst and they go ahead with their Whitehall madcap schemes. It is very distressing that our government in London appears to be so unaware of the geography, climate and nature of the seas around the North of Scotland that it could even dream of such decimation of the Coast Guard service in Scotland. Are the lives of those who earn their living from the sea and of others who are currently served by the Coastguard service of so little importance? My operation relies on Stornoway Coastguard on an almost daily basis. They are an integral part of our standard operating procedures and safety policy and provide a hugely important and thoroughly professional service to all users of the maritime environment in this geographical area. To reduce or remove this service would be an act of the utmost folly and would lead to loss of life sooner rather than later. Not much point in having a Day Station—the sea doesn’t go to sleep!!! Keep Stornoway—it covers a huge area. As a fisherman, this government’s just putting another nail in our coffin, but this time there really doing it, putting our lives in danger by there insanity. I have called Stornoway coastguard twice last year for divers suffering from the bends and the response time was amazing I can not consider them not being there. I have actually been in the control room at Stornoway Coastguard as a full scale emergency has been unfolding. As well as the high level of professionalism and skill from the team on duty, what struck me was the value of in-depth LOCAL knowledge and how this can help save lives. In 2010, Stornoway Coastguard undertook 183 operations, the most in a single year since it was established 25 years ago. It will be too late to realise what a mistake closing it will be once environmental damage is done or when lives are lost. The Government may think that they will be making savings but the cost, in reality, could be very high. I strongly support the retention of Stornoway Coastguard Rescue Co-ordination Station and furthermore that it should remain a 24-hour operations station. I feel the plan to reduce the number of stations around the British Isles is fundamentally flawed and poorly thought out, the emphasis being on saving money rather than saving lives. Stornoway CG cover the busy shipping lanes of the Minch and west of Hebrides, as well as providing essential cover for the NW of Scotland. It is unfeasible that the same level of knowledge and operational excellence could be provided from Aberdeen. As a frequent sailor and sea kayaker in this area I rely on Stornoway coastguard for vital local knowledge and accurate weather and safety information. With smaller radios, it is often impossible to hear or contact any other stations and they lack the local knowledge I am looking for. Kayakers especially will find their safety compromised in the remoter parts of the Western Isles—an area growing rapidly in popularity with this sport. A reduction in use will impact on a fragile economy just beginning to benefit from more visitors by kayak and yacht. I also value the wildlife of this coastline. The potential for a marine disaster is high with a consequential impact on wildlife, fishing and local communities. There have been close shaves. A 24 hour maritime centre in the Minch both increases the chances of avoiding an accident and is best placed if anything were to happen minimising the risks to all. This marine biodiversity should continue to receive the highest level of protection available at times when it is already under stress from human mismanagement of fishing and pollution. It is this kind of service I pay taxes for—and would pay more taxes for. Please retain this centre. As a visiting small boat sailor who is getting to know this area, and knows how lonely it can feel when things turn difficult, I’d like you to maintain the reassurance of having 24 hour local cover from Stornoway Coastguard. The absence of night cover with local knowledge for coordinating cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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rescues alarms me. These are some of the most testing waters around the UK and a local station must be essential for maritime safety. I regularly sail in the waters covered by Stornoway Coastguard and have firsthand experience of how important it is for the area. Any downgrading of the station could have serious ramifications the more so in the light of the massive future west coast development of marine based energy generation. These activities will greatly increase marine traffic. The UK government must be stupid to think that all THREE of the coasts of Scotland can be covered by one coastguard station in Aberdeen. The minimum needed is one on the East Coast, one on the west Coast and one to cover the Orkneys and Shetlands. Having worked within the Minch and associated areas covered by the Stornoway Coastguard for the last 25years) and having on numerous occasions needed their assistance, co-operation, and co- ordination in situations which could otherwise have ended in serious injury or fatality!!! I personally think that the loss of local expertise, knowledge, and 24 hour coverage would amount to sheer folly, resulting in an increased rise in the fatal outcome of many incidents. I have worked with the coastguard for 12 years in my position as GP on the small isles. Services did not improve with Oban coastguard station discontinuing. I can see severe problems with trying to centralise the service even further to one station based in Aberdeen. that is east coast. We are west coast!!! If Stornoway was to close lives will be lost because of lack of local knowledge in an emergency. I am greatly indebted to Stornoway coastguard for probably saving the life of my 19 year old son who had a serious heart problem while fishing in the Minch. The speed with which they reacted and airlifted my son to hospital made all the difference between life and death. I fear this speedy response will be lost if station was to close. Stornoway has so much coastline to cover. Local knowledge is paramount ... how can someone in Aberdeen know where all the ins and outs of the western isles and northwest coast of the Mainland. It’s ridiculous to even think of it. All it would take would be one incident and a misunderstanding by someone in Aberdeen trying to understand gaelic and it could all go downhill. This proposal is flawed and obviously it was drawn up by MCA management looking for brownie points ,see me what I have done to save money, they have little or no maritime knowledge and their aim is look after number 1. Where do they propose to get the additional staff required at Aberdeen MRCC when at this time it has a 30 to 40% staff turnover. What about local knowledge there are many headlands, islands etc with local names not marked on maps or charts and additionally many places have the same names , for instance there are five Pabbay islands in the Hebrides chain. Keep Stornoway as a 24 hour station guarding the west coast and the north west approaches to the UK, mariners work 24/7 not daylight hours The average time for incidents in the Stornoway area is around three to four hours and not a 10 minute smash and grab as happens in southerly stations. I have no doubt that I owe my life to Stornoway Coastguard and Stornoway Coastguard Helicopter. These plans show little appreciation for the need for rescues to be coordinated with 100% clarity and speed. When I get a “shout” I want to know asap, where I am headed and vital time could be lost with the communication side of things, thats when lives can be lost. Think of this going over the radio to someone in ABERDEEN “I am in loch Bun Abhainn Eadarra” or “I am two miles off Gob Rubha Bhalamuish Bhig”!!!, WE NEED FOLK FROM THE WEST COAST, ON THE WEST COAST, LOOKING AFTER THE WEST COAST What are they thinking about, as an ex Coastguard Watch Officer I know that local knowledge combined with the vast amount of Search and Rescue Skills save lives. Yes in theory the technology makes it possible to co-ordinate all rescues from a single centre, what next, MRCC Delhi staffed by call handlers working from a scripted check list? Technology has its place but cannot replace the highly trained Coastguard who knows the area and all of its meteorological and tidal anomalies, a skill that can only be developed and maintained by working within that area. The Northwest corner of the UK is surely a strategic location for a 24 hour station let alone daylight only. If closures must take place surely it is more sensible to relocate to the “corners” of the country where shipping have to pass whether going North, South, East or West? Obvious to the four “corners”, Stornoway, Aberdeen, Dover and Falmouth. Aberdeen(safe)—vital for Oil/North sea. Dover(safe)— Channel separation system/English Channel. Falmouth—provides worldwide SAR through satellite systems and have a good knowledge of international SAR/Southwestern approaches to the UK. Stornoway—provide cover to the North Atlantic UK SAR area and cover the most remote coastline of all the UK. The Northern and Western Isles should be left with the status quo due to the extremes of weather all year round. Assistance to these areas depends greatly on local knowledge which cannot be transferred to an IT system as things change daily and even hourly in some locations. This possibility, if it comes to fruition, would be an act of folly. While it may seem like a good suggestion as discussed in a comfortable office, I rather suspect that the seamen about to enter the North Atlantic or Minch waters as their vessel sinks from under them would hold a markedly different viewpoint. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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As a long standing member of the Stornoway coastguard helicopter crew I believe that the Stornoway coastguard station is a vital link for the west side of Scotland. To have no link is a backward step and will result in difﬁculties co-ordinating between the auxiliary coastguards, RNLI and the coastguard helicopter. It is imperative that this link remains intact otherwise unnecessary casualties may be the end result of this closure. The atlantic coast from Cape Wrath to Northern Ireland has to be one of the most treacherous sea areas in Europe if not the world and closing a base which covers a majority section seems madness to me. The Coastguard Operations Room is not a call centre. Local knowledge is a vital part of this service and its importance should not be underestimated. Their excellent personal relationships with Coastguard volunteer teams, lifeboat crews and other organisations helps them save lives—please don’t let us lose this! I have spent 36 years in Caledonian Macbrayne serving as Master of the various West Coast Ferries since 1980. I am very concerned that the whole of the West coast of the UK may be left without a Coastguard station in the aftermath of such closures. It may well be the case that technology is advanced nowadays but there is nothing like local knowledge when lives of seafarers are in danger. This local knowledge assists in making quick decisions in dire emergency situations and in my opinion is instrumental in saving lives when minutes and even seconds are of vital importance. I feel that the “need” to have two stations in the South of England makes a strong case to have two full time Stations in Scotland one East and one West. This would be best served by Stornoway serving alongside Aberdeen to redress the very substantial imbalance the proposed closures and the future plan will cause. The Minches are a vital part of the ecology of this nation and the closure of our local station in my professional opinion will have a potentially detrimental effect on this. As a leisure boat user out of Applecross I value the Coastguard presence at Stornoway, the local knowledge and experience and the regular weather updates. I would lose a lot of reassurance if it were lost and would be hard to persuade that this constitutes an improvement more than a mere cost saving at the expense of service and in this line of work that could mean lives. This proven, cost effective service covers the North West coast of Scotland and the NW SAR region, its contribution and that of its staff to maritime safety and cannot be disputed or underestimated. Knowledge, familiarity, expertise and skills are of fundamental importance in any emergency, the local knowledge, familiarity, expertise and skills applicable to this vast SAR area even more so; given the adverse, time critical scenarios to which this station responds. In these scenarios the things in balance are lives, shipping and the environment, not something easily understood or conveyed in the bottom line of a balance sheet, or political agenda. Any reduction to this service will unquestionably put lives, shipping and the fragile marine ecosystem of this remote and world renowned area at risk, and as can been seen in most maritime disasters the costs of which vastly outweighing any savings potential. These points cannot and should not be brushed aside, failure to address them would further illustrate the lack of understanding and cognisance of the real issues, that pre-empted this initial decision and exposes it for what it real is, i.e. hasty and ill considered, driven purely by short term ﬁscal constraint, rather than properly considered long term maritime and environmental safety. April 2011

Further written evidence from the Save Stornoway Coastguard Campaign Team (MCA 05b) 1. The Present Situation 1.1 Responsibilities 1.1.1 As a service, we are primarily responsible for “civil maritime search and rescue within the UK Search and Rescue Region”, which includes “the mobilisation and organisation of adequate resources to respond to persons at risk of injury or death at sea or on the coastline”. We are also responsible for provision of maritime safety information, medical link calls from ships to hospitals and mutual assistance to other Category 1 responders as part of the Civil Contingencies Act. This sees us frequently deploying our resources to land- based search and rescue incidents and assisting the medical authorities in transfer of patients from remote communities to hospital facilities. 1.1.2 Over recent winters we have also assisted in ﬂood rescue and civil emergencies caused by prolonged snow and ice conditions. Stornoway and Aberdeen are also reporting stations for vessels transiting the Minches and Pentland Firth IMO reporting areas, respectively.

1.2 Technology 1.2.1 At present, each station has a deﬁned operational area of responsibility along with a set number of VHF aerials providing coverage for the UK’s GMDSS A1 obligation; some stations have MF, fulﬁlling the cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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GMDSS A2 obligation. Each station is connected to its respective aerials via BT “kilostream” lines connecting the strategically placed aerials with the distribution equipment in the station via exchanges. 1.2.2 The system controlling radio and telephones is the Integrated Coastguard Communications System (ICCS), installed some 10 years ago but updated frequently since. The command and control software is the Incident Management System (Vision), which is similar to Police and Fire control systems offering databases, mapping and dynamic incident management within one software package—this too is approximately 10 years old but has been frequently updated. 1.2.3 Vessel monitoring is provided by the C-Scope software platform for the Automatic Identiﬁcation System (AIS), offering real-time tracking of merchant vessels operating under SOLAS agreement and over 300 gross tonnes, along with ﬁshing vessels over 24 metres in length (although this is subject to change shortly). 1.2.4 Search planning software is the now rather old SARIS system, and there are other IT packages for miscellaneous functions such as tidal predictions, data recording, etc.

1.3 Manning 1.3.1 Manning levels vary across the service, with as many as 32 watch keeping ofﬁcers in, for example, Clyde, while at the other extreme Forth has only 16. Safe manning levels are locally agreed and subject to an ongoing written risk assessment at the commencement of each shift by the duty Watch Manager.

1.4 Local knowledge 1.4.1 The service is robust currently, with staff having a great deal of local knowledge of their operational area. This enables tasking of the correct unit, in as quick a time as possible, to the right location while understanding the nature of the area that the unit is being asked to operate in. The route from casualty to coordinator to rescue unit is as direct as it can be, and good liaison and understanding between MRCC and the units involved leads to efficiencies in co-ordination as all problems have been ironed out and there is mutual trust that each understands the role of the other. All tasks relating to the co-ordination of an incident (search planning, communications, chart work, etc) are carried out within the Operations Room responsible for dealing with it, under the supervision of a Search and Rescue Mission Co-ordinator (SMC). This ensures that at any one time the SMC has a full picture of the situation both on scene and within the operations room. 1.4.2 The current MCA proposal stands to see Scotland, which has 60% of the UK coastline and more than half of its offshore Search and Rescue Region, left with only one full time station at Aberdeen plus a second station at either Stornoway or Shetland, open only during daylight hours (generally 0700–1900 local time). It disregards any form of local knowledge, placing it instead on the dubious ability of “technology” or at the feet of our volunteer Coastguard Rescue Service. It pays no heed to our unique cultures, languages or local accents and takes no account of the needs of those we serve, except the professional mariner in large vessels able to accurately pass a position in latitude and longitude format. 1.4.3 We feel that local knowledge is often being misrepresented by MCA spin in an attempt to allow their plan to “go through”. It is not the in depth knowledge of the RNLI crew, who will know the area of sea they operate in intimately, nor the volunteer Coastguard Rescue Officer who lives and works in the locality of the incident and would have a correspondingly detailed understanding of this environment. The local knowledge we talk of is a “situational awareness” of a coastal and maritime environment. It is the understanding of the geographical features, topography, weather, daily activity patterns, the users of the water (fishing, merchant, renewables, leisure, etc), the users of the coastline and littoral areas (walkers, anglers, etc), the culture, language and accents, the personalities, communities and last, but by no means least, the working relationship between the station, the units it calls out and the civil contingency partners it works with. 1.4.4 Place names throughout the West Coast and the Inner and Outer Hebrides are predominantly Gaelic with many duplicates, often subtly different in pronunciation. Places are often given nick-names which appear on no maps, charts or Internet sites such as Google Earth. Environmental conditions are some of the most extreme in the UK and our coastline is some of the most intricate and diverse in Europe, attracting large numbers of visitors to take advantage of our waters. Awareness of this maritime picture enables us to place the casualty at ease instantly with the assurance that we know where they are and what they are experiencing. While they are in communications with us, we know the appropriate units and we will task and co-ordinate the actions of these units with which we have built a good working relationship over many years of interaction within our operational environment.

1.5 Training 1.5.1 Currently, training is an expensive part of HM Coastguard’s running costs, with a “central” training centre in Highcliffe, Dorset. All technical training is conducted on site, and generally trainers are recruited from the ranks and then spend a variable amount of time as trainers (sometimes very long periods). 1.5.2 Recently, there was an initiative to regionalise trainers so that more courses could be run on-station, thus saving travel and subsistence costs, along with overtime to replace staff while they were off station. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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2. Questions and Points to be Raised

This section presents a number of questions and other points arising from information (or lack of it) in the MCA’s consultation document and supporting publications. The main points are in bold, with supporting answers or information below.

2.1 The consultation document proposes “a modernised Coastguard service that exploits the potential of [existing] technology with a networked national service”, yet it is the MCA’s intention to merely refresh and upgrade their communication system (ICCS)—a system which has been in use now for 10 years. It is also their intention to enhance systems such as C-Scope AIS, the Vision data management system, and also to make more use of Internet-dependent systems such as Google Earth, Long Range Identiﬁcation and Tracking technology (LRIT) and SafeSeaNet

2.1.1 What “shelf life” does the MCA consider for this upgraded/enhanced technology considering it will be required to function as an integrated network, and is it not likely that there will be greater costs incurred and a lack of reliability/resilience in the longer term as the core operational technology shows its age, and requires replacement?

2.1.2 Google Earth, GIS (Graphic Information Systems) do not take into account local names, Gaelic (Scottish or Irish) or Welsh spellings, etc. Example: Loch Tamanavay (Gaelic spelling Tamnabhaigh), pronounced Hamanavay, neither of which can be found using Google Earth. When Google Maps is used to ﬁnd East Loch Tarbert, it automatically jumps to the Outer Hebrides; however, there is also an East Loch Tarbert on the Kintyre Peninsula. These are just two of the many examples.

2.2 The MCA states that at present Coastguard ofﬁcers have different workloads throughout the UK’s 18 MRCCs, which means that individuals have very different opportunities to actually put their technical skills into practice; in other words, some Coastguards get to use their skills more frequently than others, depending on geographical location. One of the aims of the proposal is to balance out these disparities whilst spreading the workload, therefore realising the staffs’ full potential

2.2.1 The staff at sub-centres may be promised the same training, roles and skills as staff at the MOCs, yet they will never have the opportunity to apply their knowledge to incidents arising in the hours of darkness. Some examples of particular subject areas of relevance are given below: — search planning; — meteorology; — investigating/locating the source of possible ﬂare sightings at night; — working with Search and Rescue Units operating at night; and — application of our required knowledge of vessel lights, navigation marks, lights and buoyage systems, for example if a close quarters situation with two vessels occurs.

2.2.2 In addition, any new staff recruited at the sub-centres will have to receive the same training as those at the MOCs, but will not then go on to gain the same level of practical experience. It is proposed that when larger incidents occur around the coastline of the UK, then SAR co-ordination will be executed by one of the MOCs and not the sub-centres: again, opportunities for valuable experience will not be shared and sub-centres will ﬁnd that incidents which grow in severity or urgency must be handed over for the MOC to control.

2.2.3 Does the MCA recognise that, within their proposed new structure, the disparities in the use of staff skills and knowledge in fact still exist, and that they are creating a two-tiered Coastguard?

2.3 The new organisational structure outlined in the proposal mentions that one of the responsibilities of the “Team Leader” is the discharge of speciﬁc functions such as emergency call handling, search planning cell and CERS processing. This clearly indicates that “Teams” will be assigned speciﬁc duties to perform and therefore will not necessarily be responsible for every aspect of an incident through to its conclusion

2.3.1 The present UK maritime rescue co-ordination system allows a SAR incident to be co-ordinated by a team of people in the same operations room from start to ﬁnish, with any learning points then collated and shared as appropriate.

2.3.2 Currently, Coastguards gain the most job satisfaction from being able to work as a Team to ensure an incident is co-ordinated right through to a successful outcome. Breaking this process up into components and farming out tasks throughout the national network is likely to result in staff becoming more disjointed from the whole SAR picture. As the whole is always greater than the sum of its parts, why establish a more centralised national co-ordination network to then de-centralise the critical functions of a search and rescue mission and blur the boundaries of accountability? cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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2.4 Introduction of the new structure relies heavily on large numbers of existing fully qualified and experienced staff being able to relocate to the MOCs, in order to at least maintain the current standard of SAR coverage in the UK 2.4.1 Not only are these premises to be located in two of the most expensive parts of the UK in which to live, the MCA are expecting their staff and their families to move house, change their way of life, embark on a new role with a new training programme, and in some cases to realise a lower standard of living as well. In the last 10 years, Coastguards have largely been recruited locally and therefore have much stronger ties to their present locations than the original “mobile” Coastguard grade that in the distant past attracted staff from other UK locations. This is, therefore, a considerable expectation of staff, who have also suffered from low morale and over three years of industrial action. 2.4.2 Given that the whole proposed re-structure hinges on having a large pool of existing Coastguard officers willing to relocate, has the MCA carried out a feasibility study on this aspect alone, and if so what are their findings? How do they intend to man the MOCs if they have to recruit and train potentially more than 50% new staff? Have the costs of this been considered? In the last round of closures, only 10% of staff moved: that will surely mean considerably more than 50% unqualified staff in the new structure. The MCA will also lose many years worth of experience and local knowledge, as anyone employed in the future will generally be recruited from the area of the MOCs and not from the areas currently in operation.

2.5 The MCA intend to make Aberdeen a Maritime Operations Centre, yet this will tie them into a 25-year commitment to a site they do not own, at the same time potentially closing viable alternatives. How do they explain this? 2.5.1 We cannot understand how this will be allowed ﬁnancially when Aberdeen costs 6 times more than Humber, Portland, Forth, Shetland or Stornoway in running costs, is the most expensive in the UK (next most expensive MRCC Clyde) and has suffered historically high staff turnover. The cost of keeping Aberdeen open could pay to keep Shetland, Stornoway and Forth open. This decision is due more to internal politics than sound reasoning. 2.5.2 Why have no options have been explored for modiﬁcation of existing estate? 2.5.3 Have no options been looked at regarding use of secure data centres to house server equipment, thus allowing another site to be considered for a MOC?

2.6 With regards to the Coastguard Rescue Service (CRS), the consultation document states that “in the future it is also intended that the CRS, led by a new management structure, would deliver the co-ordination function for land-based incidents in alignment with other partners in the emergency services” 2.6.1 How would a Coastguard Rescue Team leader be able to do this? The Coastguard Rescue Teams, which form the core of the CRS, are made up of volunteers who have other occupations and roles to play within their communities. They are allocated a basic allotment of only 22 hours training per year, yet the MCA expect to place co-ordination of what may be a multi-agency response at their feet. To add this co-ordination function to their existing skills set would not only require considerable additional training, but also a willingness by them to take on the added responsibility. Does the MCA think that it is acceptable to place such responsibilities on volunteers who receive only a little remuneration for their time? 2.6.2 In addition, if it appears that a “contract” exists between an organisation and a volunteer for work undertaken, then the EU Working Time Directive applies; has that issue been taken into account when planning future enhancements for the CRS? 2.6.3 The MCA do not state what enhancements in equipment would be required to enable this, and from questioning we have been unable to gain sufficient detail from them. It is not possible for current Coastguard vehicles to provide a sufficient platform for co-ordination of a major land-SAR incident involving communications searches, unit co-ordination, SAR planning, and the ever-increasing burden of logging all actions taken. To run this (from personal and current experience) is a large task for an experienced team of four officers in an MRCC. This will not work. 2.6.4 There are more often than not maritime SAR units involved in our response to coastal incidents (even those that are land-based). Under this proposal, will the CRS find themselves co-ordinating one part while the MOC co-ordinates the other? This is how mistakes occur and will result in an increased risk of fatalities. 2.6.5 Currently, we as Coastguards need to hold an SMC certificate to co-ordinate incidents. Yet there is no requirement for Sector Managers, but if this proposal goes ahead, they must surely be qualified to do this (it is an IAMSAR requirement). Have the MCA allowed for this in their training budget? If not, why not?

2.7 The Consultation document states the typical pattern of demand by month, of incidents in 2009, peaks in the summer months. How was this information collated and how accurate is it? 2.7.1 For the last three–four years the Coastguard service has been on a work-to-rule as part of industrial action, which means ministerial targets have not be accurately recorded during this period. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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2.7.2 The duration of incidents have not been taken into account, just the number of incidents opened by each station. Example: a medical evacuation from land on one day in July 2009 took 1 hour at one Ops Room, and on the same day another Ops Room spent 6½ hours dealing with the same type of incident. Another example: one station dealing with a vessel appearing in difﬁculty, which took two and a half hours to bring to its conclusion, yet another station spent 45 minutes dealing with the same type of incident. The consultation document does not take into account the total staff input, with regards to time and effort, that each of these incidents took.

2.8 How does the MCA intend to replace the local knowledge that their proposal is going to lose, and how can an emergency call be resolved if the operator taking it has no idea of the area of the incident? 2.8.1 The answer that they will provide 24/7 on-call officers, or use the RNLI, CRS, or NCI, is inadequate on the following grounds: — This will build in a delay in the process, this being entirely dependent on getting the right person quickly. This may fail due to paging problems in the first instance (some stations often spend 10–15 minutes trying to call teams out due to black spots, of which the MCA are aware but unable to address). — These on-call officers will be one of a team of six in a district, so there is no guarantee they will have the information to be able to help, particularly in remote or island areas. — It relies on volunteers being able to resolve an issue that they may not be able to, or indeed may not be available to by nature of work or other commitments. — Any time lost at the outset of very urgent situations (for example persons in the water) can never be regained; this will lead to an increase in fatal outcomes for certain types of incident. — These on-call links will have no idea of the actual “maritime picture” that exists in each MRCC at that moment, and accordingly will be unable to advise of small craft movements, leisure activity, availability of SAR units, etc. 2.8.2 The answer that “we will make enhanced use of technology such as databases and Google Earth” is inadequate on the following grounds: — Can databases predict colloquial place names that do not exist on maps? Answer: NO. — Does Google Earth recognise a lot of coastal features and place names? Answer: NO—we have tried this and it fails. — This is dependent on an operator entering the information in a format that the system can recognise—how will an operator with no idea of languages such as Welsh or Gaelic (Scottish or Irish), which is prevalent in place names on the west and north coast of Scotland, be able to understand the caller and put that information in accurately? Answer: IT WON’T WORK. — The EISEC system for emergency calls is a system whereby caller identity and location is made available to an emergency operator. This is unreliable to seaward and in many coastal areas, particularly on the west coast of Scotland where cover of any sort is patchy, and does not work for roaming emergency calls. Yet, the MCA expect an operator to be able to identify a casualty on the other side of the country amidst poor reception, unfamiliar language and no firm lat/long or OSGB reference being given by an often distressed first informant!

2.9 In the Consultation document, the MCA say local knowledge can be obtained from Coastguard Rescue Team members, RNLI & NCI. These are all volunteers who usually have full-time jobs. Have they been approached to ask if they are happy to be woken at 2 am to be asked where a speciﬁc location is? Have the costs for this additional task been calculated? — Coastguard Rescue Team members at present have not been asked. — This would incur an additional cost for calling out the Coastguard Rescue Team member, which is currently three hours minimum pay. If they were called more than once in the night, would they be able to claim twice? — Some RNLI Launching Operation Managers (LOMs) have not been approached. — Would the cost of calling a LOM be paid by the RNLI, or is it a costing to the agency at RNLI rates?

2.10 The MCA place great faith in provision of technology to track and locate vessels that may get into difﬁculty, yet this is only a tiny proportion of their annual casualty statistics. They need to explain how they will ensure that the small craft operator (whether commercial or leisure) is guaranteed a safe response? 2.10.1 The current link, whereby the MRCC has a dynamic understanding of small craft and coastal activity, will be broken. Examples such as the current TR (trafﬁc report) scheme—in which leisure craft are able to report activity to us, which we log and are then able to use in situations such as overdue or missing vessels and to provide resources for response to distress situations—are lost. This will again increase response time and affect the ability of the SAR system to resolve particular types of incident. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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2.11 Scotland has approximately 60% of the UK’s coastline yet will hold only one 24 hour station and one daylight station. Where is the logic—surely this is not strategic positioning of stations? 2.11.1 We believe the MCA answer will go with their statistics of 20% of incidents occur in Scotland. This is flawed on the following grounds: — The proposal makes reference to workload sharing—surely then anywhere in the UK could be selected if the planning behind this statement is correct (which it isn’t). — The statistics are purely quantitative and take no account of incident duration, complexity, units involved, terrain, distance, weather, etc. All these are significant factors in the number of co- ordination staff needed to deal with an incident. The answer that the first 20 minutes are key surely takes us back to the fact that the first period is where detailed local expertise is necessary in order to deal with this incident—not someone on call filling the gaps!

3. Critique of the MCA’s Retrospective Risk Analysis 3.1 Risk commentaries Search and Rescue coordination risk commentary Risk 1: Insufficient staff available causes mission failure by delayed or incorrect response 3.1.1 The MCA provide no valid data to back up this statement. Data should be available with the number of incidents that have been affected by either of the above. If this has happened, then what procedures has the MCA put in place to prevent reoccurrences? Coastguards are highly trained and multi-disciplined; they have to multi-task on a daily basis, with incidents, search planning and routine tasks, etc. If there are problems in this area then the data should have been published as a percentage of total number of incidents. 3.1.2 It is obvious that insufficient numbers of staff can potentially contribute to failure or delayed response to any mission. Insufficient staffing problems have the potential to occur anywhere and by reducing the number of Coastguard co-ordination centres, this risk is actually increased. 3.1.3 HM Coastguard states that it currently mitigates the risk by filling overtime on watches that fall below minimum manning. This does happen, but only after looking at all other options, ie cover from other watches. 3.1.4 In the proposed new structure, there will be flexible rostering across the network with the use of sub- centres for surge capacity. It has yet to be confirmed how this will be managed: if a MOC is using a particular aerial for an incident, it cannot be used by one of the sub-centres. 3.1.5 If it was proposed that a more feasible number of current rescue centres remained, and these were configured so that they could share access into a UK SAR communications network, then should one station suffer from a major staffing problem, such as a flu outbreak, then that station’s flanks (or even further afield) could share the workload until it is back up to strength again. Similarly, this could be done for training and development. 3.1.6 With only two MOCs located in highly populated areas, and no doubt staff travelling between the two, the staffing resilience is potentially weaker. The MOCs are essentially a form of “call centre”. Call centres have the highest rates of staff turnover. It is currently predicted that as the economy grows out of recession, more staff will be aiming to move away from the “call centre” environment and into better-paid and more appealing careers that offer long-term benefits. Coastguard co-ordinators need to be highly trained; therefore, we need to attract staff who are going to stay the course and build up their experience. In areas such as Aberdeen and the south coast of England, where jobs in the maritime sector are quite abundant, there is a much greater risk of staff using the MCA Coastguard training programme as a stepping stone into other more lucrative occupations. 3.1.7 From the outset of the consultation process, existing staff have expressed their concerns that they will not be able to afford to relocate to the MOCs or to other sub-centres, given the current economic climate and particularly that Aberdeen and the south coast of England are two of the most expensive areas in the country. Therefore, it is highly likely that if the transition into the new structure goes ahead the MCA will inevitably loose a large proportion of its most experienced and reliable staff. This will be irreversible.

Risk 2: Skills fade causes mission failure by delayed or incorrect response 3.1.8 The MCA provide no data to back up these statements. If this has happened, they should be able to provide details as a percentage of the total number of incidents. Information should also be available on what action is taken to prevent these situations from happening or reoccurring. 3.1.9 Training is undertaken during quiet periods to address the lack of live incidents, and competencies that are not routinely faced are addressed in a controlled environment. 3.1.10 One proposal put forward by management at a staff meeting was that if one station had not had many 999 calls and their skills were fading, all 999 calls for the whole country could be routed to that station for a set time, to allow skills to be used/improved. This just puts an extra leg in to an emergency call, which will lead to time delays and mistakes. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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3.1.11 It was stated at a recent meeting with management that the new structure will involve hubs/cells for different working regions, enabling operators to gain local knowledge for the area they will be working. If this is the case, how can directing live work at individuals work to maintain and develop their skills with different types of incidents? Again, it is plainly obvious that if staff do not refresh the skills they require to carry out their job effectively, then there will be an element of skills fade. Gaining experience through exposure to live incidents of different kinds can help with this; however, there are types of incident throughout the UK that very rarely happen and therefore there is little chance of all Coastguard co-ordination staff sharing this “live” experience. Examples of this include incidents posing a threat to the security of a ship, its crew and its cargo, incidents involving radioactive, nuclear or biological materials, terrorist incidents involving multi-agency response, and passenger aircraft crashes, to name a few scenarios. 3.1.12 The UK mitigates the risk of failure in response to these types of scenario through Emergency Planning, Civil Contingencies Planning, and regular multi-agency exercises, both live and tabletop. The keywords are “prevention, preparation, response and recovery”. The primary method of ensuring that skills fade does not occur is by providing quality training for operational Coastguards including refresher programmes, complete with incentives such as bonuses on successful completion. 3.1.13 Coastguard operations staff have remained locked in a period of industrial action for the last four years approximately, regarding the low remuneration received for their work. Throughout this period, they have also been aware that the MCA was making plans to close a number of existing MRCCs as part of a modernization of the service. Morale and motivation has been at an all time low, and with staff feeling so undervalued, until the MCA is seen to address this long outstanding problem properly, their staff will no longer be prepared to go that extra mile.

Risk 3: Insufficient qualified staff available causes mission failure by delayed or incorrect response 3.1.14 Where is the evidence to support this? How many incidents were there with no qualified SMC that led to poor decision making? 3.1.15 Again, if in the new MOCs there are going to be hubs/cells to enable staff to gain local knowledge of an area, how can this give more flexibility within the MOCs, as staff from one cell will not have the knowledge of the other cells areas. 3.1.16 Management have already admitted there may be a delay in tasking resources due to having to contact a SM/CRT or the RNLI to confirm locations. This should not be acceptable. 3.1.17 In a MOC structure, there is more likelihood that watchkeepers or the SMC will not see information, as there will be more noise and distractions in the background. 3.1.18 The existence of effective, fully trained managers or Team Leaders is a vital part of any organisation. However if they do not have the full support of valued and motivated staff, the standard of work will fluctuate. 3.1.19 At present, there must always be a watch member who assumes the role of SAR Mission Co-ordinator during every watch at every station. Ideally, they should be SMC qualified; however, it is also procedure that the role can be delegated to a fully competent and able Watch Officer. The District Management Team, and in particular the RCCM, has the responsibility to ensure that any Coastguard officer assuming the role of SMC is experienced and fully capable of taking on the responsibly. To the best of my knowledge, within the present system no watch is ever permitted to run without a suitable officer delegated as SMC.

Risk 4: Non-observance of procedures causes mission failure by delayed or incorrect response 3.1.20 Where is the evidence to support this? In how many incidents did the above happen? If it has happened, what is the percentage? 3.1.21 Incidents often begin with minimal information, while the rest of the team within the operations room continues to gather more information. Incidents are dynamic and can continually change with the updating of information. Within the current structure, Coastguard co-ordination staff face a plethora of procedures and policies, and with the various amendments and updates it is impossible for a human mind to remember everything. The most effective way of ensuring easy recall of essential procedure is to aim to keep the procedures as straightforward as possible. The appropriate documentation should be concise, easily read, and stored in an easily and quickly accessible location. Unfortunately, in our computer-driven world, we are increasingly reliant on our IT systems to keep us on track with procedures. This means that the risk of failure to comply with procedures will become much greater should a computer system fail. The new proposed structure indicates a totally computer-driven environment containing a “restructured rules set” that will use “live feedback to keep it current with emerging best practice”.

Risk 5: Insufﬁcient staff available causes non-emergency, safety critical tasks not to be performed 3.1.22 Where is the evidence to support this? What percentage of routine tasks are not performed? 3.1.23 When a MRCC is overloaded with work, they request the assistance of their ﬂank/paired station to support them, as well as the DAO attending the operations room to assist. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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3.1.24 The Maritime Safety Information broadcast is already automated and at MRCC Stornoway has been used religiously since the ICCS installation in 2000. Staff record each forecast section as updated weather information is received into the operations room. However, it should be noted that while incident communications are ongoing in a specific area using one or more aerials, then these aerials would generally be selected so that the MSI system does not lock onto those aerials and interrupt SAR communications with a routine MSI broadcast. This would be a contravention of radio regulations if a Mayday broadcast had been issued. It does not mean that the whole MSI broadcast is aborted; it will be made on the remaining aerials that are not being used for SAR. 3.1.25 With regards to AIS, OAN 487 outlines the MCA’s Operational Policy for the system’s use. Operational Policy paragraph 9 specifically states the following: MRCC Dover is already using AIS to enhance CNIS but elsewhere as a matter of policy, MRCCs will not undertake positive or active monitoring of AIS and will not dedicate an operator(s) to AIS choosing to meet the current requirements of the VTMD by passive monitoring through electronic methods. So, as for AIS not being monitored for navigational safety, whilst staff do regularly look at AIS to see the general traffic movement in the district, as it states above…we are not to undertake positive or active monitoring of AIS…! There are two AIS terminals in the operations room and a large plasma screen with the AIS picture on it. Should a SAR incident occur in an given sea area, then it is quite natural to look at AIS not just to see what ships are in the vicinity, but also to use it as a positional reference. Coastguard helicopters also show as targets on AIS, so we do keep an eye on their movement. 3.1.26 Following on from accident investigations into incidents such as Aquila, FV The Brothers, the loss of Cadet Kayleigh Macintosh in Loch Carnon, we have often come under criticism from our own MCA SAR Branch for dealing with “routine calls” during these extensive incidents. The operations staff have vehemently defended our actions because we have to answer all incoming calls. Every call could be the source of a vital piece of information, or it could be a call reporting another incident. When we take the call, we make a judgment regarding the type of call, and if it is of a routine nature that can wait until later, then we explain to the caller that we are casualty working and ask them to call back in a specified time. In my experience, the callers fully understand and appreciate our situation. As weather and tidal information is freely available on the internet, if they are planning a passage they can retrieve this information and then call us later with their plan. 3.1.27 The MCA states that there would be a greater use of Digital Selective Calling (DSC) for routine traffic and use would be made of intelligent call routing. DSC has been around for a number of years now and not many recreational sailors use it. How will customers be encouraged to use it? The system will only work well if all use it: the MRCC and the maritime community. With a VHF base set fitted with VHF DSC costing around 300–400 pounds, for seasonal leisure small-craft users this is quite an expense—what about jet skiers, kayakers and paddle boarders? Should these people wish to carry VHF, then it will need to be one equipped with VHF DSC and integrated GPS to give a position. However, kayakers, for example, may report their intended movements to the Coastguard but then turn their radio off to conserve the battery in case they do need to raise an alarm. 3.1.28 Intelligent call routing will not work in an emergency service. We have a 999 emergency telephone network that prioritises calls. 3.1.29 The MCA feel with increasing use of GPS/satellite tracker devices, this will “take the search out of Search and Rescue”. So, in their perfect world every seafarer and coastal user will have a device that will be able to give positional information. Of course that would make life easier, but what happens when a family member phones and reports a loved one not returned from a walk and no answer from their mobile phone? Within the current system, the ops team question the first informant, using their local knowledge, mapping and experience to produce a search plan. As an emergency service, we need to be prepared to deal with the difficult, challenging scenarios, not just the textbook ones.

Risk 6: Misapplication of local knowledge causes mission failure by delayed or ineffective response 3.1.30 What is the percentage of incidents where this has happened? 3.1.31 “An incorrect resource may be tasked to an incident, which ultimately could lead to casualties not being located, or a rescue delayed”. In the new MOC structure this is more likely to happen because, as management have admitted, there may be a delay due to having to phone a SM or CRT to conﬁrm incident location and most appropriate team. Minutes count when lives are at risk. 3.1.32 CG3 Volume 1, Part 1, Chapter 2, Section 10 clearly lays down the national guidelines for local knowledge tests, including the number of questions, marks per question and the national pass mark of 80%. These tests are and have been open to auditing. 3.1.33 There may not be a policy to recruit on the basis of regional dialects or non-English language skills, but this does happen. With recruitment completed locally, it generally means CWA posts are ﬁlled by local persons, who then advance by TAN (Training Ahead of Need) to WO grade and beyond. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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3.1.34 The statement about concept of operations is wrong: the current concept of operations is based on the Maritime Operations Review 2000, which was implemented in 2003. 3.1.35 “The concept of operations for the proposed future structure will be based on factual knowledge derived from informed investigation and interrogation of information systems.” This statement describes the system as it already is in its current form. 3.1.36 It is not possible to place a value on the existence of good quality local knowledge. It is the local knowledge and experience, often built up over many years, that allow Coastguard officers (working as a team) to respond quickly and efficiently to calls for help. It is humanly possible for us all to make mistakes from time to time: it does not matter where you happen to be based, what computer databases you have, or who is supervising—humans do make mistakes and that is why the emergency services exist in the first place. 3.1.37 Within the present structure, coastguard officers have enough local knowledge between them “contained in their brains” to be able to affect a rescue should all the databases/IT systems fall over. In the new proposed structure, the MCA wants to rely more heavily than ever on technology, so the risk of failure is greatly increased should the IT network completely fail. Using systems such as Google Earth creates a dependency on the integrity and stability of the Internet connection. 3.1.38 The Agency also states that Coastguards in the new MOC will be exposed to familiar operational areas or zones. So if the MCA decide to close MRCC Stornoway or MRCC Shetland and none of the existing staff at those stations are willing or can afford to relocate to MOC North or South, who in these MOCs will be familiar with either Shetland’s or Stornoway’s current districts? Are they then going to have to waste more taxpayer’s money in paying for local knowledge trips to these locations? 3.1.39 Should staff have no choice but to leave the Coastguard as a result of these proposals, then the local knowledge and skills will be lost, so the so called “local knowledge harvesting” will have to start from scratch. 3.1.40 The MCA state that “the Coastguard can still draw on detailed local knowledge by contacting a wide selection of coastal community based resources (Coastguard Rescue Teams, RNLI, National Coastwatch Institution, harbour and port authorities)”. So Coastguard officers who do not have the local knowledge to respond quickly to an incident will have to waste precious time phoning “local experts” for local knowledge.

Risk 7: Disruption to the chain of command causes mission failure by delayed or incorrect response 3.1.41 Again, the MCA does not provide statistics. How may times has ineffective decision-making led to mission failure or delay? 3.1.42 Within the present structure, operational decisions are made by SMCs available around the coast 24/ 7. If it is essential that Tactical and Strategic ofﬁcers are required 24/7, then this duty could be rotated around suitably trained and experienced Watch Managers (SMCs) in the MRCCs around the UK. Bearing in mind that Tactical and Strategic level decision-making is not required on a regular basis within HM Coastguard, is this not more cost effective to be left as it is?

Coastguard Rescue Service Risk Commentary Risk 8: Non-observance of procedures causes mission failure by delayed or incorrect response 3.1.43 Where is the evidence that safe systems of work are not being applied by Coastguard Rescue Officers? 3.1.44 Incorrect or failure of alerting/paging systems, paging incorrect teams or delayed call out while telephone alerting is carried out. Alerting/paging systems should not be taken into account for Coastguard Rescue Service risk as it is an Operations Room task and failure of the systems can not be mitigated by training of volunteers. This can be tied in with the quality of local knowledge in the Operations Room. The more familiarity that the staff have with the local Coastguard Rescue Officers, their places of work, habits and best means of contacting them, the better. 3.1.45 Enhancement of the Sector Managers role is welcome. At present, they spend too much time on MCA bureaucracy when they should be out and about with their Coastguard teams and the public. However, how are the MCA going to provide this on call 24/7 additional level of supervisory management and operational presence that would provide cover for incidents occurring in and around the Scottish Islands. In the last few months there have been three vessels that have grounded or hit rocks on the island of Rum. Will these officers be expected to be transported around by lifeboat and helicopter so that there is a “supervisor” present to watch over a Coastguard Rescue Team at work? Will teams have to wait for a full time officer to arrive before they begin their rescue?

Risk 9: Insufficient staff available causes mission failure by delayed or incorrect response 3.1.46 Again, here the MCA intends to mitigate this risk with the availability of a 24/7 operational officer in support of the Coastguard Rescue Teams attending an incident. The response from us is the same: is this officer going to be easily transportable to locations such as the Uists, Eriskay, Barra and the Small Isles for example, and will the local Coastguard team be allowed to carry out the rescue or will they have to wait? cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Risk 10: Skills fade causes mission failure caused by delayed or incorrect response

3.1.47 “Incorrect safe systems being following due to unidentiﬁed skills fade”. Where is the evidence to show that this has happened?

3.1.48 Within the proposed new structure, the increased numbers of Sector Managers for training and sector duties is a welcome change. Our current Sector Managers are overloaded and are often working beyond their routine hours and over weekends. The Sector Managers operate a good support system among themselves, with area training at weekends, etc. However, 24/7 operational presence at the scene of an incident cannot be guaranteed, so the Coastguard Rescue Teams must be able to effect a rescue under the supervision of their Station Ofﬁcer, putting all their training and health and safety/risk assessment procedures into practice.

3.1.49 Information gained from Sector Ofﬁcers who attended a Sector Ofﬁcer meeting in Aberdeen is that they will not be expected to attend any more incidents than they attend now, but will be available via telephone for advice, etc. This is not what is implied in this document.

Risk 11: Insufﬁcient qualiﬁed staff available causes mission failure by delayed or incorrect response

3.1.50 What evidence is there that safe systems of work are not being applied? And if there have been occasions, what has been done to make sure it does not happen again?

3.1.51 Enhancement in the number of Sector Managers is welcome to ensure that the teams have support and training as and when needed. However, for the Coastguard Rescue Teams (particularly given that they are well-trained volunteers) operational and risk assessment procedures should be streamlined, made easy to retain and should be straightforward to deliver in training. This would greatly reduce the risk in this respect. It must be remembered that these are volunteers who give us some of their time for very little remuneration. They must not be “used” as cheap labour and should be praised and rewarded appropriately where good team work is evident.

Risk 12: Local knowledge causes mission failure by delayed or ineffective response

3.1.52 What evidence is there that safe systems of work are not being applied? And if there have been occasions, what has been done to make sure it does not happen again?

3.1.53 Any human being can potentially make a mistake, and whilst training and experience mitigate this risk, it can never truly be removed. There is no proposed change to current local knowledge testing and Coastguard patrols in the new structure.

3.1.54 As Coastguard Rescue Ofﬁcers are, for the most part, long-established members of their local community, their local knowledge is of the highest calibre possible.

Risk 13: Partnership working causes mission failure caused by delayed or ineffective response

3.1.55 Attendance at Local Resilience Fora and Regional Resilience Fora is key to ensuring that lessons learned are cascaded in a timely manner in a structured way.

3.1.56 There will only be six Coastal Safety Managers (CSMs) within the proposed structure. Are all six expected to attend all these Resilience Fora throughout the entire UK, then process and promulgate all the issues raised? Are all these meetings “face to face” incurring travel costs, or will video conferencing be used?

3.1.57 At present, our CSM is rarely on station with all the meetings, etc, he attends. How are they going to take on more work and be able to pass this on locally?

Risk 14: Disruption to chain of command causes mission failure by delayed or incorrect response

3.1.58 As per comments above, any enhancement to the current number of Sector Managers would be beneﬁcial. We must remember that our Coastguard Rescue Ofﬁcers are volunteers and whilst they must operate safely and effectively, they should not be taken for granted. We have had scenarios where disharmony within a Coastguard Rescue Team has rapidly caused its demise. It then takes time to recruit and establish a “fresh” team. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Vessel Traffic Monitoring (VTM) Risk Commentary Risk 15: Insufficient staff causes mission failure by inadequate monitoring or a delayed or missed intervention Risk 16: Skills fade causes mission failure caused by inadequate monitoring or a delayed or missed intervention Risk 17: Insufficient qualified personnel causes mission failure caused by inadequate monitoring or a delayed or missed intervention Risk 18: Observance of procedures causes mission failure caused by inadequate monitoring or a delayed or missed intervention 3.1.59 At present, only staff at Dover are involved in Vessel Traffic Monitoring and staff at MRCC Aberdeen are responsible for the administration of the Consolidated European Reporting System (CERS). 3.1.60 The staff in the proposed new structure will be VTM trained. If MRCC Stornoway remains a 24/7 operational Coastguard co-ordination centre, the staff are trained in VTM, and are responsible for actively monitoring shipping movements along the west coast of Scotland; this could greatly reduce the risk of shipping accidents and environmental destruction from pollution. In the present economic climate where we are seeing growth in areas such as tourism, aquaculture and renewable energy projects, combined with increased shipping traffic, this enhancement to MRCC Stornoway’s responsibility would be of great benefit to the Scottish economy for the future.

Counter Pollution Risk Commentary Risk 19: Insufﬁcient staff causes mission failure by delayed or ineffective response 3.1.61 Information gathering, assessment and alerting functions have been carried out by MRCCs receiving reports of actual or potential pollution for many years now. Within the proposed new structure this function will be constantly available from the MOCs. So, if this means that the MOCs are responsible for pollution- related incidents, again we see skills fade and a two-tier system set up here. Sub-centre staff will not be involved in the information gathering, processing and alerting for counter pollution incidents, but they will still be required to do the same training as those at the MOCs.

3.2 Risk overview table 3.2.1 In the 19 systematic risks identiﬁes in the risk analysis document, the MCA say in the existing operating model of the current risk there is four times the risk of a mission being delayed or incorrect response due to insufﬁcient staff available. What evidence is there to show this is the case in the current set up? 3.2.2 The MCA states that the same risks will occur in the proposed new set up regarding a mission failure caused by a delay or ineffective response due to local knowledge. If the MCA are cutting staff by 48%, reducing Stations from 19 to eight, then surely local knowledge will diminish and the risk in the proposed structure will increase above the level it is risk-assessed at this time.

3.3 Local knowledge: managing the risk 3.3.1 The document states the current MRCC structure was established in the late 1970s. The MCA don not seem to take into account “Focus for Change”, which was reviewed (1998), and the Directorate of Maritime services review (Building Sustainable Success 2000). 3.3.2 Local Knowledge is an important part of taking up new posts within the MCA. An officer moving to a different MRCC must sit a local knowledge exam within 3 months of a new post. 3.3.3 Retained knowledge is very important and works alongside factual knowledge and vice versa. Retained knowledge could be our declared assets, which do not tend to change, as opposed to other vessels in the area that could be available from time to time. 3.3.4 Local knowledge is not just about knowing an area, it is also about living and working within a community, we all have friends, family and contacts which we can and do use for different issues throughout our work. 3.3.5 “An emergent challenge in recent years has been the increasing numbers of mariner and coastal users with English as a second language. This is a factor that the Coastguard in common with other emergency services are addressing through training.” What training has been used to address this? 3.3.6 Within the document, there are two posts that are not referred to in the consultation document: call handling officers and routine call operators. Are these going to be new posts, or will highly trained officers be used to just answer calls and then pass information on to other parts of the team dealing with incidents? This is not an efficient use of resources. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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3.4 Location impact assessment and sub-centre rationale Rationale for the number of sites in the proposed new structure 3.4.1 During the meetings held by senior management, it has been stated that this is a modernisation of the Coastguard to improve the resilience of the service, rather than a cost-cutting venture. If this is the case and the technology that the MCA claim exists to run the MOCs and the sub-centres, why don’t the Government put this technology into all the Coastguard stations we have at present and the resilience would increase to well over 100 billion, which would be far greater resilience than one in a million! April 2011

Further written evidence from Save Stornoway Coastguard Campaign Team (MCA 05c) “Oil industry is ‘key reason’ for retaining coastguard centre”, The Press and Journal (Aberdeen), 24 February 2011. http://www.pressandjournal.co.uk/Article.aspx/2151410?UserKey 1. The article is a piece written by the Press and Journal following Aberdeen’s public consultation meeting. In it the Regional Director for Scotland states that “The oil industry is one of the key reasons the Maritime and Coastguard Agency wants to keep a main control centre at Aberdeen” and by doing so this would “ensure that we could “continue to provide the same service we have been building on for many years. We have spent many, many years working together to ensure we can make life that little bit safer offshore.”’ 2. Our Response to this is summed up by the following reply (paragraphs 3 to 5 inclusive) to the article, which we have gained the original authors approval to use (the author is actually one of our staff), please note that we are in no way proposing the closure of MRCC Aberdeen, simply that the statements by Mr McFadyen are at odds with the MCA message that co-ordination could be done from anywhere. If it is true that having a large 24 hour centre in Aberdeen makes the oil industry safer then conversely a lack of the same facility on the west coast of Scotland makes the small vessel owner using these waters actually less safe. We think that is exactly the case and this is, yet more, evidence of the flaws in the proposal as it stood on 16 December 2010. 3. In this article Mr McFadyen argues that the reason Aberdeen should remain as the station for Scotland is because of the Oil industry. Think about it... Coordinating a Search and Rescue mission on an Oil rig miles from any coastal feature does not need a Station on the east coast for reasons of local knowledge. However, a vessel run aground off Rum does require local knowledge an understanding of the community affected and the local resources available to deal with that incident. 4. So what is it about the oil industry that needs coastguards trained in search and rescue planning being in Aberdeen? Perhaps it is just the management team which needs to remain there. Let us think about cost... Aberdeen costs £280,311 a year for rent, rates, utilities and estate management. Compare that to the cost of the other stations in Scotland. Stornoway £55,150, Shetland £53,036, Clyde £112,441, and Forth £44,622. So summing that up we see that the latter four stations cost a total of £265,249 per year. These figures are published on the MCA web site. So for a saving of £15,082 the Aberdeen station could close and we could retain four regional stations. If it comes down to it why not close one station for the security of four others and for the safety of those served by the Coastguard staff. 5. So what is the justification for this choice of station and the decision to get rid of 48% of the highly experienced and trained Coastguard staff? The decision does not appear to be made on considerations of safety. It does not appear to be made on the basis of cost. It must be political or self preservation on the part of Senior MCA managers based in Aberdeen. April 2011

Written evidence from Steve Sim (MCA 11) I am concerned at the way in which the Modernisation of the Coastguard Service is being handled. As you are probably aware, the modernisation is currently subject to consultation in advance of the plans to close several of the MRCC’s and make others day stations linked to two (MOC’s) Maritime Operation Centres. As a serving Coast Rescue Officer (CRO) with 37 years service, I cannot find fault with the rationale behind the proposals, as there is clearly some inefficiencies and poor communications which reduce the overall resilience of the search and rescue (SAR) coordination provided by HM Coastguard, and clearly recognise the advantages and fully accept the need for a properly modernised service. However, there is no evidence in the consultation document supporting the proposals made and which demonstrate (or clearly and unambiguously suggest) that the sought after improvements in resilience will result. In addition, the proposals will place an increasing burden on local coast rescue teams (CRT’s) and others with the local knowledge who provide the “coal face” delivery of the service, but there has been no involvement, discussion, or real consultation with them in advance of publication of this document. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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The CRT of which I am a member supplied evidence to the last review of HM Coastguard in 1997 and this review and associated ﬁve year plan were examined in some detail by the Transport Select Committee under the chair of Mrs Gwyneth Dunwoody. At a meeting I attended yesterday at Liverpool it was amazing to note that that the Chief Executive Sir Alan Massey and Transport Minister Mike Penning MP were unaware of this and have even put in print the last time a review took place was in the 1970’s.

Whilst I accept the consultation process seeks the views of interested parties in advance of implementation, the document offers no supporting evidence, no associated assessment of risk and no assessment of the impact—positive or negative of the proposals which could have health and safety implications for CRO’s. In fact at the meeting it was admitted that some of the statistics were based on 2006 and did not take into consideration some type of call eg Hoax.

Some of the suggestions made seem to rely on technology that either does not currently exist, or which is not proven. All of these factors call the proposals (not the need for modernisation) into question and may have a negative impact on the current obligations to provide SAR coordination and the health and safety of the general public and users of UK waters and the coast.

At the meeting there were few detailed answers to our questions which gave me little conﬁdence and in fact it could be said that some individuals were arrogant to the point of condescending. I do not include the Chief Executive in this remark.

I would be most grateful if the Transport Select Committee could examine the proposals in detail and if possible for you to take up the points I have made with the minister and Chief Executive of the MCA. I know you have been a great supporter of local coastguards and I hope you can help in making sure that the end results do not have a negative impact on the British public and to the coastguard search and rescue system of the United Kingdom. January 2011

Written evidence from a Coastguard Ofﬁcer (MCA 12a)

Sir Alan Massey was asked by the Transport Select Committee in February and myself in an email last December who were the author’s of the present Consultation Document.

Sir Alan Massey stated to the Transport Select Committee and in an email to me personally and I quote “I am the Author of the document”.

I now have written evidence via the Freedom of Information Act a quote from the MCA that states, One Watch Manager and seven other Officers from Coastal Safety Managers along to Head Officer Uniformed Coastguard Officers assisted in constructing the current proposal.

Why was only One Watch Manager from the coast was asked to assist with the document?

Out of the remaining seven “Uniformed Ofﬁcers” how long is it since they were actually an active member of a watch in a Operations Room?

Sir Alan Massey was also states to me in the same email “There have been several ideas around reconﬁguring the CG over recent years. The current one has been worked up in detail since my arrival and has been agreed by Ministers to be put forward for consultation”

Point 1—Sir Alan Massey joined the MCA on 20 July 2010. The consultation document is dated 16 December 2010. This is a very short period for Sir Alan to as he has stated “I am the author of the document” and to personally verify the contents of the document, especially considering he is placing his name on the document as “the Author”.

Point 2—The Under Secretary of State for Transport Mr Penning stated in a debate in the West Minster hall “the current proposal was on his desk when he arrived and was left by the previous government”. Mr Penning took up the role of Under Secretary of State for Transport on 15 May 2010!

Which person is correct about the date the current Consultation Document was presented to the Under Secretary of State for Transport. April 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Written evidence from Denis McCallig (MCA 15) Today I attended a meeting with other CRO’s from along the coast, most with many years experience in the service, at Liverpool Maritime Rescue Sub Centre, present were the Chief Executive Admiral Massey and Mike Penning MP. I was truly shocked at the lack of clarity, lack of information and answers to our questions on the consultation for change, yet for me to answer the consultation document I am asked to provide evidence to back up my answers. They were of the understanding that the last review of the CG took place in the 70s whereas in 1997 the agency had a review and a ﬁve year plan which was investigated by the TSC and a number of my colleagues were asked to give evidence to Mrs Dunwoody and the committee. Today no evidence of risk assessment or impact assessment on the organisation could be produced which should naturally be part of any consultation document. As volunteers we are not against change and this review should be seen as an opportunity to move forward. Unfortunately some of the information in the consultation document is not backed with hard evidence and some evidence which is plainly suspect!!! May I take this opportunity to ask you to consider having the TSC investigate this matter of safety on behalf of the public. My colleagues, myself, and our families thank you in advance for your consideration on this matter. January 2011

Written evidence from Paul Kirby, PCS Branch Secretary for Liverpool Coastguards (MCA 16) Coastguard Modernisation Plan: National Our main concern over the MCA plan to modernise the coastguard is one of safety. The present system has each of the nations Maritime Rescue Co-ordination Centres covering a speciﬁc district. This has been deemed necessary due to the unique nature of the UK coast. More recently there has been an ongoing pairing exercise whereby one MRCC has been twinned with its neighbour. This has meant that two districts have worked closer together with one MRCC being able to “take over” some or all of the desks at the other MRCC should there be a problem. (This providing power remains at both locations). Twinned MRCCs are, as stated, neighbours so staff at these centres have now begun to build up a degree of local knowledge of each other’s districts. Unfortunately, due to continuous understafﬁng and underfunding a full and proper twinning has not been possible. The new proposal calls for a change to a system of two 24 hour Marine operations centres, One in the north of the UK and one in the South, with a further six “day stations” at various locations around the country. 1. Whatever “technology” is available it cannot be considered safe to reduce the country’s coastguard stations to half the previous level. As stated the UK has a unique coastline consisting of some the busiest waterways in the world, the most densely populated holiday areas in Europe and every different type of coastal terrain imaginable. Not to mention the inland waterway coverage. 2. At present if a call (by radio or ordinary telephone call or 999 telephone call) indicating some form of distress is received then the MRCC operative taking that call would question the 1st informant to ascertain the nature of the problem and the location, then, together with the watch team, lead by the watch manager, prosecute a rescue plan using the available rescue facilities in that location. The new system requires a MOC operative to take the call and pass the details up the line to a more senior team for prosecution. Details then have to be passed to the Sector manager concerned. He then has to pass the details and to the Coast Rescue Team (after paging them and waiting for them to respond) and then co-ordinate the rescue. This creates several “dog legs” into the system and cannot be considered safe. One of the main concerns when handling an emergency situation is the possibility of losing contact with the person reporting the situation and thus losing vital information as to the location and/or nature of the distress. Every “dog leg” introduced into the system increases that possibility. The time taken to respond to an emergency will also be increased to an unacceptable level. 3. The areas covered by the new Marine Operation Centres are vast. Each one will cover half the country. The idea that 24 staff would provide coastguard cover at night, particularly during the summer months is, again, unsafe. In terms of coverage the new system is badly thought out and needs an input from experienced staff members that have worked at MRCCs for a number of years and are thoroughly experienced in the co- ordination of coast rescue. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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4. The proposal seems only to focus on the co-ordination of a single rescue. This again is unsafe. An MOC covering half the country even with the ability to call on two sector managers is going to be hard pressed in the summer to deal with multiple incidents which may occur in one particular area. No mention is made of handling several diverse rescues at the same time.

5. The handling of calls from the general coast using public and professional seafarers requiring information on weather, tides, terrain, marine radio usage, and marina facilities is not mentioned. Many calls requesting information and advice concerning the next day are received from coastal users overnight. This increases the work load considerably and must be dealt with at the same time as handling several diverse incidents.

6. It is noted also that there is no mention of handling calls from the press. At present all calls from newspapers, radio and television are handled by MRCC staff. Several speculative calls from each source are received daily, usually starting before 4:00am and finishing after midnight. Significantly adding to the amount of telephone traffic handled overnight. Whatever arrangements there are in place, members of the press will always obtain a number by which to contact a coastguard station/MOC direct.

7. Local knowledge held by MRCC staff at present is all important. This knowledge is not to be confused with the knowledge retained by the coast rescue teams. These team members have intimate knowledge of the local terrain in their, relatively small, area. The level of local knowledge required of an MRCC operative is different. The imparting of this knowledge to callers may have nothing, initially, to do with a specific incident. Merely a request for information. However, if incorrect information, or indeed, no information is passed to a caller and that caller acts on said information then a dangerous situation can develop. The new system takes no account of this. Again, unsafe. The proposal assumes that personnel from stations that are to close will move to one of the MOCs or day stations. However, with the reduced staff at the day stations and the reduction overall in the workforce, positions at these locations will be limited. If these proposals are implemented all existing staff would have to re apply for the new positions. This will inevitably mean staff having to change locations. In this day and age most families rely on two incomes. This means that when comes the time to move two jobs must be found…not one. Moving grants and loans may facilitate one income earner moving to a new location but not two. As coastguard officers are grossly underpaid, jobs with a similar salary (also less responsibility and fewer hours) are available to them. The initial reaction to the proposals from officers is to refuse, point blank, to move and seek employment else ware. Job hunting by many officers is, in fact, already underway. As time goes on and the agency finally releases information as to the status and salary attached to the new positions then a few of the younger less experienced officers may agree to move, but again, a vast amount of experience and knowledge of a particular area will be lost.

8. If the proposals were adopted then existing staff would have to be completely retrained in a very short space of time. No mention is made of how this would be achieved, by whom or even where. There is a Coastguard Training Facility in Dorset but this is understaffed and not equipped to undertake such a task. The document indicates some outsourcing of training but there is no mention of to where. The inclusion of private companies introduces the inclusion of proﬁt which inevitably puts the seagoing and coast using public at risk.

The whole process for developing a plan to modernise the coastguard service is flawed. No one disagrees with the fact that, along with all organisations, the service needs to modernise. However, modernisation must be carefully thought out and planned. In this case even the planning and organisation of the modernisation planning process has been ridiculously mishandled and is badly flawed: — Impact assessments from the last round of closures have not been done. — Recommendations from the Transport Committee have not been implemented or even considered. — Risk assessments for these proposals are not evident. — There is no input from experienced MRCC operations room staff, Sector managers or serving representatives from the Coast Rescue Service. — No live exercises have been carried out to test the proposed system or indeed to develop it. — A saving of less than £5 million per year for the next 25 years is not sufficient to warrant the increased risk to the general seagoing public. This small saving is likely to be swallowed up in the current economic climate within the first two years.

It would be prudent to abandon the whole project until a thorough investigation into the procedures used in devising this plan has taken place and properly managed procedures for the process of planning the modernisation of HM Coastguard are put in place. January 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Further written evidence from Paul Kirby, PCS Branch Secretary for Liverpool Coastguards (MCA 16a) I am concerned about the independency of the whole process of this exercise and we feel that the MCA are only conducting this exercise to “tick boxes” for Transport Select Committee’s reviews of the MCA. Surely by having the Chief Coastguard and two of his deputies as the Directing staff this is not very independent. I have heard that some stations are refusing to send operational staff to assist in this process, also that staff will not compromise the stafﬁng of their stations as we are now in the easter holiday and a very busy time of the year for frontline staff.

Annex Letter from MCA to Coastguards dated 7 April 2011 FUTURE COASTGUARD EXERCISE 15 APRIL 2011—HIGHCLIFFE An exercise to demonstrate the Future Coastguard concept of operations has been devised to allow operational staff to participate in, and test for themselves, the proposed concept of operations. The exercise is in two parts; a tabletop exercise aimed at testing workload distribution and resource allocation, and a live exercise to demonstrate the means by which operational teams can act in support of each other. To that end I would be grateful if you could nominate an experienced ofﬁcer from each area who could (a) bring experience and expertise to the exercise and (b) act as a rapporteur for the Area. The exercise will take place in the Billy Deacon building and I aim to start at 0900. The exercise will be moderated by Director Chris Reynolds of the Irish Coast Guard. I apologise for the short notice, but I did not wish to issue this calling notice without notifying the Trade Unions at today’s National Joint Working Group. The PCS have been invited to send observers.

Annex FCG DEMONSTRATION EXERCISE, DATE: 15 APRIL 2011 Purpose 1. The exercise will demonstrate the manner in which the demand generated by Search and Rescue activity can be managed by the proposed Future Coastguard structure. The demonstration will exercise two key elements. A Table Top exercise will map demand and resource across the FCG network to determine the loading and residual capacity of the network geographically and functionally. 1.1 A practical exercise will demonstrate the manner in which two operational teams can work together when physically separated, including the passing of information, cooperation and reinforcement. The practical demonstration will, so far as is possible, reconstruct the live environment expected of two operational teams working in a busy area at a busy period.

Participants 2. (1) Exercise Director: Rod Johnson. (2) Exercise Directing Staff: Roly McKie, Geoff Matthews. (3) Exercise players: TBA. (4) Exercise umpire: Chris Reynolds (Irish Coast Guard). (5) Observers: Union representatives as determined by the PCS. (6) Note taker: Sophie Turner/Rebecca Banting.

Exercise Location 3. The exercise will take place in the Billy Deacon Building, MCA TC, Highcliffe on a date and time to be decided.

Aim 4. To demonstrate key elements of the Future Coastguard operational concept.

Critical Success Factors 5. That: (1) Information received is dealt with within Service Standard requirements; cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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(2) Communications resources are available to enable coordinators working in Operational Teams to accomplish tasks; (3) Work can be successfully redirected to balance overall work load across the system; (4) Incidents and tasks can be transferred/handed over between centres; (5) Sub centre Operational Teams (OT) can be stood up and stood down at beginning and end of the day; (6) ongoing incidents can be handed over to MOC OTs when sub centres stand down.

Conduct 6. The exercise will be a table Top Exercise will be using a large map of the UK SRR and geographical Operational Areas and current Radio Sites annotated. The exercise will run in “exercise time” and can stop and start as required by the need for discussions/explanations.

Single concept of Operation 7. To make the exercise comprehensible, a single concept of operations will be demonstrated and discussed (see annex for further details).

Written evidence from Serving Coastguards at MRCC Falmouth (MCA 17) We note that the Transport Select Committee is taking evidence from the Maritime and Coastguard Agency next Tuesday, 8 February. As serving Coastguard Officers we have very real concerns about decisions that have been announced by the MCA over recent months, and in particular with regard to Proposals for the Modernising the Coastguard Service, the Consultation Exercise for which was launched on 16 December. We believe that the decisions already announced will seriously impact upon the safety of ships, mariners, users of our coastline and indeed the coastal environment:- the cessation of the contract for four Coastguard Tugs stationed around our coast (£12 million) which came into being on the recommendation of Lord Donaldson following two major oil spills; the disbanding of the Maritime Incident Response Group (MIRG) through which Fire Brigade staff are trained to fight fires aboard vessels (£0.5 million); and the withdrawal of Direction Finding Radio Equipment from VHF aerial sites (equipment upgrade £8 million). The Proposals for Modernising the Coastguard Service will decimate the current operation. There are currently 491 Coastguard Officers maintaining 24/7 cover in 18 Maritime Rescue Co-ordination Centres (MRCCs) Operations Rooms around the UK Coastline. Under the Modernisation Proposals this number will drop to just 248 Coastguard Officers working in just 8 MRCCs, only three of which will be open 24/7— Southampton, Aberdeen and Dover. A further five stations will operate “day time only”, although the operational hours are not specified. In addition the small CG operation on the Thames, with a single officer on duty, will continue to operate 24/7 as now. We are very concerned with the loss of Local Knowledge, which is vital to pinpoint the location of an incident and task the appropriate resources to undertake a rescue. A study of incidents throughout the UK over the past two years indicates that nearly 60% of incidents occurred on or very close to the coast. Coastguard Officers around the coast are concerned that under the proposal over half the current stations will close, and that only three stations will be open at night, will mean that Coastguard Officers handling emergency calls will not have the local knowledge vital to pinpoint the location of an incident, and to task the appropriate resources to undertake a rescue. Under the proposal local knowledge and advice will be sought by calling members of the volunteer Coastguard Rescue Service, or RNLI volunteers, even in the middle of the night. The MCA’s Chief Executive has stated that he accepts that the process of identifying a particular location and resources will take longer than now, possibly up to ten minutes, and that this as an “acceptable risk”. However Coastguard Officers have always been trained that the time spent at the outset of an incident is critical—“Minutes Matter”—and we are all examined on a regular basis in Local Knowledge. The current Ministerial Target is that appropriate rescue units should be tasked within five minutes in 98% of incidents. It must be questioned whether the proposed structure for the Coastguard service will be able to maintain this Ministerial Target. Further, we are also very worried that there may be a plan for the Coastguard to cease the 24/7 dedicated listening watch on the VHF Ch16 Distress Channel. This is not specifically stated in the Modernisation Proposals, but the reductions in Coastguard Officers on duty at any one time, and other references within the document, indicates that this may well be the plan. Comments made by those in senior posts would seem to confirm this. If this is the case, there would be a total reliance on all vessels using Digital Selective Calling to contact the Coastguard. The DSC system, whilst useful for Distress alerting, has major shortcomings when it comes to processing routine calls, and we are concerned that the leisure mariner may stop calling with routine safety traffic such as logging passage plans. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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The Consultation Document fails to acknowledge the Specialised Roles undertaken by MRCC Falmouth and other Coastguard Stations. MRCC Falmouth is the single point of contact within the UK for the majority of foreign search and rescue organisations worldwide, and it is MRCC Falmouth to whom British vessels in difﬁculty anywhere in the world will call. MRCC Falmouth is also the UK Co-ordinator for the Global Maritime Distress and Safety System. Over the past 30 years MRCC Falmouth has developed procedures to improve the response to maritime distress situations throughout the world, and has a worldwide reputation in this ﬁeld. This experience will be lost in the proposed re-organisation.

A brief summary of the work undertaken by MRCC Falmouth is attached.

You will appreciate that morale in the Coastguard Service is at an all time low. This is reflected in the fact that key indicators within the MCA staff response to the 2010 Civil Service Staff Survey (eg Leadership and Managing Change, Pay and Benefits, Taking Action) show staff satisfaction levels within the MCA are way below that of the Civil Service as a whole. Coastguard Officers are the lowest grades within the Civil Service despite the importance and complexity of the work we do (Coastguard Watch Assistants AA grade, Coastguard Watch Officers AO grade and Watch Managers EO grade).

Coastguard Ofﬁcers at Falmouth recognise that there is a need for change and, as a station, we are working up an alternative proposal which we will submit by the closing date for the Consultation in March. We are told that the Proposal has taken four years to develop, but the document is so light on detail we have been obliged to request information from the MCA under Freedom of Information Legislation to enable us to submit an informed alternative proposal.

We are concerned that this is a Consultation in name only and decisions have already been made. During his visit to MRCC Falmouth on 7 January, the Chief Executive stated more than once “I am the author of this report, it is my vision for the Coastguard, and the direction I expect it to take over the coming years”. Just today, to the BBC in Scotland, Sir Alan described the plan for the Coastguard as “the best there is”.

Seemingly lessons are not being learned from the much delayed and hugely overspent project to regionalise ﬁre control, which has just recently been abandoned by the Coalition Government. Fires will always be reported by telephone, and most ﬁres will start in buildings with recognisable addresses and postcodes. Compare this with the myriad of ways that Coastguards receive distress and other messages far from the coast, within inshore waters or from our complex coastline and beaches—VHF and MF radio, Satellite telephone, landline and mobile, Satellite texting, email, EPIRB alerts etc. A project to centralise all this on a national basis is clearly a far more complicated exercise, and there is a very real risk of IT overspend.

Comparisons have been drawn with the National Air Trafﬁc Service (NATS), centralised at Swanwick. It has to be remembered that both the commercial airline industry and the leisure air sector are both highly regulated. The leisure mariner, or indeed the users of our coastal waters and coastline, have no such regulation.

NATS were successful in attracting sufficient staff to relocate to Swanwick, but the pay level in air traffic control is many times higher than in the Coastguard. The Chief Executive of the MCA has already admitted that there is a further “inherent risk” with the new structure, in that Coastguard Officers may not be prepared to relocate. Again the Proposal Document is light on information, with regard to any new pay structure or relocation packages, which makes it difficult for us to respond in an informed manner.

To summarise, our concerns are as follows: — the proposal document is light on detail, and in places is seriously misleading. The foreword states that the Coastguard Service has not been reviewed or modernised for 40 years. Yet the Coastguard Service was the subject of a major review in 1995, and a visitor to any Operations Room will have no doubt that we are working with modern technology. — the reduction of 18 x 24/7 Coastguard Stations with intimate local knowledge of their Search and Rescue Area to just three x 24/7 Stations, supplemented by five daytime Stations whose role is so far unspecified. — the likely cessation of the 24/7 listening watch of the VHF Ch16 Distress Channel. The majority of our inshore fishing fleet and leisure users do not currently have the VHF DSC facility, which will then be the only way to contact the Coastguard via VHF radio. — the loss of VHF Direction Finding equipment which has proved invaluable on many occasions to swiftly identify the location of a casualty vessel. — the loss of the strategically placed Salvage Tugs placed around the UK, with the threat of a major pollution incident occurring on the UK coast and the impact this would have on tourism, the economy and environment. — the abandonment of the MIRG facility.

All the above seems to be at odds with the MCA’s stated vision “to be a world-class organisation that is committed to preventing loss of life, continuously improving maritime safety, and protecting the marine environment: Safer Lives, Safer Ships, Cleaner Seas”. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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We apologise for the late submission of this letter, but trust that yourself and members of the Transport Select Committee will share our concerns and will take the opportunity to question the Chief Executive and other Directors when they appear before you next week. Please feel free to contact me should you require any further information. We hope that yourself and members of the Transport Select Committee might have an opportunity to visit MRCC Falmouth to gain a better understanding of the work we do.

MRCC Falmouth Duties Maritime Rescue Co-ordination Centre (MRCC) Falmouth has responsibility for Maritime Search and Rescue (SAR) around the Cornish Peninsula (approx 450 miles of coastline), from Dodman Point near St Austell round to the Devon Border at Marsland Mouth on the North Coast, including the Isles of Scilly. MRCC Falmouth is responsible for maritime SAR over 660,000 sq miles of the North-Eastern Atlantic, and is the single point of contact within the UK for most foreign SAR authorities. MRCC Falmouth acts as the UK Co-ordinator for the Global Maritime Distress and Safety System. This includes receiving Emergency Position Indicating Radio Beacon (EPIRB) alerts, identifying the vessel and then co-ordinating search and rescue or passing to the relevant authority. We also broadcast distress and urgency messages via Satellite to vessels anywhere in the World. MRCC Falmouth’s worldwide reputation has lead to British vessels calling Falmouth for assistance from any point on the globe. In addition to SAR missions, MRCC Falmouth undertakes a host of routine tasks, including: — maintain a dedicated listening service 24/7 on VHF Ch16 and MF 2182 kHz Distress and Calling Frequencies and VHF and MF Digital Selective Calling. — broadcasting Weather and other Maritime Safety Information eight times a day to mariners, and operating the UK NAVTEX service to all mariners using British waters. — receiving on average 950 reports per month from ships transiting the Lands End Traffic Separation Scheme. — fulfilling the UK’s role in the EU reporting scheme regarding the movements of laden tankers (a further 700 reports per month). — assisting 2500 ships per year in performing Ship Security Tests, and acting as UK receiving station for Ship Security Alerts (eg: Piracy Attacks) from UK flagged vessels. — accepting passage plans from scores of leisure yachtsmen each week, providing safety advice, and answering hundreds of general enquiries from the public.

MRCC Falmouth Incident Data In 2009 MRCC Falmouth recorded 3,754 Incidents, which included 2,304 Search and Rescue Missions. MRCC Falmouth was the busiest station in the UK for Search and Rescue. In 2010 MRCC Falmouth recorded 3,602 Incidents, which included 2,286 Search and Rescue Missions. Again MRCC Falmouth was the busiest station in the UK for Search and Rescue. Under the proposal for the Modernisation of the CG Service, MRCC Falmouth would be closed at nighttime (the times are unspeciﬁed), however 30% of recorded incidents commenced during night-time hours of 2000 to 0800. In 2010 MRCC Falmouth tasked CG Coast Rescue Teams on 612 occasions, RNLI Lifeboats were requested to launch on 427 occasions, and Rescue Helicopters ﬂew 282 SAR missions. February 2011

Written evidence from Jean Hendry (MCA 18) I hope very much that I am still able to bring some matters to your attention, as Chair of the Transport Select Committee, before the Committee meeting on 8 February 2011 to examine matters regarding the Maritime and Coastguard Agency (MCA). Unfortunately, I have only newly learned of this meeting, but not wishing to give oral evidence, unless you require it, I trust the timing is less critical. I am concerned about the proposed loss of the MCA’s four Emergency Towing Vessels (ETVs). They were introduced in response to Lord Donaldson’s Report, which was entitled “Safer ships, Cleaner seas”. The ETVs have helped to achieve and maintain that goal. Having worked on this issue since the news of these proposed cuts ﬁrst broke in October 2010, I have achieved coverage of the subject in all the East Kent newspapers. I have kept my own MP, Damian Collins, fully informed on the situation. He met with the Shipping Minister on 19 January, and he is currently waiting for a written response on the points I asked him to put to the Minister. All four ETVs are important, but I will conﬁne these comments to the ETV in The Straits of Dover, my local area. At present, this is the Anglian Monarch. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Is it true that the MCA commissioned an independent consultant’s Risk Assessment on the importance of ETVs, and that this report was delivered in late 2008? Has your Committee been provided with that report and any other independent risk assessments? Wouldn’t the release of all such studies be essential to an informed process of public consultation on the current proposals? Is it correct that in 2008, the conclusion was that an emergency towing facility was most clearly needed in the Dover Straits, and that there were no suitable alternative towing vessels near enough at hand? In 2008, weren’t the small Dover Harbour tugs adjudged inadequate and unsuitable for the ETV’s task? No one has been able to convince me that there is any significant change in the need for an ETV, and the continuing absence of alternatives, in the Straits of Dover. The Straits present rather different problems to the other areas, and consequently this ETV should be considered entirely on its own merits and not as though it were part of some indivisible package. One clear distinction is that this ETV is only 50% financed by UK Government funding. France currently pays half the cost of this ETV, and its planned axing is causing considerable concern to the French authorities. The cost to the UK of the Straits ETV is considered to be around £1 million/year, while a single super tanker disaster would cost hundreds of times more. I am concerned that the Shipping Minister is concentrating only on the cost of the ETV, while seemingly ignoring or confusing the income side of the account. Indeed the MCA Press Office have been active in “spinning” that it is “wrong for the taxpayer to provide free towing”. The ETV does not provide “free towing” for ship-owners—either a Salvage Claim is made, or a full commercial towing rate is charged. But that income does not go to the taxpayer. The truth seems to be that whenever there is any towing income to be made (or Salvage to be claimed), the ETV goes “off contract” (as the MCA say)—and that allows the tug-owner to take all the income. This arrangement seems as generous as only a Government Department could negotiate. I feel sure that a Minister, truly minded both to protect the public and the public purse, should be able to negotiate a contract whereby the Government underwrote the provision of the service, ensuring its existence, yet clawed back some proportion of the income generated, to defray and perhaps eliminate the cost of guaranteeing that there was an ETV available on those occasions when it was needed to prevent a disaster on the scale of the Amoco Cadiz. Another concern of mine is that the Minister seems to be under the misapprehension that a commercial salvage tug in the area, (if such a thing existed), would be an adequate substitute for an official ETV. The reason that it is not a substitute is that the ETV has official Powers of Intervention, from SOSREP. The Donaldson Inquiry concluded that such powers were essential to cut through the delays occasioned by the haggling over whether or not a Lloyds Open Form was to be signed. A speculatively-positioned commercial tug simply could not act with official authority. Yesterday, my MP informed me by email of his impressions following his meeting with the Minister (he awaits written confirmation). It seems that the Department’s latest idea is for Government to compel a ship to accept a tow from an ordinary commercial tug—and at a higher than normal rate. I quote Mr Collins: “This is the key part of the issue I think, and something that the Department is still working on, it would seem that if there was a case of a vessel that needed to be towed to safety and its owners refused to pay to arrange for it to be towed by one of the private operators, that it might be arranged that the Secretary of State would be able to order it to be towed, and would hire a towing vessel to do this, and then look to recover the costs from the owners. These costs would be much higher than if the owners made the arrangements themselves”. Quite how such a scheme could possibly operate requires investigation. I am struck by the seeming lack of awareness of the shortage of time available during an emergency in a narrow waterway. Without any official representation whatsoever on-scene offshore, how is the determination to be made by officialdom that these powers should be applied? By looking at a radar screen on shore? Isn’t this handing out powers of extortion to would-be commercial salvors? Indeed, it seems that the stance of the MCA, as given to the Press, is so simplistic as to confuse a ship in distress—drifting out of control in a narrow and crowded shipping lane, close to the Goodwin Sands and many other hazards, threatening to spread a quarter of a million tonnes of crude oil over thousands of square miles— with the situation of a truck, temporarily inconvenienced by breaking down beside the Motorway. The potential consequences to lives, the economy and the environment make any such comparison utterly absurd. The image of a Motorway breakdown crew demanding a signed Lloyds Open Form makes the analogy almost comic. The MCA statements were reported in Kent News/Kent on Sunday http://www.kentnews.co.uk/p_12/Article/a_ 10531/Dover_Straits_tug_Anglian_Monarch_is_not_a_good_use_of_public_money The local ETV also fulfils a number of other official roles. One of great personal interest to me is pollution monitoring. I can personally vouch for the fact that since there has been an ETV on-station, the incidence of oiled seabird strandings because of pollution from activities such as illegal tank-washing at sea has greatly reduced. Quite apart from the benefit to the environment, the cleaner seas and beaches can only have helped the local fishing and tourism industries. I understand that the ETV is also regarded as an “asset” by the Borders Agency (for anti-smuggling, anti-illegal-immigration and potentially anti-terrorist duties.) I have also been told cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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that it has been used in connection with military training exercises and the civil emergency services. Given their concerns about the cost of the ETV against their budget, it surprises me that the DfT does not seem interested in charging any of the ETV’s services across to other Departments. The ETV’s roles beyond mere towing were recognised in an Article in Maritime Journal in November 2010 http://www.maritimejournal.com/features/tugs,-towing,-pollution-and-salvage/tugs,-towing-and-salvage/there- is-more-to-etvs-than-just-salvage On last Christmas Eve (2010), the Eren Turgut suffered a fire when 18 miles off Dover. She lost all propulsion, power and lighting in bad weather and darkness, right at the crossroads of the Channel Traffic Separation Scheme. Three injured crewmen were helicoptered to hospital, but sadly one died later. Two lifeboats briefly attended. The ETV Anglian Monarch stood by for many hours through the night, both as a Guard Ship, and ready to tow the stricken vessel if it were to drag its anchor. Thanks in large part to its presence, there was no repeat of the Channel pile-ups that have occurred in the past, as with for example the Tricolor and the earlier Texaco Caribbean. One very strange aspect of the Eren Turgut incident was that while both the Dover and Ramsgate RNLI press releases paid attention to the ETV’s role, the MCA’s own press release (372–10 from the Southampton office PR) managed to avoid any mention of their own “asset” being on the scene. One might almost have thought that they were trying to portray the ETV as insignificant. I do fully realise the competition within the MCA to avoid the Minister’s axe, but I regard the provision of an official ETV as being much too serious a matter for playing politics with—especially “office politics”. It has become rather hard to obtain data on the calls upon the ETV’s services. Nevertheless, on the MCA website, I did find the official MCA figures for the first year of the Dover Straits’ ETV (then the Far Turbot). It was “tasked” more than 60 times to ships with engine problems, plus a few with steering problems, dealing with a couple of collisions, picking up illegal immigrants in a small boat, and removing various hazards to navigation. The purpose of its “tasking” was to prevent the risk of the situation becoming disastrous—would a purely commercial vessel be similarly tasked, or would we just have to cross our fingers and hope? I hope very much that you will be able to confirm that I am still in time with this submission and that these matters will be of interest and concern to the Select Committee. If you should want more detail, fuller explanations, or corroborative materials, I would be happy to provide them February 2011

Further written evidence from Jean Hendry (MCA 18a) I am concerned about the Government proposal not to renew any contract for MCA provision of Emergency Towing Vessels. My particular concern is with an ETV for my local area, the Straits of Dover. In this regard, I have already submitted a paper to the Transport Select Committee, by mail and email, to the Chair, Mrs Ellman MP. That submission has been acknowledged by a letter from the Committee dated (and received) 2 February. I am writing again because I have newly received what I believe to be an extract, specifically the Synopsis and Executive Summary, from a 149 page report commissioned by the MCA, and presented in or about November 2008—which I would like to draw to the attention of the Committee. The extract is attached. This report, seemingly not in the public domain, appears to be essential to any meaningful discussion of proposals for ETV provision—or non-provision. I note, for example, the conclusion that, far from doing away with the Dover ETV, it should actually be upgraded to an even more powerful vessel. Also that there is a “market failure” to offer alternative commercial towing capacity, particularly in the Dover area—which is plainly at variance with the Minister's current position, as reported to me by my MP (please see my earlier submission to the Committee). Of particular relevance to any economic questions is the cost/benefit analysis, that the prevention of just one single PRESTIGE-sized incident over a 10 year contract for four ETVs, would make the ETV fleet something of a bargain. If the MCA have not yet volunteered this report to the Select Committee, I feel that the Committee should be calling for it. February 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Further written evidence from Jean Hendry (MCA 18b) To the Chair Mrs Louise Ellman MP and Members of the Transport Select Committee following their Meeting with the MCA on 8 February 2011. I feel that, while the Committee quickly took the measure of their witnesses, they did rather let Sir Alan Massey “off the hook” on the subject of the ETVs. I trust that the Committee will now decide that more detailed investigation of the ETV situation is required. In response to Tom Harris MP, Sir Alan said that “the nature of business, the nature of all of our policymaking, within this Department and certainly within my Agency, is such that we are always analysing impact and risk”. And yet he later claimed he “had not seen” the 2008 risk assessment commissioned by his Agency on an ETV provision. Mrs Ellman understandably found that “surprising”. It would be a great pity if Sir Alan’s unbelievable answer were to be all that was needed to prevent further examination of the increased risks being run by cutting the ETV fleet. Even the MCA’s Head of Communications has admitted, in a Kent newspaper, that risks will be increased by withdrawing ETVs —“The Maritime and Coastguard Agency's head of communications Maggie Hall believes the financial benefit outweighs the risks. She said: “Ministers have judged that the associated risks are acceptable in the light of the need to reduce the fiscal deficit.” http://www.thisiskent.co.uk/news/Safety-fears-plans-axe-tugboats/article- 3068212-detail/article.html I note that in his replies to Mr Harris’s final set of questions, Sir Alan admitted that the MCA had carried out “a formal risk assessment” for the ETVs (but not for other Coastguard changes). Presumably, this revealed the increased risk that the MCA’s Head of Communications was referring to. It will be interesting to study that “formal risk assessment” in detail, once it is available, and I feel sure that it will open many lines of enquiry for the Committee. The Committee might care to ask how Sir Alan could possibly formulate his plans without detailed awareness of that consultant’s 2008 report. Particularly when that Marico report concludes that there is justification, not just for retaining an ETV at Dover, but actually for having a bigger, more powerful ETV stationed there. Perhaps Sir Alan did not consider this “Assessment of Requirements” to be a “risk assessment”? How much were Marico paid for the report that Sir Alan is trying to bury? It needs the Committee to enquire how Sir Alan has arrived at the opposite conclusion to his Agency’s consultants. Clearly policy has changed, but what facts now lead to the different policy? Which came first, the justification or the policy? Sir Alan remarked on there being relatively few “taskings” of the ETVs recently. Has his Agency fully reported those taskings? In its first year, the Dover ETV (then the ‘Far Turbot’) was tasked over 70 times— principally to attend ships with engine or steering failure. Those tasking reports are available as PDFs from www.mcga.gov.uk/c4mca/mcga-15_annex_i_fart_a.pdf and www.mcga.gov.uk/c4mca/mcga-16_annex_i_fart_ b.pd It is hard to have a meaningful consultation on this when the MCA does not now release similar tasking logs for their ETVs. Did the MCA record the Dover ETV as being “tasked” last Christmas Eve (2010)? In fact, it attended the “Eren Turgut” after an explosion on board which killed one crewman and seriously injured two others. The stricken ship was without propulsion or lights in a busy shipping lane, on a stormy night. The ETV illuminated the scene and acted as a Guardship for many hours, preventing a marine pile-up. The incident began around 1630, and the Anglian Monarch was on-scene before 1800—but when, if ever, does the MCA record it as being officially “tasked”? The MCA Press Release about this incident does rather curiously fail to mention the Anglian Monarch’s involvement—in stark contrast to the RNLI Press Releases. Considering one of his lines of questioning, Mr Leech might want to enquire why the Eren Turgut has been under arrest in Rotterdam, ever since being towed there after this incident. While Sir Alan says that the ETVs are not busy, the Minister says that the Dover ETV is so busy that it would be an attractive commercial proposition to station a commercial salvage tug in the area. They cannot be allowed to have it both ways. Is it busy, or not? But the ETV’s, like Fire Engines, are needed—even if they aren’t busy—as the Minister should understand. The rationale for an ETV is to prevent major incidents. Preventing one per hundred years per ETV would be cost-effective—in financial terms, quite apart from loss of life and damage to the environment, marine industries and tourism. But does Sir Alan really see the ETV as a commercial tow-truck, rather than as an “emergency responder”? Does Sir Alan really believe that when a lorry on the M25 is on fire, “a commercial arrangement” must be struck before a Fire Engine responds? I fear that Sir Alan got away with an inadequate answer over the current ludicrous contract arrangements for the ETVs. Does the MCA really receive a sum calculated as a percentage of the ETV’s “off-contract” cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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income? (As the Committee were led to believe.) Or does it receive a rebate against its contractual payment, simply based on the time that the ETV was not “on-contract” to the MCA? If the MCA were underwriting the ETV service in ‘lean’ years, by actually taking a reasonable percentage of the income in “fat” years, the service could be put on a sustainable ﬁnancial basis. If the contract were as the MCA have suggested, then there need be no alteration in the principles involved (the MCA taking a percentage of the towing or Salvage fees), any negotiation would only have to be about inserting appropriate numbers. Sadly, as John Leech MP pointed out, a willingness to negotiate a sensible contract does seem to be lacking. I was struck by Sir Alan’s references to Coastguard “incidents” purely by number, rather than by severity. Incidents requiring an ETV are potentially those on a very large scale. And accidents involving commercial shipping don’t happen principally in daylight hours and in Summer. Why is Sir Alan so concerned to structure his service provision around the number of incidents, rather than their scale? There is a need for some investigation of the international obligations of the Department and the MCA regarding ETVs. I believe that, to answer the questions Mrs Ellman posed, evidence can be produced for the Committee that our French partners are upset, at the very least, about the Government proposals. They have a ﬂeet of more powerful ETVs than those the MCA has employed. The Kent press has previously reported “French authorities who pay half the Anglian Monarch’s costs are also against the move, with the Pas de Calais Council President Monsieur Dominique Dupilet saying the savings would mean nothing if there were a maritime catastrophe”. http://www.kentnews.co.uk/p_12/Article/a_10531/Dover_Straits_tug_Anglian_Monarch_is_not_a_good_use_ of_public_money I hope that my comments may help the Committee. February 2011

Further written evidence from Jean Hendry (MCA 18c) Regarding the Proposed MCA “ETV” Cuts There is extreme necessity for an official Coastguard vessel in the Dover Straits. The Straits are the busiest seaway in the world. It is often quoted that 500 ships pass through the Straits each day. While it is well known that the Straits include hazards like the Goodwin Sands, and that ferries with up to 2,000 passengers on board are constantly crossing the traffic streams, it may not be so well known that the traffic includes some of the very largest ships to be found anywhere—and that these typically have only a single propulsion engine. One example would be the container ship Emma Maersk, 400 metres long, three times the length of a football pitch, and almost as wide as one—with a single engine. The larger, and specifically the deeper, the ship, the narrower is the channel that it can use—these big ships quite literally have “no room to manoeuvre”. This “heavy traffic on narrow lanes” demands that Government not abdicate its responsibility for disaster prevention. The MCA refers to their current vessel as an “Emergency Towing Vessel” and, in suggesting that it can be done away with have only, and reluctantly, addressed alternatives for the “towing” function. It is important that it be recognised that this is actually a “Coastguard Emergency Vessel” with many other duties. Put simply, a Motorway Tow-truck, with a yellow flashing light, is no substitute for all the “blue light” emergency services—Police, Fire and Ambulance. At sea, these Coastguard Emergency Vessels do the work of land-based Police, Fire and Ambulance Service vehicles. These vessels, actually on the scene of an incident, are the very epitomy of a “front-line service”. Quite apart from towing disabled ships, these Coastguard Vessels are available at a few minutes notice, every day and night of the year, for duties that can include: — policing the Dover sea area, not least to ensure that ships obey the rules of the road and stay within the correct east- and west-bound traffic separation lanes; — intervening uninvited, and without the delay of commercial negotiation, in any developing emergency; cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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— preventing and investigating marine pollution. Illegal oil dumping (from tank washing) was previously a significant problem in this area, however, since the arrival of the Coastguard Vessels it has become an extremely rare occurrence; — acting as a Guard Ship, ensuring that other traffic keeps clear of a ship in difficulties (rather like a Police vehicle closing Motorway lanes after an incident), and even signposting and illuminating the scene after dark, in the all-too-common event of a ship losing power and lighting in the shipping lanes; — providing fire fighting capability at sea; — providing on-scene command and control facilities for rescue efforts. A commander at the scene of the incident can determine much more than someone many miles away, who is only looking at a radar screen; — offering a capability for Border Control duties, monitoring and preventing illegal immigration and smuggling; — Hydrographic Survey duties and removal of hazards to navigation, including wreckage and lost cargo; and — availability for Fishery protection duties. Consequently the Coastguard Emergency Vessel in this area could never be functionally replaced by a mere commercial towing vessel. A yellow-light tow-truck cannot possibly be a substitute for the official blue-light emergency services. If the Government were to propose removing the Police, Fire and Ambulance services from the roads of Britain they would be rightly ridiculed. And no-one would be satisfied if the Government were then to say “Its all right, we will ensure that there will be plenty of commercial tow-trucks available to cover all types of emergencies”. The proposal to remove the official presence of Coastguard Emergency Vessels is a policy for the seas that would be instantly dismissed as crazy, if it were to be suggested for the roads. April 2011

Written evidence from Liz Hustler (MCA 21) I understand questions are invited for the transport select committee to put to Sir Alan Massey and the MCA management on Tuesday 8 February. I have one main question, which I am hoping can be presented: Why when all the current coastguard stations can access all other stations remotely, can access all the necessary databases for information and take control of any station's area by remote access, do we need the cost of setting up MOCs? MOCs, which are planned for two of the most expensive areas of the UK, with new technology, which has not been tested and/or proven and with the cost of training or relocating staff. The Coastguard service does need to save money, that is without debate, but why not propose to close every other station around the UK plus two or three more if necessary? This would reduce stations from 18 to approximately seven, but the service would be able to utilise the existing structure and technology already in place. Surely this would be far cheaper to implement, still achieve a high level of cost saving, reduce the amount of negative public opinion amongst the leisure maritime and ﬁshing communities, which is being generated by the current proposals, utilise the new computer systems, which are already being rolled out, and maintain the stafﬁng levels necessary to monitor adequately the maritime distress channels. February 2011

Written evidence from Coastguard Watch Officer (MCA 22) I am a Coastguard Watch Officer at MRCC Swansea. I have been informed that I can submit questions to you for the Transport Select Committee meeting on 08/02/11. I would be very grateful if you could ask the following questions. 1. Does the agency intend to cease listening to International voice distress and calling frequency VHF Channel 16 in the future? If so when will the general public be informed? How will this impact on Search Rescue operations? 2. How many current staff are anticipated to move the Maritime Operations Centres? If this number is far less than anticipated, what plans are in place to fill the experience, skills, and knowledge gaps? (The general consensus around the coast is that very few staff will be willing to move. Over the past 15 years staff have been recruited locally and due to the low wages are second income earners or have been forced to seek another cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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income and can not afford to move. The staff who were recruited prior to this were generally second career people, who now fall into the redundancy bracket). 3. What are the security costs for sub centres when they are closed at night? What plans are in place to ensure running equipment is safely monitored overnight? 4. MRCC staff provide a 24/7 point of contact for the public who require immediate assistance when they are in grave and imminent danger on the coastline or at sea around the UK. Why does the MCA not consider these staff to be a frontline? (The Coastguard coordinate Search & Rescue, we do far more than take calls and despatch resources) 5. How will the Maritime Operations Centres be staffed? Has a risk assessment been carried out? If there is a model for the stafﬁng levels, has been tested? 6. Lack of local knowledge in MRCC—MOC staff will result in slower response times, which in a Maritime Search & Rescue situation can mean the difference between a successful rescue or body recovery. Why does the MCA no longer consider Local Knowledge important for MRCC—MOC staff? February 2011

Written evidence from a Clyde Coastguard (MCA 23)

How can Alan Massey justify retaining MRCC Aberdeen, when it costs more to run than the other ﬁve Scottish Stations put together? MRCC Clyde handles more incidents over longer periods of time and therefore has more experience than Aberdeen how can Sir Alan Massey justify the loss of this expertise.

How can Alan Massey justify selecting two of the most expensive places for people to live, for the locations of the MOCs? During Transport Questions on 27 January 2011, Mr Phillip Hammond said “I should emphasise to hon. Members that we are talking about search and rescue co-ordination centres. They are not front-line delivery points; they are the centres that manage and co-ordinate the calls coming in, and task the front-line rescuers.” Alan Massey himself has stated that the operations room staff, are not front line service.

Is Alan Massey under the impression that the only input operations room staff have, is to answer calls and task the front line staff to respond and have nothing further to do with the running of an incident? You have stated that the closure of stations will not affect the response times during incident working. Given that your proposal is to get rid of approx 50% of operational staff and more than half of the stations I think it is important that you understand exactly what the operations room staff do and I’d like you to explain your understanding of the roles undertaken by these staff during incident working.

What level of public dissatisfaction would need to be experienced to cause these proposals to be thoroughly reworked, with full and proper consultation involving all the concerned parties?

Coastguard Operations Rooms work very closely with partner agencies, most notably the RNLI and Military Helicopter providers, Police and Ambulance. What opinions have they expressed concerning the proposed changes? Alan Massey has publicly stated that it is not cost effective to have coastguard stations fully manned during the quiet periods, does he therefore propose that most of the full time ﬁre stations be closed for the same reasons. How much has the Consultation Process cost thus far and how much is it anticipated to cost by the end of the process. Why is it only coastguard personnel which seem to be losing their jobs.

If Alan Massey has visited coastguard stations, why does he think that they are just call centres and what happens when volunteers are not available to go to an incident or to give local knowledge.

Why when the system was tested recently at the Training centre in Highcliffe and failed are the MCA still going to try and implement it. February 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Written evidence form Karen Paradise (MCA 24)

Question1

Why has the following not been considered by Sir Alan Massey and management before Thames Coastguard was marked for closure?

1. Unlike other Coastguard stations, the Thames Coastguard site is owned by the MCA. Located in the same building as the Coastguard there is the Harwich Marine Ofﬁce (MCA Surveyors), the Counter Pollution and Salvage Ofﬁcer, and the Coastguard Rescue Team, all of which will continue to be based at the site. Located on this site is also the Walton VHF/MF/AIS radio aerial. The cost saving by removing the Coastguard Operations Room staff from this site is therefore minimal.

2. Contained in the Thames Coastguard District are: (a) The busiest leisure area after the Solent (yachting hubs in the rivers Alde, Ore, Deben and Orwell, the Blackwater Estuary, the rivers Crouch and Roach, Southend and the Medway). Total leisure vessels 6,617 + those in transit or trailered to the area. (b) Numerous ports including: Felixstowe—largest container port in the UK and one of the largest in Europe. Harwich—one of the UK’s leading multi-purpose freight and passenger ports. London Thamesport—one of the UK’s busiest container ports. London Gateway—Construction underway for the UK’s newest deep-sea container port combined with Europe’s largest logistics park. Once complete, London Gateway will berth the world’s largest container ships. Also the ports of Wivenhoe, Brightlingsea, Bramble Creek, Mistley, Ipswich, Tilbury and a number of commercial shipping berths within the river Thames. (c) There are numerous wind farms operating and under construction including the; Gunfleet (48 Turbines), Greater Gabbard (140 Turbines), London Array (340 Turbines) and Kentish Flats (30 Turbines). (d) There is the major commercial traffic area in the Sunk Precautionary area and Traffic Separation System. (e) A number of very busy beach areas at; Felixstowe, Walton, Clacton, Jaywick, Southend, the Isle of Sheppey and Whitstable. (f) There can be up to 20 ships anchored at a time off Southwold, waiting to carry out ship to ship transfer of fuel. There is a potential risk of major pollution during these transfers.

3. Thames Coastguard deal with a particularly challenging geographic area with offshore shipping channels, offshore and onshore sand banks, rivers, estuaries, creeks and areas of mud, marshes.

4. Thames Coastguard provides support to London Coastguard for the lone operator on duty there. When for instance, during an incident, the operator is over-run with telephone/radio calls or when the operator needs to take a meal/comfort break. Thames Coastguard remotely operates the site.

5. How will the Maritime Operations Centre (MOC) in Aberdeen competently deal with incidents along the south coast on days that overload “MOC South”, due to their lack of understanding of the area and the local conditions experienced.

6. There will be no dedicated cover for the Thames District, incidents will be either co-ordinated at Aberdeen or Southampton/Portsmouth, or Dover or Humber dependant on their work-load at this time.

Question2

Having read both the document “MCA 05” and Question 1 above, having seen the amount of oposition from commercial & leisure maritime organisations and the general public, is Sir Alan Massey now of the opinion that the “HM Coastguard Proposals for Modernisation Consultation 2010” are not feasible?

I would be very grateful if the above questions could be asked. February 2011 cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Written evidence from Simon Davey (MCA 25) Would you please be kind enough to put the following question to Sir Alan. Is Sir Alan aware that because of future uncertainty, anecdotally at least, watchkeeping staff are leaving (or planning to leave) certain MRCCs in considerable numbers, potentially rendering those stations operationally undermanned as we approach the busiest period of the year. Stations affected may not be able to continue to operate as they do now, possibly in the very near future. Are there any plans in place to manage this situation? February 2011

Written evidence from Grahame Thompson (MCA 26) 1. Why Aberdeen for the northern MOC? It’s one of the most expensive places to live in the UK unless you work in the oil industry, local recruitment is poor, staff turnover is extremely high, housing is very expensive, are there funds available to help personnel moving to Aberdeen, and if so will it be on new terms or are they keeping the old terms. 2. Why was no risk assessment carried out for this consultation, we have to ﬁll in a RA just to drive the staff car, and every time we drive the staff car! 3. Why were no operational coastguards consulted on this document, management have already stated that no operational coastguards were consulted, Watch Manager Grade or below. 4. Why are they now recruiting a person to oversee these closures, surely that should of been done months ago. 5. Scotland BT is currently running at 115% capacity, how can the MCA absolutely guarantee the stability of the network to support the communications needed. 6. Why is management down playing local knowledge, staff are examined on this subject every two years, and on arrival at a new station you are examined within six months. To keep your SAR Mission Coordinator ticket valid you are only examined every ﬁve years. February 2011

Written evidence from Les Jenkin (MCA 27) I am sending this as a current Operation Room Coastguard and also as a PCS member of the Brixham PCS Executive board as I know that you have a meeting with Senior Managers of the MCA on 8 February 2011. I am sorry it is so long but it just goes to show the strength of feeling not only at Brixham but at every MRCC around the UK very few operational staff believe that the proposed system will be able to carry out a responsibility for Search and Rescue as required under the Coastguard Act. The Consultation document itself is very flawed with little detail and we believe that before publication some other papers were withdrawn from the Document. It is, therefore, very difficult to submit a constructive answer to it when we do not seem to have had all the facts. I am sure I speak for all Operational Staff in thanking you for reading this email and trust that you may be able to get some answers from the MCA Executive board and perhaps allay some of the doubts we all have for the proposals under the Consultation Document. I am sure that you are aware of and as concerned about the closure of Coastguard Stations around the U.K as are a great majority of the British Public. These proposed closures include Brixham and Portland and Falmouth Coastguard becoming a day station only. Staff at these and other stations will be made redundant or have to re-apply for their own jobs at one of the two x 24 hours stations at Aberdeen or Portsmouth. We believe that, contrary to the MCA and Chief Executive, Sir Alan Massey that lives will be at risk in our area which goes from Exmouth to Mevagissey, half-way across the English Channel as well as around the coast of the U.K. Local knowledge and experience will be lost and local contact with the Fishing Fleet, Yacht Clubs, Harbours, Dive Clubs etc will be lost forever. We have until the 24 March to respond to the document. The knock-on effects will be huge for local amenities, hotels, shops etc and will in effect be the end of an era for Torbay. There is a great deal of support from The Fishing Community, Dive Clubs, Yacht Clubs and the public. All these people are gravely concerned that lives of Mariners and people ashore will be greatly increased but this has been refuted by the CEO who believes that locations will be quickly found on updated systems. We have had some major incidents over recent years, ie MV Ice Prince, MV Santa Anna and Bothnia Stone etc. These were expertly handled by Brixham and we believe that Aberdeen or Portsmouth would find the same task challenging. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Below is a list of Statistics for MRCC Brixham for the last ﬁve years including the totals for people rescued from life threatening situations and those assisted in other ways. 76.1% of our Incidents occur either on land, just offshore or within the 12 mile limit and for these local knowledge is vital with local place names that are not shown on any mapping system but are known to staff on duty. Sir Alan Massey has told us in person that no new equipment will be introduced in the new centres but that the current equipment will be upgraded. All Operations Room staff will tell you that the current system is in no way robust or reliable and tends to crash very frequently. Stuff currently around the U.K. have serious doubts that the new MOC’s will be able to cope with the work load especially during busy summer months along the South coast and can only lead to more staff going sick with stress as the noise levels and numbers of incidents will be tremendous.

BRIXHAM STATISTICS 2006—2010 Year Total Incidents Rescued Assisted 2006 1,117 316 939 2007 1,160 405 1,943 2008 1,040 260 4,498 2009 1,263 372 1,389 2010 1,298 358 1,926 Totals 5,878 1,709 10,715

2010—Brixham Incidents on land, close Inshore or up to 12 Nautical Miles Offshore = 76.1% of Year Total. The proposed new system is lacking in critical details. Some examples: — to what extent will the new system form a national network- the two main centres are being treated interchangably, meaning that every operator will need to be able to handle calls from every corner of the country. — to what extent will the VHF network become amalgamated? What will the effect of this be on radio trafﬁc? — or if- the role of the “daytime” stations. It is not currently known whether they will handle local matters only they will provide additional staff on a national network. — local knowledge will be captured on a “database”; this does not yet exist and it is unclear how it would work, or to what extent it would delay operations. — the proposal assumes greater reliance on volunteers for critical activities including the initial task of locating the casualty. Nobody knows how the volunteer force will respond to this increased demand and signiﬁcant change in role. — no risk assessment has been carried out by the MCA on the effect of these proposals. The biggest weakness in the new system is the possibility of misinterpretation and delay. At present, when the CG are contacted, they will have your location pinpointed before the end of the call. They can do this because they know their “patch”. But it is being proposed that in the new system they will rely on RNLI and similar “resources” to help narrow down the location. This means that the point at which the casualty’s position is known is deferred until later in the process. Assumptions will have to be made about which RNLI unit etc to call on. In the past the wrong lifeboat has been sent due to confusion over place names- the possibility for such errors is far, far greater under the new system. Anybody who welcomes this proposal as improving safety has done nothing but read the cover page. It is alarming that the RYA fall into this category. In reality, the supposed improvements simply involve greater reliance on electronic safety systems. This completely ignores the role that the CG play in providing a rescue service for non maritime users, or the growing numbers of users of very small craft (kayaks etc). February 2011

Further written evidence from Les Jenkin (MCA 27a)

1. Ref the Number of Incidents Quoted and Shown in Public Meeting Transcripts for 23 June 2006 Managers attending Public Meetings around the United Kingdom have stated that a trial had taken place in the form of a table top exercise prior to the Consultation details being released. They have quoted that the date chosen was the 23 June 2006 which was in fact a Friday. At one meeting it stated that this was the busiest day in the last 10 years and at another that it was the busiest day ever in Coastguard history. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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I would dispute the fact that a weekday in June, when schools had not broken up and it was not a Bank Holiday, that this can in fact be the case. I don’t believe that any totals for that date were given at the Public Meetings.

If a real test was required I would suggest that a Saturday or Sunday or even a Bank Holiday Monday in August would have provided a more accurate and realistic overview of the number of incidents that MRCC’s around the United Kingdom dealt with and would have to in the future.

On a busy weekend or Bank Holiday during the summer we at MRCC Brixham can have up to 20 incidents during a 24 hour period with the majority occurring during daylight hours. MRCC Solent regularly have 30–40 incidents in the busy summer period.

In the current economic climate it is likely that more and more people will holiday in the United Kingdom and this will mean increased numbers going to our coastal resorts which in turn will lead to an even greater number of incidents.

2. Independent Chair at Open Meetings Held by MCA

We were given to understand that the Chairing of the public meetings was by an independent person not connected with the MCA.

As it turns out, the Central Ofﬁce of Information Governments News Network were allocated to chair all the meetings around the United Kingdom. It was discovered that the COI and the MCA did in fact have a working relationship and presumably Senior Managers at both Agencies knew each other even if only on a formal basis.

On 25 October 2007 the COI and MCA were jointly awarded ﬁrst place in the Issues and Crisis Management category of the PW Week Awards 2007 in relation to the MSC Napoli incident.

Robin Whitbread was head of the COI team working with the MCA at this time and he in fact was the “independent” chair person at a great number of the open meetings held by the MCA in recent weeks.

Having looked up the COI in Google I found that their ﬁrst line included the phrase “Our focus is always in engaging and inﬂuencing audiences at the right time and in the right way, nationally, regionally and locally”.

Was this the intention when COI were appointed to chair the Public Open meetings?

3. Running of Public Open Meetings

At our Open meeting on the 10 March 2011 about 250 people were present including local dignitaries, Coastguard regular and volunteer staff and members of the public. After the initial MCA presentation the room was opened up by Mrs Jones for questions. Although many good questions were asked by the public it was apparent that no known or suspected Coastguard staff were to be “selected” at random to ask a question. I, in fact, had my arm raised for over an hour of the hour and a half meeting but not unsurprisingly was not asked or given any opportunity to address the meeting.

I gather this has been the same format and procedure at most of the other meetings held around the United Kingdom. Mrs Jones looked in my direction on several occasions but ignored me and chose what she obviously thought would be somebody with a less controversial point to make.

Members of the public have commented that they were also disgusted with the conduct of the meeting and felt that those affected most should have been given the opportunity to ask Senior Managers relevant questions. They were also concerned that MCA Managers were unable to provide statistics in relation to MRCC Brixham when questioned about the graphs shown in the presentation.

The MCA claim that due to Union Industrial action that no statistics are available after 2006. I have collated statistics at Brixham using the B.O.S.S. Database to which MCA management also have easy access. I have statistics obtained from B.O.S.S. for the last 10 years. If I can obtain these statistics so easily there is no reason why they cannot at least get Search and Rescue Incident totals for all stations up to and including the present day.

As a matter of interest for the first three months of this year, the number of Search and Rescue Incidents at Brixham is already up by over 60 on last year as are the number of persons rescued and assisted. We have also had five lives lost at sea already as opposed to just one fatality in the first three months of 2010. If this is the current trend around the coast then it would make sense to have more stations kept open as opposed to the two MOC’s and six day stations proposed. April 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Written evidence from Stephen Hennig (MCA 28) I am writing to you in the knowledge that the commons select committee session on 8 February will concern evidence from the Maritime and Coastguard Agency. I watched with great interest an interview with Sir Allan Massey, chief executive of the MCA, on BBC2 Reporting Scotland on 31 January. In it Sir Allan frequently referred to new Geographic Information Systems (GIS) to be facilitated in the new setup of UK Search and Rescue. However, he failed to explain what these new systems to be used by HM Coastguard are and when they are to be introduced. The new equipment replacement programme currently undertaken by the MCA does not include any new GIS, just updates to already used software. Likewise, the consultation document on reforming HMCG makes no mention of new GIS at all.

Could Sir Allan explain what these systems are, whether they are tried and tested or whether they were only thought about after the consultation document was published? Furthermore, he mentioned the use of Google Earth as one option to be facilitated in UK Search and Rescue. Google Earth, while free to use, is currently not used by the MCA because of computer security protocol (which is unlikely to be loosened and more likely to be tightened further as computers/networks are coming under increasing threat from cyber attacks). Google Earth can also only be used as a platform in conjunction with GIS rather than a stand-alone system. I would be very grateful if you could please enquire of Sir Allan how he envisages to use GIS as a replacement/enhancement of local knowledge, what those new systems are and how they will be implemented quickly as the ﬁrst two rescue coordination centres are due to close within the ﬁnancial year 2011–12. February 2011

Written evidence from Kathy Grant (MCA 30) Firstly, thank you for giving us the opportunity to have our questions asked. I know you will not be able to ask them all, but it gives us the chance to be heard. I would like to ask: (1) In the consultation document it talks of the communications plan. Whilst at a meeting on 6 January 2011 Richard Parks (Director of Corporate Support) admitted that there was no such document, and that the “NEW” equipment was actually the same we are using NOW. Why is there misleading information in the document and mention of plan that do not exist? (2) The report on the risk assessment has been requested several times. At a meeting on 20 January with Bill McFadyen (Regional Director for SCOTNI) and Ian Burgess (coastal Safety Manager for North SCOTNI) when again a copy of the report was requested and results of the risk assessment the reply was “we did think about that”. When asked if one was carried out, the reply was “we thought about that”. We believe there has been no formal risk assessment carried out and therefore there is no report. Can Mr Massy provide this committee with a formal risk assessment document? If a risk assessment has not been carried out, then why are the board of directors saying there has been? Again a bending of the truth. I know there will be many many more questions from around the coast, I hope mine help. February 2011

Written evidence from Katrina Hampson (MCA 31) Questions to Ask 1. When a fault occurs in Shetland or Stornoway where all communications are down (both radio and Telephone) how will the North MOC be able to communicate with the Islands. The Resilience at the moment is that the aerial at the MRCC is hard wired into the ops room which enables the ops room to take local control and speak to Coastguard Rescue Ofﬁcers at Remote Aerial Sites if the station is not there this resilience is not there either. The last instance of this was October 2010 where all communications to the mainland were lost for over 72 hours. What is the MCA’s resilience plans for this. 2. Will any back-up connectivity for the Remote Radio Sites be provided in the event of a loss of Kilostream connection. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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3. Has a full Risk Assessment been carried out on these proposals. 4. What are the contingency Plans if the MCA cannot fully man the MOC’s. February 2011

Written evidence from Lynne Fry (MCA 32) I am writing to you as a Coastguard Watch Officer to express some of the many serious concerns of the operations room staff, particularly with regard to recent events surrounding the proposed cuts outlined on the MCA Consultation document. It seems that MPs are either unaware or have been badly briefed about the nature of the job that we do in the Coordination centres, if their comments when questioned are to be believed. Philip Hammond and Mike Penning have consistently referred to Coordination centres as non Frontline services and that we are call takers working on a national basis. This was particularly evident when answering questions relating to the proposed changes comparing them to the already scrapped plans for the fire service.* In effect the changes proposed are very similar to the Fire service and as such will be unworkable because of the local nature of the job that we do and the fact that we are very much in the front line when effecting rescues along the coast and at sea in our specific areas. All communications with the coastguard rescue teams, lifeboats and other rescue units are via the operations room and logged accordingly. We question informants in detail to determine the correct location by telephone/ radio. Most of our incidents are in areas not covered by post codes so are not immediately obvious by the mapping system. In the case of vessels at sea a knowledge of charts and navigation markers is also required in order to respond in the quickest and correct manner to any incident. Therefore to say that Local knowledge is not relevant is totally incorrect ... If this were the case why is local knowledge one of our key competencies and something we all need to be examined in every two years as per the attached document. We do not work in the same way as the police centres whereby a call is taken and then passed on to another unit in order to deal with the incident. Here we monitor and actively control the incident from the coordination centre and are very much hands on from start to finish in effecting rescues determining search areas and giving precise instructions to rescue units on scene based on the information being constantly fed into the system. Another point I feel it is important to raise is the proposed reliance on Digital Selective Calling as a means of distress alerting instead of maintaining a listening watch on VHF Channel 16. As an ex merchant navy Radio Officer I can understand how this system operates but without legislation insisting that all small boat users carry the equipment and use it correctly this is a recipe for disaster. Small boat owners and local fishermen will be reluctant to rely on this technology as a means of distress alerting, and, according to IMO GMDSS regulations a DSC signal is purely an alerting mechanism and should be followed up immediately with a broadcast on CH16. Therefore unless this is changed completely CH16 will continue to be the preferred method and has been actively encouraged by the Coastguard and the MCA for at least the last 10 years. The MCA has also actively promoted the use of radio rather than mobile phones on small vessels but the proposals now say that mobile phones are one of the primary means of communication. Another point to note about DSC is that any position indicated in the alert could be up to six hours old unless the equipment is linked to a GPS navigation system so the broadcast on CH16 is extremely important. Can I request therefore that these points are considered amongst your questions to the MCA representatives at the Transport Select Committee meeting on 8 February. *Info from the Transport ministers questions on BBC Parliament and replies given to our local MP and perpetrated on the BBC and in the press. February 2011

Written evidence from John Steer (MCA 33) I am writing to you to convey my deep concern about the recently published proposals for the re-organization of the Coastguard Service. These together with the decision to withdraw the four ETV’s seem to demonstrate an alarming lack of awareness of maritime safety. Just a brief biographical note so that you can gauge my background might be useful. My grand-father and great grand-father were lifeboat crew members and my father served 35 years in the Royal Navy retiring as a senior CPO. I myself ﬁrst sailed seriously at about the age of ﬁve almost 60 years ago. I am a boat owner and have sailed extensively throughout British, European and Arctic waters, fortunately without mishap, never requiring the services of lifeboat or coastguard despite some narrow escapes. I have no connection with the coastguard service whatsoever although I know local coastguards personally. I have just watched Transport Questions on BBC Parliament and was amazed by Philip Hammond’s answer to Ms Doyle in which he said that MRCCs are not front line responders. Was this deliberately disingenuous or simply a lack of understanding of the role of MRCCs? On receiving a call for assistance no SAR operation cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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can be launched until a MRCC evaluated the options available and tasked the correct rescue assets. He seems to be falling into the trap many critics of these proposals have suggested: namely that the MRCCs are nothing more than call centers. I realise ministers not the authors off these proposals and that I suspect neither Mr Hammond nor Mr Penning have much experience or knowledge of the sea and using it but I urge you to question most severely those senior MCA officials who have worked on this plan. How much actual recent experience has they of SAR on the front line? I have read in full the proposals on the MCA website and completed the online consultation response form but consider it rather restrictive in scope and slanted in its questions. I am therefore communicating with you to express my misgivings in greater detail. I am aware that Mr. Penning is Minister for Shipping but as Secretary of State I assume that you are ultimately responsible. I have copied some of the statements made by Mr Penning in the introduction to the proposals below. Our seas are becoming more congested. The volume of shipping is increasing in many areas. We have many more large ships confined to deeper water in restricted channels. Large numbers of offshore renewable energy installations are being developed around our coasts restricting the areas available to shipping. Ships are getting larger. Today’s ultra large crude carriers carry up to 500,000 tons of oil, some five times the capacity of the Torrey Canyon, which sank off Cornwall in 1967. The largest container ships are 1,000ft long and can carry more than 11,000 containers. So, while shipping has generally become safer, the increasing number of very large vessels means if an incident occurs the consequences may be much more serious, affecting more people, causing more pollution and disrupting critical supply chains. Our coastline is getting busier. The UK has more than 10,500 miles of outstandingly beautiful coastline. Today millions of people use our seas, coasts and beaches for an increasingly wide variety of recreational purposes, often in areas that are also well used by commercial shipping These comments would seem to argue against any down sizing of the full time coastguard service; incidentally the British Cartographic Society considers the entire coastline of the UK to be 19,491 miles with Scotland itself having a coastline of 11,550 miles. It should also be noted that these proposals do not affect the response times of lifeboats that are provided independently of HM Coastguard by the RNLI, other independent organisations or rescue helicopters. These organisations are not affected by this restructuring. This is a disingenuous statement to say the least. True the Walton lifeboat will continue to launch within ten minutes of its crew being paged but the key factor in its response time or that of any lifeboat will be how long a remote MOC takes to ascertain the situation and push the pager button. Interestingly the MCA consultation page on its website does not count the RNLI as an emergency service nor does it allow a contributor to tick a box indicating that they are connected in some way to the RNLI, be it as a crew member retired or active or as an active fund-raiser or official!! The current organisation of MRCCs was conceived in the age of radio, which has been superseded by the technological advances of AIS, Vessel Traffic Management and Digital Selective Calling. The new structure will seize the opportunity provided by technology, maximise the knowledge and skills of Coastguards and implement modern, flexible working practices. The full rationale for change is outlined in the consultation document. If the only vessels sailing our shores were commercial or if all vessels of every description were fitted with AIS and DSC this would be a valid statement. The reality is rather different. Whilst most leisure craft have VHF radios many of the smaller craft especially speedboats and the like use mobile phones, a not totally reliable means of communication. Even when fitted with VHF an essential requirement is to know where you are. Would you be surprised to know that it is not uncommon for leisure boaters to have no idea of their position, not to have charts or know how to use them if they do and to misunderstand readings of GPS and chart plotters? For some the road atlas is the favoured means of navigation. This factor alone makes the decision to withdraw VHF DF facilities from MRCC’s incomprehensible. This could mean several lifeboats being tasked to search for lost craft where previously a bearing or cross fix from one or more DF aerials would have given an approximate position. It will also hinder the identification of carriers on Channel 16. Currently a very busy station will have to deal with this peak load within the constraints of their staffing level on that day. Currently there is very limited facility to delegate away activity of a non SAR nature or to reinforce the number of officers available. The proposed new national network will allow the delegation of non SAR work and for additional staff to be utilised from other stations Of course there are different levels of activity around the UK coast but I am puzzled as to how the MCA hierarchy will be able to anticipate a sudden burst of activity. Can anyone anticipate when a cruise ship or ferry will catch fire or collide with a large container ship? Equally how can anyone be sure when a sudden change of weather conditions such as a sudden squall or sea fog will occur especially in summer months? Is it the intention to have large numbers of coastguards standing by ready to rush to whichever MOC is suddenly facing a major disaster? If so where will they be waiting? What research has been done to anticipate the number of extra staff needed at peak times this? How many extra staff will be available? cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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We will also maintain our current strong working relationships with partner SAR organisations such as the RNLI, in which considerable local knowledge and expertise reside. These proposals reorganise how HM Coastguard delivers its service but do not affect the day to day operational interface with partners such as the RNLI. It is true that the local knowledge of lifeboat crew will remain but it will be of little use if the local knowledge of the current MRCCs is lost and an inappropriate lifeboat is tasked. Thames, my local station, controls ten lifeboat stations from Southwold to Whitstable. The watch managers will have built up close contacts with the lifeboat LOM, coxswain and helmsman. The proposed new MOC in the Southampton area will have vastly more lifeboat stations to control particularly at night when presumably it will be responsible for all lifeboat taskings in England and Wales. How many CG watch officers will be on duty to deal this at the new MOC? Let me highlight two incidents last year. In the first a large vintage wooden yawl ran around on one of the numerous sandbanks in the Thames Estuary two hours into the ebb tide. The skipper was supremely confident, as yachtsmen often are, that he needed no assistance to refloat. The CG watch manager consulted with the local lifeboat coxswain and both agreed that the lifeboat would launch to assist on the flood tide. Just as well for with a freshening wind, two little anchor cable and a lee shore the yacht was pushed further up onto the bank before being successfully refloated by the lifeboat without suffering too much damage. Just after Christmas a small 20ft angling boat reported engine failure. The Harwich ILB could quite easily have dealt with this casualty but there was dense fog, less than 50 yards, known of course by looking out of the window. It was bitterly cold and the CG watch manager correctly requested the launch of the Walton ALB equipped with radar and radio d/f. Would the Southampton MOC have made the same decision in this case without knowledge of the local weather conditions? What consultation would have taken place over the yawl aground or would nothing have been done until the situation became serious. I think it implausible that the MOC will have sufficient staff on duty to deal with the numerous incidents of this nature that will occur. I am distinctly under-whelmed by Mr Penning’s various media interviews and statements on these proposals for he displays a somewhat low level of understanding of the work of the full time coastguard. He repeatedly claimed that the current set up is inefficient without explaining why other than the claim that the workload was uneven and the need for better technology. If new technology is needed why not install it in the present system? What is this new technology and will it work successfully unlike many government IT projects? In my long experience sailing around the UK the CG response if usually quick and efficient for whatever is required of it. Mr Penning stated that a 999 caller would receive the same response as now. From various media reports I have read, seen and heard comments that MRCCs are nothing more than call centres, opinions based on ignorance I assume, never a sound basis on which to make a judgement. This is frankly highly insulting to highly skilled and trained coastguard staff. MRCCs are a great deal more than call centres. (Are you aware of the training required for a CG watch officer?) Mr. Penning gave no indication that he is aware of VHF Channel 16, 2182k/c and DSC selective calling which are the main means for maritime distress communication. Likewise he claimed that local volunteer CG teams would be strengthened but they can only respond when they are paged. In any case with offshore incidents, which are the majority of SAR incidents, what use are beefed up teams of volunteer coastguards when a casualty vessel is 20 miles offshore? Just as for lifeboat tasking how long will it take fort a remote MOC, lacking local knowledge and intimate understanding of tidal and weather conditions prevailing at the scene, to decide which is the most appropriate asset to deploy? Indeed will they even make the right choice for every incident? How will a coastguard based in Southampton correctly identify an obscure Welsh beach bay or headland with an almost or indeed wholly unpronounceable name? How many Penrhyns are there in Wales: I know of at least ten. Recently while in Cornwall I heard an interview on BBC Radio Cornwall at 12:30pm on 7th January with the recently appointed head of the MCA on whose advice I suspect you are relying. I have obtained a transcript of this broadcast, which is very interesting in as much as it shows a lack of understanding by Admiral Massey of the realities of SAR. He also comes very close to admitting that the real driver of these proposals is cost saving insisted on by the Treasury. (Transcript sent as separate attachment) Below is perhaps the most alarming part of this interview: I recognise the… I absolutely recognise the importance of maritime safety, otherwise I wouldn’t have volunteered for this job. I mean, it’s… yes… yes, you’ve got a… you’ve got limited time to respond but frankly, even now, a coastguard will spend… spend a good bit of time making sure that the informant has actually got the place right, that the lat/long… sorry, latitude and longitude position is correct. This takes minutes and, you know, a couple of extra minutes on that is not going to be life-threatening. This is the point: we’ve got to make better use of what’s around, otherwise we just put our hands up and say, “Well, let’s go back to coastguard stations five miles apart, that’s the only way to do it” it clearly isn’t. If Admiral Massey believes that every vessel in distress will be able to give an accurate lat/ long position he is wrong for reasons already stated. It shows a somewhat naïve appreciation of the nautical knowledge of many leisure boat owners. For example how will a child drifting out to sea in a rubber dinghy give a lat/long or a swimmer or a family out in their newly acquired speed boat for the first time running out of fuel (fuel cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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tank or consumption not checked) be able to give lat/long when they have no GPS and to their astonishement discover no sign posts out of sight of land? As for his claim that two extra minutes will make no difference that is wholly irresponsible for as a recent sea safety campaign stated seconds count. No one as far as I know is advocating returning to the system of my grandfather with CG stations every few miles keeping visual watch. These statements seem to be those of a man trying too hard to justify change. He may have had a distingushed naval career but that does not automatically qualify him to understand SAR? Will the proposed day centres deal with SAR incidents if so how will the transition from them to the MOC take place when the day centres close down for the night? This has the potential for much confusion as many incidents start close to watch change with the present system. Will the day centres have fixed hours of operation or will they be variable according to the time of year? Will the Scottish day centres be open fully during the long summer hours of daylight? I am confident you can tell me the answer to these questions, as I would be most surprised if the authors of these proposals would not have considered them. Local knowledge is at the core of most leisure SAR incidents and the loss of this will almost certainly lead to increase response times and possible loss of life. I have seen statements from top MCA officials suggesting that local knowledge is not essential and yet I understand that CG officers are tested on local knowledge at regular intervals. I would like you to know how the proposed MOCs are to be organised; the number of watch officers on duty at any one time, how best practice from the closed MRCCs is to be used and how the local knowledge that resides in those closed MRCCs is to be utilised. I assume Admiral Massey knows the answers unless of course these proposals were formulated without thinking through the methodology of carrying them out. Will all the responses be posted on the MCA website? Can serving CG officers be certain that any adverse comments they might make about these proposals will not lead to disciplinary action being taken against them? I have noted two recent decisions made by the Government namely the abandonment of regional fire centres because according to the statement issued by the fire minister there will be loss of local knowledge, the cost has overrun and the technology does not work. What backup will there be should technology at one of the MOCs fail? Indeed what is this marvellous new technology? The second Government proposal I noted with interest was the decision to amend the route of the HS2 link and to give more generous compensation to those affected by it, almost conclusively I suspect in Conservative held constituencies. Of course the consequences of implementing in full these changes to the Coastguard Service, should thy not work, are somewhat more serious than a loss of property values or having a high speed train rumble past the bottom of a very spacious garden. Equally by the time the mistake is realised you and your colleagues will have moved on to new fields. When I next venture across the North Sea to Holland or Germany I trust I will not have a problem until east of the Nord Hinder which will bring me under the control of the Dutch Coastguard Service. February 2011

Written evidence from Roger Davis (MCA 34) I would like to protest about the proposed programme of closure of HM Coastguard stations, especially MRCC Brixham and MRCC Falmouth. I feel that with the establishment of only two 24-hour stations to cover the whole of the United Kingdom, this would not provide the necessary resilience required to protect the lives of the seafaring public. Sickness at one station and technical difficulties at the other, where is the resilience? I fear for the safety of people engaged in leisure activities on the coast, cliffs and beaches of the United Kingdom, and for the safety of small leisure craft in difficulties in coastal waters. If the Coastguard service is centralised in two centres, Aberdeen and Solent area, local knowledge will be lost, and however good the communications lives will be put at risk. Also, the demise of VHF direction finding at HM Coastguard stations since 31 December 2010, does not now give the watch-keeping staff a haystack to search. It is a bit late in the day for mobile units ie RNLI All Weather Lifeboats and Inshore Lifeboats or SAR aircraft to search, if only one transmission from a distressed craft has been received at a Coastguard station. Lifeboats and SAR aircraft will not launch without this information. I am writing this letter to request that you refer the proposal to close ten of the UK’s 18 Coastguard Co- Ordination Centres to the Transport Select Committee in the House of Commons. I appreciate that I do not live within your constituency but my feelings on this subject are extremely strong and I am writing to you and all your fellow Members of Parliament. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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The decision to close these coastguard co-ordination centres is seriously ﬂawed, and amongst a number of reasons as to why they should not close and be centralised the loss of local knowledge is paramount.

SAR Responsibility—Government

The requirement for DfT to maintain an adequate and effective search and rescue organisation and to establish national machinery for the overall co-ordination of search and rescue derive from the UK Government’s acceptance of the Convention of the High Seas 1958, of the International Conventions of Safety on Life at Sea 1960 and 1974, and of the International Convention on Maritime Search and Rescue 1979 (as amended).

The Coastguard Act 1925

By the authority given to the Secretary of State by the Coastguard Act 1925, it was agreed in Parliament on 9 March 1992 that H M Coastguard is responsible for the initiation and co-ordination of civil maritime search and rescue within the United Kingdom Maritime Search and Rescue Region.

This includes the mobilization, organisation and tasking of adequate resources to respond to persons either in distress at sea, or to persons at risk of injury or death on the cliffs or shoreline of the United Kingdom.

HM Coastguard Regulations.

HM Coastguard CG3 Volume 1 section 10.

10.1.3 SAR Unit Selection

SAR unit selection involves two major evaluations: (a) The operational capability of the unit; (b) The training and experience of its crew. The unit selected should be able to reach the scene quickly, and should be suitable for at least one, and preferably as many as possible of the tasks of a SAR operation. Evaluating experience is more subjective and means weighing the normal primary duties of the agency furnishing the SAR unit against the speciﬁc operation in hand.

10.1.4 Local Knowledge Commitment In order to meet the responsibilities outlined above it is necessary that all grades of Coastguard Ofﬁcers on ﬁrst joining a new station should acquire a thorough local knowledge of all available Declared and Additional SAR facilities, navigational hazards, coastal features, shipping activity and potential SAR problems within the Area.

You may already be aware that the last time a rescue service was going to be centralised (the ﬁre service), the decision was axed after eight years at a cost of £423 million to the taxpayer. The actual MP who announced the centralisation of the coastguard (Mike Penning) campaigned against the centralisation of the ﬁre service because the lack of local knowledge would endanger lives. According to a recent interview with Sir Alan Massey, the cost savings from the closure and centralisation of these coastguard co-ordination centres will only save £120 million over 25 years—roughly £5 million a year.

It therefore strikes me that Mike Penning MP, and the government as a whole, have not fully undertaken a detailed examination of the proposal before making the decision public. The savings envisaged can surely be found somewhere away from an emergency service; the cost beneﬁts do not outweigh the risk that will be introduced.

With an online petition set up against the proposals which has over 8,000 signatures as well as numerous Facebook groups set up which each have thousands of members, I once again request that you please refer the proposal for the closure of ten of the UK’s 18 coastguard control centres to the Transport Select Committee in the House of Commons. January 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Written evidence from Andy Cattrell (MCA 35) RE: PROPOSALS TO MODERNISE HM COASTGUARD—REQUEST FOR EVIDENCE Regarding the above proposals and your request for evidence I would be grateful if you could take some time to consider the points listed below and include them as a submission to your enquiry into the MCA proposals.

1. The Consultation Document The Consultation document is not a true request for opinions and/or contributions. It is more of an information document detailing what is going to happen to HMCG over the next three to four years. A bona fide consultation would have alternative proposals and ideas for discussion and consideration. There are no alternative proposals, this is the plan. It has been generated by a select group at MCA HQ, individuals’ intent on making a name for themselves with a grand plan. The CEO has only recently joined the MCA so these plans are clearly not of his making, but he has thrown his full weight behind it and declares it to be the best option. As an experienced Coastguard Officer I am concerned that Sir Alan is being ill advised by senior managers and is now clearly ignoring the concerns that are being expressed by operational Officers from all around the coast. Is it reasonable to claim that Coastguard Officers from all around the UK with 10, 15, 20 years of operational experience are all wrong, and the views of a handful of Senior Managers who actually have limited operational experience are right? This proposal is not a “good idea, whose time has come”; rather it is the “idea of one man, who thinks his time has come”. The consultation document has been circulated only to cater for the statutory requirement to consult, there is no intention to change this proposal significantly. The document also lists what questions we should ask. I would rather ask questions which I deemed appropriate and would require answers to, rather than questions that they would like to us to ask.

2. Modernisation The Transport Minister Mike Penning writes in the forward that HMCG is in need of urgent modernisation and that the service was last reviewed 40 years ago. This is not true and is patently designed to give the impression that HMCG is archaic and is seriously out of date. The service underwent a major review in the mid 1990’s under the Focus for Change, which was heralded then as “the most detailed and thorough review undertaken into the structures, workloads and running of the coastguard service for decades.” Clearly this has been ignored as it does not suit the drive to portray the service as out of date. HMCG has also been subject to continuous technical improvements to advance and upgrade all our I.T. systems since then. It is not out of date and it works. All Coastguard Ofﬁcers recognise that modernisation is part of the natural development of the type of work that we carry out, and we are not averse to change—but we will object to changes that will endanger the lives of the maritime community and coastal users.

3. Resilience Much is made in the document of requirement for “national resilience”. What has gone wrong with the current arrangement of paired stations, which support each other? Has there been a failure which has affected both stations in a particular pair? The answer is no—there has been no such failure and according to my technical colleagues they cannot envisage a situation where such an event could occur. A request under the FOI Act confirms that no such failure has occurred. So why has the resilience been called into question when there is no evidence to support such a claim? MRCC Falmouth suffered such a catastrophic a failure as could be imagined when the station was struck by lightning and was out of service for a period. However, our flank station was able to take up some services and contingency plans were put in place to enable as near normal service to be maintained. It worked and was resilient. To run the whole of the UK from a central location, which will be subject to exactly the same risk levels of encountering a major failure, is not fulfilling the requirement for national resilience, it is in fact exactly the opposite. A major failure would have national consequences and would be far harder to rectify. True national resilience would be to spread the risk and minimise to impact should a failure occur. To use national resilience as an argument to support these proposals is misleading and not correct. Refer to the failed Fire Service proposals.

4. MOC Trials For a proposal to set up a MOC, it is reasonable to assume that an extensive trial would have been set up to mimic a MOC to establish what the expected workload would be and how it could be managed. As I understand it the only trial that took place was a tabletop exercise in London in May 2010, with a handful of invited staff who “walked through” the scenario and analysed incident data. Well I’m afraid that this does not constitute a valid trial of such an important proposal. At the very least it should shadow the workload of multiple MRCC’s on a busy July day, monitoring incidents and all other routine working to actually see how cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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and if it can be done. Simply using the phrase “refreshed technology and improved systems” provides no evidence and guarantee of success, but invites failure. If a trial was conducted I recommend that your committee asks to see the evidence and results of that trial. You will also ﬁnd that there were no experienced Coastguard Ofﬁcers at that trial.

5. New Technology Throughout this document much emphasis is placed on “new or refreshed technology”. It has been conﬁrmed that technology will be that which we use now, but “refreshed”. What this actually means is not clear. Technology has a habit of promising much and failing to deliver, look at the debacle that befell the Fire Service proposals. Technology also has a habit of haemorrhaging money. You will note that there are no hard ﬁgures published as to what this proposal will actually coast, but history shows that this project will certainly overrun and will be massively over budget. Again, take a look at the Fire Service proposals.

6. Alternative proposals This document provides, nor requests any alternative proposals other than that which is set out in the plan. It is reasonable to explore alternative proposals and weigh them up against each other. Why has this not been done? Has it been done? If it has been done why have we not been told? I have an alternative proposal which addresses a lot of the issues that the current proposal claims to resolve and has been submitted to your committee separately, briefly outlined below; Amalgamate the current paired stations into one larger MRCC, increasing the area of responsibility and its overall workload. This would reduce the total number of MRCC’s around the coast whilst maintaining full national coverage and local expertise. Each of these bigger MRCC’s would then be linked up to provide the resilience that is required, without the risk of a national failure. The costs would be significantly reduced, both in terms of estates and manpower. The total number of MRCC’s would reduce to about half (nine) and most of the reduced manning would be serviced through natural wastage. Relocation costs would be minimal, enhanced roles for staff could still be introduced. Most importantly the risk of moving towards a centralised MOC, with no proper trial and no proven technology would be significantly reduced. The cost of this alternative would also prove to be far cheaper and easier to manage. This proposal has been put to the CEO and is dismissed as too expensive. A very quick answer with no actual substance or consideration. You can be sure that it will be less expensive than the plan which is proposed, but has the support of the Officers around the coast and carries much less risk.

7. The Fire Service Example It has recently been announced that the proposed plan to remove some 46 fire control centres and open nine regional control centres has been scrapped because the promised I.T. solutions could not be delivered, they could not make it work. So far this has cost over £420 million and is still rising. The initial aim was to provide, quote “improved national resilience, interoperability and efficiency as well as to enhance the technology to the Fire Service.” This could not be achieved and the alternative plans are to be based on “the principles of localism, ensuring public safety and building up national resilience”. This all quoted by the Fire Minister Bob Neil. The present Minister, Mike Penning when in opposition in 2005 was a strong opponent of the Fire Service centralisation and is quoted then as saying he was “desperately concerned for my constituents’ safety, as well as the safety of constituents elsewhere in the country. The fact that local fire control centres know the topography and understand the ground keeps our country safe. Moving the centres to regions will put lives at risk.” Why does he not show the same degree of concern of the users of our coasts? The proposals for HMCG go entirely opposite to the above. The promised I.T. did not materialise. The approach to national resilience has changed to provide a greater spread of risk—local failures are just that, local, they do not affect national resilience. The term localism has been bandied about by this Government. Localism cannot be associated with the proposals for a centralised Coastguard Service. The Government needs to compare the debacle that was the review of the Fire Service control rooms with what is proposed for HMCG. They took over four years and more the £420 million and could not make it work. It is not difficult to draw a parity, and the conclusions should be the same—scrap the idea. Obviously attempts will be made to distance the two projects as any comparison would condemn the Coastguard project to failure. But comparisons are clear and obvious, and should be pursued by the Select Committee. The MCA will argue that the main obstacle to the Fire Service proposal was the fact that they all had different systems. Well the Fire Service Control rooms use Vision—the same incident management system used by HM Coastguard.

8. MRCC Falmouth Operating in Daylight Hours Only The proposal includes the concept of MRCC Falmouth operating in daylight hours only, with a reduced staff of 10. How this is to work has not been explained, what is meant by daylight hours is not deﬁned. What is clear is that the full role that has been played by MRCC Falmouth has not been fully considered. Since the cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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concept of GMDSS was introduced MRCC Falmouth has played a pivotal role in international search and rescue, for which we have built up a well respected reputation for excellence spanning some 30 years. Falmouth carries out similar search and rescue work to other Coastguard stations in the UK, but we also fulfil many other vital roles which are unique to Falmouth. Satellite distress communications, COSPAS/SARSAT beacon alerts, SSAS, NAVTEX, MOB Guardian alerts. Falmouth is the UK Single Point of Contact (SPOC) for other international rescue centres, and is well known for providing a first class service to our international colleagues. The vast majority of merchant vessels have the contact details for Falmouth logged into their communications equipment because they know the level of service we provide is tried and tested and can be relied upon. International marine colleges advise all course delegates to have MRCC Falmouth as their default communications setting and include this information in their syllabus. The ocean going yachting community know they can rely on MRCC Falmouth should they fall into difficulties. This has been built up over 30 years by the dedication and experience of the staff at MRCC Falmouth. We did not invent GMDSS, but Falmouth played a significant role in making it work and assisting when it was upgraded or modified. Falmouth took on the role of dealing Ship Security Alerts when it was introduced and invested considerable time and effort to refine the procedures. The UK NAVTEX system is managed by Falmouth and again considerable effort was put in to make it work properly. Our role in international SAR is well documented, it is well known that we regularly deal with incidents that are outside the UK area of responsibility. We do this because the experience that we have built up over the years tells us which areas of the globe are likely to require our services and which do not. To reduce MRCC Falmouth to daylight working is ridiculous. We are patently a 24 hour operation, the list of night time work is huge. To reduce the Operations staff at Falmouth to 10 is ill conceived. The international work will not go away, the area we cover will not reduce, the amount of merchant vessels calling for assistance and advice will increase. What will be lost is the experience of the Officers at Falmouth. That cannot be trained or simply passed to on to another centre. It will go wrong and will severely affect the standing and respect of HM Coastguard throughout the world. Falmouth is known as the UK MRCC for a reason, because it is. Some criticise MRCC Falmouth as elitist. Well I am happy to accept that, no other MRCC does the work that Falmouth carries out. The Officers at Falmouth are proud of this work and are happy to be labelled elitist.

9. Local Knowledge A significant criticism of the proposal is the concern that vital local knowledge will be lost if all operations are centralised. This is being echoed all around the coast by very experienced Officers. It was very disappointing that the Chief Coastguard at a meeting in Holyhead dismissed this part of our skills base as “not essential for us to carry out our work”, stating that technology can make up for this loss. This was patently not true and sparked a huge furore around the Coast. It is interesting that those promoting the proposal now acknowledge that this knowledge is important and are making attempts to outline how Officers in the new MOC will require a level of local knowledge, but for a huge area. Coastguard Officers around the coast are required to know their area and are examined every two years to ensure that they do. It is laid down in our operational manuals (CG3) and remains therein. We do not profess to know every rock and gully, but we do know every port, harbour, beach, headland, cliff, marina, light, danger area and local service or authority. Sir Alan states that local knowledge will be provided by volunteers from the Coastguard rescue service, RNLI and National Coastwatch Institute. Again this is misleading, they can provide local knowledge once an incident has been commenced, but the vital time for local knowledge is when the call is received. This responsibility lies with the Officer running the incident and is needed immediately. Serving Officers do this now and do it well, because of the knowledge we have built up over many years. We do use technology to assist us if required, but it is only to assist, it is not the prime method of defining the location of an incident. To dismiss this knowledge as “not essential” shows little respect or appreciation of the work carried out by Coastguard Officers and only highlights the limitations of the advice given to Sir Alan Massey by his senior managers. If you add incidents from around the Welsh coast the problem is magnified.

Manning Levels One of the drivers for the proposal is the fact that some stations have quite periods and do not conduct as many incidents as others. What is not considered is the plain fact that as an emergency service we are a reactive service—there is no getting away from that, it is the nature of the business we are in, we can only react to emergency situations as they occur. To simply reduce the numbers in the MOC to reflect historical statistics so that all hands are “employed” will invite an inevitable risk of the staff being very quickly overwhelmed. To have the South MOC manned by twenty or so staff will be dangerous. This proposal has serious flaws and should be stopped. It is the brainchild of a select group of individuals who are intent on making their mark on the service, no matter what the consequence. The operational experience of the authors is limited, and the testing of this proposal is minimal. This proposal puts at risk the reputation of HM Coastguard both domestically and internationally. It also increases the risk to those who operate in the UK search and rescue region, on and around our coasts. Sir Alan Massey has been the head of the MCA for less than a year and not the author of this document. I would hope that during his visits around the coast to speak with operations staff he has been getting the message that most if not all operational Officers disagree with the proposal. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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I trust that the Transport Select Committee will examine this proposal in detail and take note of all the concerns that will no doubt be put before you by experienced Coastguard Ofﬁcers prior to the hearing. March 2011

Written evidence from Bob Skinley (MCA 36) Summary of Main Points — The consultation process itself is ﬂawed and is not a serious attempt to consult. — The MCA has “previous form” in ignoring consultation. — The proposals made in the consultation document are seriously ﬂawed and may lead to deaths around the UK coastline. — Many of the assertions made in the consultation document are either based on false assumptions or are simply untrue or little or no evidence has been supplied in order that a proper considered judgement of the proposals may be made. — The MCA should be required to revisit and re-evaluate the entire process, come up with credible evidence to support their conclusions, present alternatives to what they propose, again with supporting evidence so that a reasoned judgement on the best way forward can be made, and made to engage seriously in consultation with the results being independently scrutinised.

The Author of this Evidence I am a serving Coastguard Watch Officer of over five years operational coastguard experience at Shetland Maritime Rescue Co-ordination Centre (MRCC). During this time I have been involved in some serious maritime Search and Rescue incidents, such as the capsize of the anchor handling tug “Bourbon Dolphin” west of Shetland. I also have other emergency service experience having been a Police Officer with Grampian Police for two years prior to serving as an RAF Policeman for over five years and then as a Special Constable with Northern Constabulary for a further three years.

The Evidence Introduction The MCA has presented a consultation document entitled “HM Coastguard Proposals for Modernisation 2010”. This document outlines the MCA’s proposals for the future of the Coastguard service. These proposals include the reduction of the Coastguard service from its current configuration of 19 MRCC (Maritime Rescue Co-ordination Centres) to just two MOC (Maritime Operations Centres) and five, “daytime only” Maritime Rescue Sub-Centres. It is my firmly held belief as an operational coastguard, that these proposals will result in an alarming loss of “local knowledge” about our coastline and a consequent increase in lives being lost as a result. There will be less resilience, not more. There is a very high likelihood that this project will go the way of previous similar public sector projects, such as the recently cancelled FiReControl Project (which was very similar) at enormous cost to the taxpayer, which, in these economic times, is an alarming prospect.

The Consultation Process The whole consultation process appears, on the face of it, to be very little to do with consultation at all. It is a very restrictive document, designed to elicit the response the MCA wants to hear. The only accepted form of response appears to be the online questionnaire, which in itself is a limiting factor as it excludes those who do not have internet access or who are not computer literate. The questions in the response form are, and this appears to be deliberate, “closed” ie they do not in themselves seek any discussion of what has been proposed and present no other alternatives. Rather, they merely seek additional information or recommendations to what is already proposed, presenting this as a “fait accompli” which hardly meets my deﬁnition of “consultation”. If I may use Question 1 from the response form as an example, it asks: “We have set out the changes that would affect the way the Coastguard needs to operate. Are there any other changes and pressures that should be taken into account in our plans for a modernised Coastguard service? Please provide supporting evidence for your comments.” Furthermore, you will note that whilst the majority of the questions in the response form demand evidence/reasons for the response whilst the MCA themselves provide very little or none at all to back up their assertions, which is somewhat one sided. Indeed the MCA (previously the Coastguard Agency) has a track record of this sort of behaviour. In a previous consultation exercise in January 1998 regarding the proposals contained in the document “Five Year Strategy For HM Coastguard” they stood accused of similar dubious practices. In their Sixth Report of Session 1998–99, the then Select Committee on Environment, Transport and Regional Affairs said of the consultation process: “The consultation document offered no alternative proposals about which the views of staff and other interested parties might have been sought: rather it sought only to justify the decisions already made and announced. The data provided by the document was insufﬁcient even for that purpose, since information cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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was provided only about the four stations planned to be closed, and the two to be co-located, rather than all maritime rescue co-ordination stations, thus failing to supply the comparative data which might explain why the stations had been selected.” History repeating itself. The MCA has attempted the same strategy again in an effort to bulldoze through their proposals in complete defiance of what the Honourable Members of the Committee said in 1998. The Select Committee further stated: “The document eventually issued by the Agency appeared to seek only to justify decisions already taken rather than genuinely to canvass the views of interested parties about the Strategy.” Quite so. This is not the only flaw in the current consultation process and similarity between it and the 1998 process. In 1998 the Select Committee found that the consultation process was done in bad faith and that at the end of it, the responses were ignored, they said: “The suspicion that consultation about the Five Year Strategy was simply ‘a PR exercise’ was reinforced by its outcome. Although some aspects of the Five Year Strategy, such as the introduction of new technology, were supported by respondents to the consultation exercise, the closures and co-location of stations were condemned. 84% of those who expressed a view about the closure of Pentland maritime rescue co-ordination centre were against it: the equivalent figure for Tyne Tees was 71%, for Liverpool 88%, and for Oban 79%. The co-location of Portland and Solent was supported by only 8% of those who addressed the matter, and opposed by 56%. Overall, 86% of respondents expressed an opinion about the implementation of the Five Year Strategy, and 66% of them were opposed. Nevertheless, on 31 July 1998 it was announced that the Strategy would be ‘taken forward as proposed’. The only change as a result of the consultation exercise was slight: Oban and Pentland would now be closed in autumn 2000, Tyne Tees and Liverpool in autumn 2001, and Portland and Solent would be co-located in autumn 2003. The delay in closing the stations corresponded exactly to the additional time taken up by the consultation exercise.” and they concluded: “Finally, the Agency in any event apparently ignored those who responded to the consultation document, deciding in the face of overwhelming opposition to the Strategy not to alter it in any way. Thus there has been no serious attempt by the Coastguard Agency, and latterly the MCA, to engage in consultation about the Five Year Strategy. There should have been.” Everything points to this current process going in the same direction and on that basis it should be halted and the MCA forced to take away their proposals, rethink them and then engage in consultation in a serious, meaningful manner ie by having the results of the consultation process independently scrutinised.

Rationale behind the proposals and why they are wrong In his foreword to the proposals on Page 3 of the consultation document, Shipping Minister Mike Penning stated: “like many in the industry, I also recognise that the Coastguard needs urgent modernisation to keep pace with changing demands, changing technologies, and our changing economy.” Nowhere in the document is any evidence presented as to why this modernisation is so “urgent” or indeed that it requires the wholesale dismemberment of HM Coastguard as currently configured. There is no evidence provided that HM Coastguard as it is currently configured is unable to cope with the demands placed upon it. Even if that were the case, no alternatives are posited to alleviate such a problem, the proposals are presented as “the only show in town”. My experience of HM Coastguard is that it is a constantly evolving, changing, modernising organisation. New equipment and procedures are frequently being implemented and adopted. Indeed, the current MCA Chief Executive, Vice Adm Sir Alan Massey, in his foreword to the consultation document stated on Page 5: “The proud history of the Coastguard over the past two centuries has seen regular change and modernisation.” Indeed, although this is somewhat at odds with the previous statement by the Minister and this, as I will show, is the first of many contradictory statements made in the document. So whilst not disputing that there is always a need to strive to do things better in a more efficient way, what makes this particular modernisation programme so “urgent”, above and beyond what already takes place? The consultation document has provided no evidence to back up this assertion. The Shipping Minister continues: “But much of the computer and radio technology that was cutting edge a few years ago is now outdated, and there is huge potential to improve the service and make it more efficient. This gives us a real opportunity to modernise the service that was last reviewed in the mid-1970s. So that is why we are launching this consultation.” Firstly, the statement that the service was “last reviewed in the mid-1970s” is factually untrue. The service has been reviewed numerous times since the mid 1970s. In 1994 we had “Focus For Change” which was cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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described by the then Coastguard Agency as “the most detailed and thorough review undertaken into the structures, workloads and running of the Coastguard Service for decades”. This was followed on 17 November 1997 by the “Five Year Strategy for HM Coastguard” which sought to improve the “effectiveness and efficiency of an already highly proficient Coastguard Service” and which proposed the closure of four Coastguard stations at Oban, Pentland, Tyne Tees and Liverpool and the merger of those at Portland & Solent. So clearly, to state that the “service was last reviewed in the mid 1970s” is factually wrong and misleading. Secondly, with respect to modernisation, a great deal of the technology we have in Operations Rooms around the coast is being constantly modernised and upgraded. AIS (Automatic Identification System) for example, has recently been configured to allow the overlay of search plans derived by our search planning software SARIS, onto the AIS map, effectively combining the two systems in an integrated approach to search planning. Our Incident Management Software known as “Vision”, is currently in the process of being upgraded (indeed a team is conducting the roll-out of this and associated training at the present time). The Medium Frequency radio equipment in certain MRCC is also in the process of being replaced and modernised, with the MF equipment now being fully integrated into ICCS (the Integrated Coastguard Communications System) and a planned replacement programme of all Operations Room PCs (computers) is also in hand. So again, to imply that the Coastguard service is clapped-out, out of date and in need of “urgent” modernisation is somewhat fanciful and far-fetched and takes no account of all the recent and ongoing modernisation work already going on around the coast. Rather, this looks like a deliberate attempt to suggest otherwise to mislead the public into arriving at the same conclusion as is proposed. The Shipping Minister also argues that the proposals will have: “flexibility to allow for fewer staff having to work at night when there is often little to do.” This statement bears closer scrutiny. Firstly it is based on an assumption that there are fewer incidents at night than during daylight hours. This is misleading. Whilst this may be the case on the south coast of England it is certainly not true of the majority of Scotland. Using my own station, Shetland MRCC, as an example, our incident profile essentially “flatlines”. What this means is that incidents are evenly spaced between whether they happen during the day or night, whether they happen Spring, Summer, Autumn or Winter and that the severity of incidents has little to do with either of these factors. This whole assertion is based on the “peak demand” fallacy, where it is believed, through an incorrect use of statistics, that such a “peak demand”, which may well exist on one part of the coast, can then be extrapolated for the whole of the United Kingdom and used as basis of station opening times and indeed watch manning levels. This is a disingenuous, and indeed a potentially dangerous misuse of statistical data. Secondly, it implies that under the current configuration, there are dozens of Coastguards around the coast sitting idly twiddling their thumbs with “little to do”. This is both factually wrong and an insult to the professionalism and integrity of myself and my colleagues. In any case, even if it were true, it misses the whole raison d’etre of the Coastguard service as a front-line, reactive, emergency service, but then, that is something that the MCA has completely lost sight of at the very top of the organisation for a long time now. The MCA has become very “corporate” in its outlook, something that has no real place in an emergency service. I am quite sure that the same accusation could be made of our emergency service colleagues in the Fire and Rescue Service or the Ambulance Service. Even if it were true, I see no demand for Fire Stations to be closed or the number of Ambulance Stations to be slashed in order to make them “more efficient” the public simply would not tolerate such nonsense since they recognise that we are there “in case something happens” an insurance policy against disaster which none should put a price on. It also fails to acknowledge the sheer volume of “routine” work that goes on in an Operational Coastguard station, whether that be the regular weather broadcasts (every three hours), Vessel Traffic Monitoring, (the Dover Strait is not the only busy stretch of water around the UK which requires vessels to report in to the Coastguard, indeed there are several around the coast of the UK). Again using Shetland MRCC as an example, we monitor the Fair Isle Channel, which is a busy route between the oil installations of the Norwegian sector, such as the Mongstad Oil terminal, and the USA/Canada. In 2010 some 935 vessels, representing over 30.5 million GRT, reported in to Shetland Coastguard during their passage through this channel, a substantial number. This, however, only represents those vessels who actually report in, since this reporting area is “advisory” not “compulsory” so there are a substantial number of vessels passing through this channel who do not report in. It also fails to acknowledge the sheer volume of studying and ongoing professional development that is required of a Coastguard Officer. In my just over five years experience in the Coastguard I can think of very few occasions when I have not been either studying for the huge raft of exams that have to be taken, especially at Watch Officer level, or carrying out self-study or participating in exercises in order to maintain the extremely high level of knowledge that an operational coastguard is required to have in order to just do their job. Then, as a Watch Officer, as well as my own training I am expected to mentor other members of staff who are undergoing training, supervising what they do, teaching them how things are done and actively participating in all aspects of their training. This is just a small handful of the duties we are required to perform so to suggest that somehow we are sitting around with “little to do” is again misleading and does not represent the facts. Also, if it were true, then surely the most obvious solution (and far less costly) would be to revisit current risk-assessments as to what the current manning levels at current stations should be in order to provide the best service, but again the MCA have failed to come up with a single alternative strategy. The MCA is using this misrepresentation as justification for closing stations, reducing watch levels, station opening times and overall manning levels and is simply not to be trusted as a sound basis on which to do so. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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The Shipping Minister also justiﬁes the proposals by stating: “The UK has more than 10,500 miles of coastline that is enjoyed by 200 million visitors a year. Our industries, shops and services depend on ships for 95% of visible trade by weight, and the shipping industry contributes about £1 million every hour to our economy.”

They cannot even get a simple fact like this correct! According to the British Cartographic Society, the length of the UK coastline, including all the major island groups comes to 19,491 miles (source British Cartographic Society using Ordnance Survey Data based on the “Mean High Water Springs” measurement using GIS software). Therefore, the Minister has made a frighteningly substantial error of fact by some 8,961 miles! One has to wonder of the rest of this document rests on such ﬂimsy data.

In the Executive Summary on Page 7, it is stated that: “we are changing the way we use our waters and our shores. This is making our coastline far busier than ever before. We are building much larger ships that are less manoeuvrable and drilling rigs and increasing numbers of wind farms pepper the seas around the UK. As a result our seas are becoming much more congested. Weather conditions are also becoming more extreme, with signiﬁcant weather events becoming more frequent and severe, making work at sea more perilous and increasing the risk of coastal ﬂooding.”

If we accept that the above is true, then how is it sensible or logical to cut the number of Coastguard Stations around the UK coastline? Surely logic dictates that an increase in a particular circumstance requires an increase in resources to deal with it, for example it has often been said that in order to deal with rising crime rates we need more “police officers on the beat”. If it were proposed that with an increasing number of fires we slash the number of fire stations or that with the increasing number of crimes we slash the number of police officers, would those proposals seem sensible and indeed would the public tolerate them? I doubt it very much. The document also proposes increased investment in the Coast Rescue Service, our volunteers around the coast. Again, if it were proposed that to tackle an increase in fires, we would slash the number of full-time, professional Firemen and rely more on retained firemen or with increasing crime rates we slash the number of full-time professional police officers and instead rely on Special Constables, would that be an acceptable way to deal with problem? I venture to suggest it would not. Like our brethren in the Fire And Rescue Service, the Police or the Ambulance Service, HM Coastguard is a front-line, reactive, emergency service just like they are and we should not be over-relying on our volunteers at the expense of full-time professional officers. The MCA may have forgotten our emergency service ethos, we should not.

The Executive Summary continues: “The current arrangement of the Coastguard dates back 40 years and is not well placed to respond to these challenges.”

As already outlined in my submission and confirmed by the statement of the Chief Executive in his foreword, to suggest that the Coastguard has effectively stood still and not been reorganised or reconfigured over the pasty 40 years is patently false. This is a misleading statement that is often repeated throughout this document which does not stand up to any basic level of scrutiny. It appears to be a somewhat disreputable attempt to convince a public, unaware of the ongoing modernisation of the Coastguard over a number of years, that sudden, “urgent”, drastic reorganisation and modernisation is required or desirable, before some sort of unspecified disaster overtakes us.

The current configuration of the Coastguard works well. That is not to say it could not withstand some improvements, however, that does not necessarily mean the complete decimation of the Coastguard as we know it, as this document proposes. Furthermore, this whole process is fundamentally flawed as it only proposes one possible view of how the Coastguard could be reconfigured or modernised to the exclusion of all others. One cannot escape the conclusion that this is being driven not by necessity but perhaps by personal agendas. Again, in putting all their eggs in one basket, the MCA is culpable of repeating the mistakes of recent history. The Select Committee on Environment, Transport and Regional Affairs observed in its report in 1998 that: “In a letter sent in February 1998 to the then Chief Executive of the Coastguard Agency, the Scottish Fishermen’s Federation claimed that ‘it is obvious on examining the [consultation] paper that the Coastguard Agency is not, in any case, engaging in meaningful consultation with users of the service. The Agency is at best consulting upon how to implement its closure plans rather than on addressing the more fundamental question of whether closure of the stations is justified in the first instance’. We are inclined to agree. The consultation document offered no alternative proposals about which the views of staff and other interested parties might have been sought: rather it sought only to justify the decisions already made and announced.”

The Executive Summary further states: “Each centre’s systems are ‘paired’ with a neighbour allowing them to work together when necessary, but beyond these pairings the stations are not interoperable.” cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Again, this is a misleading statement, since it does not give the whole picture. Each station, paired or not, has the facility to operate another stations communications through the ICCS system, as if an operator were seated at a desk in the remote station. By the simple expedient of “remoting in” from one ICCS terminal in one station to a free ICCS terminal in another station, remote control can be taken of another stations aerials, telephones etc. This applies nationwide. For example, I could effectively dial into ICCS from Shetland and remotely operate another ICCS terminal in, say, Falmouth. The current “pairing” arrangement has worked very well and has already been used successfully “in anger” so to speak. On 27 December 2005, a fire forced the evacuation of Swansea MRCC and all operations were transferred to Milford Haven MRCC for a number of days whilst repairs were carried out at Swansea. The system works and there is no loss in resilience. That is not to say improvements could not be made, but do improvements necessarily mean the sweeping changes currently being proposed? It is difficult to discern because, as previously pointed out, no alternatives have been submitted for examination. By its very nature, a system of 19 geographically dispersed MRCC is in itself “resilient” in that it is proof against catastrophic failure. Since all of our current MRCC can, if the need arises, operate completely autonomously and carry out all the usual functions they normally would, then this is patently a resilient operation. One of the major problems confronting Civil Contingency planners in this day and age is the possibility of a major disease pandemic, such as one involving one of the various strains of influenza. In such circumstances, does it really make sense to concentrate as many staff (and indeed their germs!) and functions into two, centralised locations (MOC’s) and five Sub-Centres who, could not in themselves cope with a major emergency on such a scale. Even at a basic staffing level, an MRSC with its complement of 10 staff could not hope to cope in such circumstances, should they be required to cover enormous stretches of the UK coast because an MOC was unable to. Whereas, the current set-up, with their much larger staff pool, their clearly defined areas of operation and their ability to take over the functions of a neighbouring station potentially could. It is perfectly possible that given a little work on the communications and IT infrastructure, the current set-up could cope perfectly well with such a scenario and at much less cost but again it is hard to make a rational, evidence based judgement, since no evidence is presented or alternative solutions proposed. The Executive Summary states further: “This means that the system suffers from a fundamental lack of resilience. In the event of a problem affecting both centres in a pair, it is not possible for an incident to be managed from another centre.” What evidence is there that indicates the likelihood of such a scenario, that two neighbouring MRCC would completely lose all systems and be unable to function? None is presented, so I cannot accept that as a fact. What I can present as a fact is that in the five years or so that I have been an operational coastguard there has been not one occasion were such a scenario was realised. Furthermore, it is a purely imaginary “what if” flight of fancy of which a great many could be concocted, but would that necessarily mean that the answer to any of those would be the complete dismemberment of the Coastguard as we know it? Again one cannot make a sound judgement due to the complete absence of any supporting evidence or alternative proposals, which could potentially have a much lower cost implication. It also states: “It is also impossible to spread workloads across the system; so staff in one centre may be struggling to cope with call volumes while workloads in another may be low.” This is another factual inaccuracy that is not supported by evidence. At present, it is perfectly possible to spread the workload across the system. For example, stations have and do, on a regular basis around the coast, delegate work to their flank (ie next door in either direction) stations. In this way a station which is heavily involved in, say, a demanding SAR (Search and Rescue) operation can ask a flank station to take over some of its routine duties such as weather broadcasts or Vessel Traffic Monitoring (VTM) duties. Or an another example being that of when a station is operating on reduced manpower due to sickness etc, it can request flanks to be prepared to carry out search planning duties should the need arise. All perfectly reasonable and resilient. To suggest that uneven workloads cannot at present be spread more evenly is risible. The Executive Summary continues: “In addition both emergency and non-emergency demand varies widely by geographical location, the time of day, and the time of year. Analysis shows that the busiest centres handle over five times as many incidents as the quietest with 30% of all incidents happening in July and August and 70% of all incidents occurring between 9am and 7pm.” If it is true that demand varies widely by location, and I accept that it is, then conversely it cannot be true that there is an identifiable “peak demand” period that applies to the entire UK coastline as the consultation paper suggests, you cannot have your cake AND eat it as the saying goes. This so-called period of “peak- demand” is given as one of the reasons for the five Sub-Centres being open only during daytime hours. As stated on Page 20 of the consultation document: “sub-centres would be staffed only during ‘daylight hours’, when activity levels are much higher than at night.” As previously noted, this may well be the case along the south coast of England but it does not apply to other areas such as Scotland, therefore any rationale for having cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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any stations in Scotland which were not under 24 hour operation simply does not exist on any evidential basis. It may be the case that peak loads at certain stations could be alleviated by having extra staff available at peak times and/or changing the shift pattern/working practices to overcome what are, short-term difficulties during, say, the summer season. Again, a sound, evidence based decision on what would be the most appropriate solution cannot be readily identified, since no alternatives are proposed. It also states: “These uneven workloads lessen resilience, hamper staff development and lead to higher than necessary staff costs.” These are completely unsubstantiated arguments without a shred of evidential basis. Firstly, in what way does an uneven workload reduce resilience? Is there any evidence at all that shows that any Coastguard station under the current configuration was at any time unable to function because of these “uneven workloads?” None is provided and in my experience it has never happened. As previously stated, there are alternative methods of dealing with this scenario such as delegating tasks to a less-busy flank station, or looking more closely at staff distribution and work/shift practices. To present this as the only way of dealing with this matter is patently ridiculous. Secondly, it has always been the case that HM Coastguard has offered ample opportunities to progress. There are many examples of staff who have started at or served at comparatively “quiet” Coastguard stations who have gone on to reach the very highest levels of the MCA. Geographical location or station activity level has never, in my experience, been an impediment to career progression, nor should it ever be. If this is an admission by the MCA that it has, then that is to be roundly condemned and is symptomatic, not of a failed Coastguard station structure, but of a failed career progression process and an “anti-small station” bias in the MCA which should be addressed by better Human Resources management processes and not used as a flippant excuse for closing Coastguard stations. Thirdly, How does uneven workloads between stations produce the “higher than necessary” staff costs? Regardless of where a Coastguard is located we are all paid the same pay scale. How does it logically follow that the end product of uneven workloads between two geographically distant Coastguard stations mean increased staff costs, where is the evidence for this? If they are suggesting that increased costs are down to factors such as overtime and TOIL (Time Off In Lieu) then this argument simply does not hold water. Overtime, TOIL etc are a fact of life for an employer, particularly one which deals with the safety of life and whose manning levels are dictated by a risk assessment that it is necessary to have a particular number of staff on watch at any time to provide the necessary numbers and expertise levels. Irrespective of where staff are based, be that under the current configuration or that which is proposed, this will essentially not change. There will always be a requirement to have certain minimum staffing levels on watch at any one time and there will always be unexpected, extraneous factors which result in overtime and TOIL being necessary, such as outbreaks of illness (and I’m not necessarily talking about pandemics here either, it could simply be a vigorous outbreak of the common cold for example) or a major incident. If it is the case at present that levels of overtime etc are inordinately high, then this could potentially be down to one thing, the complete lack of the ability of the MCA to recruit and retain staff due to the appallingly low pay levels, something that this document fails to even recognise.

Loss of Local Knowledge Throughout the document, the MCA refuses to acknowledge the importance of Local Knowledge, or where it does, it suggests that this can all be obtained from resources such as the Coast Rescue Service or the RNLI. I disagree. Local Knowledge in the Operations Room is fundamental to what we do and having a good local knowledge of your “patch” reduces response times both in terms of the amount of time needed to be spent on initial information gathering and in subsequent allocation and tasking of resources. To say that local knowledge is unimportant in the Operations Room is to fundamentally misunderstand what a Coastguard Operations Room does. The Operations Room is not a “call centre” where emergency calls are merely taken and the a unit dispatched to deal with that emergency. A lot more substantial work goes on in a Coastguard Ops Room. You cannot have a “call centre” mentality in the Coastguard like you do in other emergency services, why? Because of one, fundamentally important difference—our casualties are not stationary, they drift. So because of this we have to take a whole raft of other information into account and we have to make decisions other than just dispatching a unit. First and foremost, we co-ordinate. No other emergency service can do what we do, as effectively as we do. No other emergency service is as good at co-ordinating multiple search and rescue units with differing characteristics and abilities and be able to also incorporate into that all the other emergency services as well. No other emergency service has to do search planning of the scale and complexity we do. The MCA have tried to insist that local knowledge does not have to reside in the Operations Room, that it resides with the Coastguard teams etc and with the “power of our technology” as Sir Alan Massey stated in his foreword, and better questioning they would have all the local knowledge they needed. Frankly, on that basis then, there is absolutely no reason why a MOC could not be sited in Mumbai, at a huge cost saving to the taxpayer, other than that is a completely ridiculous suggestion, but then so is the idea that Operations Rooms require no local knowledge. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Furthermore, the management argument that local knowledge in the Operations Room setting is not important, is completely at odds with the training regime for Operations Room Coastguard Officers and the published operating procedures as contained in CG3, essentially the Coastguard “Bible” which contains all of our principles and procedures. CG3 contains page after page detailing the importance of local knowledge in the operations room. Indeed it specifies at length the depth of knowledge required and also lays out how that knowledge should be tested. As serving Coastguard Operations Room officers, we are required to be examined in our local knowledge every two years. This examination is comprehensive, indeed CG3 has pages of suggested questions for such examinations. Furthermore, when embarking on either CWA (Watch Assistant) or Watch Officer Training, an up to date local knowledge certificate is required in order to pass the training course. If local knowledge is so insignificant in the Operations Room setting then why go to these lengths to ensure that local knowledge in the Operations Room is thorough, comprehensive and up to date? Something in their argument does not add up. It is fairly clear to me that this disliking for the importance of local knowledge is that if local knowledge is so important, it puts it completely at odds with what the management is proposing to do with HM Coastguard, it is an inconvenience that needs to be explained away, dismissed as a minor issue, when in fact it is absolutely crucial to what HM Coastguard does. There is a “corporate” mind set in MCA Senior Management, a “Call Centre” mentality, which has no place in a front-line emergency service.

The MCA tried to make this argument previously in 1998 and the Select Committee was having none of it. Their report said: “The most common concern about the closure programme, however, was that it would lead to a diminution of the local knowledge of Coastguard Watch Officers. Over time, Watch Officers build up knowledge of local tides and currents, unusual weather conditions, rescue resources, colloquial place names, the coastline, and locally-based seafarers and their vessels. That knowledge, we were told, is invaluable to Watch Officers in deciding what resources to deploy, and particularly where they should be sent. We were told that ‘the more you hone down the area of search, the quicker it is [to find those in difficulty]; the quicker it is, the more chance you have of saving a life’. Local knowledge has a vital role to play in enabling the Watch Officer quickly to ‘hone down’ the area to be searched. The PCS Union said that ‘the need for a Coastguard officer to have a detailed local knowledge of his or her guard is paramount. This knowledge saves lives’. It was feared, however, that the closure programme, by requiring the remaining stations to be responsible for lengthier stretches of coastline, and larger areas of sea, would undermine the quality of the local knowledge of Coastguards. As the Royal Yachting Association put it, ‘there is considerable concern about lack of local knowledge when rescue centres are up to 200 miles apart’.”

We were given many examples of the role of local knowledge. Mr Watt, from the PCS Union, said that increasingly emergency calls are made by infrequent visitors to the coast, whose location might only be quickly identified by a Watch Officer with appropriate local knowledge. The Scottish Fishermen’s Federation gave details of a case in which a canoeist went adrift off north west Scotland, and it was only because of a local Oban Coastguard’s knowledge of the “very strange tidal configurations off the west of Scotland ... that the helicopter went in darkness to [the correct] point, and they plucked him out of the water”. The Cruising Association said that “shallow water and tidal effects give particular problems to control centres which can only be resolved by local knowledge. Names of places given in emergency calls are frequently not those charted and many names, particularly of small physical features, are duplicated on charts. Local knowledge is required for quick resolution of the resulting confusion”.

The report further stated: “It is apparent that the overwhelming majority of incidents dealt with by rescue co-ordination centres are either on the coast or just off-shore, exactly where local knowledge is so valuable. To imply otherwise is disingenuous.”

and: “We are convinced that local knowledge, whilst clearly not the only source of information for Coastguards, is a fundamental tool in Watch Officers’ armouries. We believe that it helps Officers to respond quickly and appropriately to incidents, and therefore saves lives. We are concerned that the closure programme, by requiring Watch Officers to cover more lengthy stretches of coastline, threatens to dilute local knowledge to such an extent that its value will be reduced, with a potentially very serious impact on the performance of the Coastguard service.”

The MCA made exactly the arguments then as now: “The MCA now seems unconvinced of the importance of local knowledge to Watch Officers. The consultation document said that whilst ‘a knowledge of the overall operational area a co-ordination centre controls is important ... it is misleading to think that any officer at a co-ordination centre could retain a detailed working knowledge of an area which on average is around 500 miles of indented coastline and many thousands of square miles of sea’. The Department of the Environment, Transport and the Regions agreed that each station deals with a large area, and the centre at Falmouth, for example, deals with incidents from around the globe: ‘it is misleading, therefore, to view co-ordination centres as a focus for only “local” activity’. However, the National Audit Office established that one third of all incidents to which the Coastguard responded in 1996 were on the coast, and the Coastguard Agency itself has revealed cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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that 75% of all search and rescue vessel incidents involve recreational craft, which, in the majority of cases, can be assumed to be close to land.” and “That said, the Coastguard Agency’s Five Year Strategy stated that local knowledge ‘is invested in sector managers and the 3,000 or so auxiliary Coastguards ... [and] is also available from other local rescue facilities—lifeboats, helicopters and those ships and people who work and operate within the area’.” In their response to the Select Committee on Communities & Local Government in 2005, regarding the very similar FiReControl Project, the Association of Chief Police Officers stated: “It is also important to emphasise that, whenever possible, ‘local knowledge’ must be maintained within any migration to regional call centre systems. Failure to do so is likely to impact on the effectiveness of the Fire and Rescue Service to provide an informed and ‘intelligence led’ response to incidents.” and the Committee themselves said: “Local knowledge of an area can help to identify the location of an incident, particularly if a caller is not at the incident site (thus reducing the benefit of caller identification/location functions of planned RCC technology). The President of the FBU highlighted how important local knowledge had been in the organisation of the response to the Buncefield Oil Depot Fire, particularly as the initial emergency call did not link the explosion to the oil depot.” Indeed the whole attitude of MCA Management with respect to local knowledge is contradictory because the operational procedures for HM Coastguard, several volumes known collectively as CG3, specifically lay down how important it is for Coastguards working in Operations Centres to have a substantial local knowledge. Even setting out how often we should be tested on such knowledge and laying out in great details the sorts of questions that should be included in the Local Knowledge Test. Furthermore it is a requirement that when a Coastguard goes down to sit their final CWA/Watch Officer examinations, that they have a current, up to date local knowledge certificate. So if they do not attach any great importance to it, why then the insistance that we know it. They cannot square this circle. What the Committee said then about local knowledge is equally true today. Its is equally clear, from the responses to the inquiry into the FiReControl Project, that the only group of people who think that local knowledge is unimportant in an operations room setting is MCA Management. The argument that local knowledge is not important in the Operations Room has been patently demonstrated to be a fiction, which is all about securing the objectives the MCA wants and nothing to do with its relevance to the saving of life.

Similarity with the FiReControl Project The FiRe Control Project was established to reconfigure the Fire And Rescue Services control rooms across England. It was proposed that some 47 Local Control Rooms would be centralised into nine much bigger Regional Control Centres (RCC—essentially the Fire Service equivalent of a MOC). The arguments presented for this radical solution were pretty much identical to those being touted for the reorganisation of the Coastguard. As the Fifth Report of Session 2005–06 Vol 1 of the Select Committee on Communities & Local Government stated: “The Government’s main motivation behind the amalgamation of fire control centres is to increase ‘resilience’ by enabling the FRS to handle large-scale incidents better, from environmental disaster to a terrorist attack. RCCs will co-ordinate services in a region from one central point and will have the capability to co-ordinate with other RCCs across the country, providing fall-back support should any RCC cease to be operational.” Very similar wording to that used to justify the Coastguard reorganisation. Indeed on Page 5 on the Communities & Local Government document “FiReControl and overview” its states: FiReControl will provide: — Improved systems and better technology providing a more effective response to emergency calls. The project will deliver networked access to up-to-date information on the nearest and most appropriate fire appliances for any incident. This will improve local, regional and national mobilisation. — A more resilient system that supports FRSs in responding to major emergencies. The RCC network will enable fall-back and back-up arrangements. — Enhanced capability for dealing with high volumes of emergency calls. There will be common systems, procedures and mobilising protocols. All FRSs will have the full range of capability that currently only some FRSs benefit from. “Resilience”, “Improved Technology” and “Enhanced Capability” all buzz words or phrases also used in the Coastguard document. The current Shipping Minister, Mike Penning, whilst being an enthusiastic supporter of such radical plans for the Coastguard, had no such liking for the similar plans for the Fire and Rescue Service, stating in the House of Commons on 12 October 2005: “I fundamentally oppose the project.” In particular, he raised concerns cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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about the IT (Information Technology) which underpinned the project, concerns that were borne out as we shall see later. He stated: “Like many members, I have grave concerns about IT projects. A Labour Member commented earlier...... that IT projects went wrong under Conservative Governments too, which is perfectly correct— they have been going wrong since time immemorial. In relation to this IT project, the key is lives being saved. That is why I fundamentally oppose the project and why the FBU (Fire Brigades Union) opposes it, as it understands the situation on the ground much better than any bureaucrat in Westminster.”

In the light of the above, could I respectfully request that the Select Committee enquires of Mr. Penning why it is that such proposals were so bad for the Fire and Rescue Service and yet they are to be welcomed for the Coastguard? Why his “Road to Damascus” conversion to the wonders of centralisation and the beneﬁts and reliability afforded by IT, when lives are at stake?

In relation to the FiReControl Project, a number of submissions made to the Select Committees enquiry also sound clear alarm bells for the Coastguard proposals. With respect to the supposed “increased resilience” the FBU stated in their evidence that: “we do not believe that FiReControl improves the resilience of the ﬁre service and that it’s potential risks—both operationally and ﬁnancially—greatly outweigh any potential rewards.”

They were subsequently proven to be correct and I would argue that exactly the same argument can be made for these current proposals for the Coastguard.

Indeed the FBU had more speciﬁc concerns about the whole project and these concerns exactly mirror my own and my colleagues: — Whether the project will indeed enhance resilience. — The potential impact on front-line services. — The location of RCCs (in the Coastguard case MOCs). — Whether the project will enhance efﬁciency. — The technology. — The funding arrangements.

The FBU also made the same complaint I have about the total lack of detailed information supporting the project.

The Select Committee’s report further found that: “Some witnesses argued that the RCC structure will have a negative impact on front-line services which in turn would undermine resilience.”

As highlighted in the Local Knowledge section previously, the same concerns about the loss of such knowledge from the Coastguard by the move to centralised Control Rooms were made about the FiReControl project. Local knowledge is vital and as been demonstrated, is likely to be lost in any migration to a more centralised system, be it a MOC or an RCC.

This project was subsequently cancelled on 20 December 2010 at a cost of some £423 million to the taxpayer and an ongoing cost of rent for the now empty and useless RCCs of some £6.5 million per annum. Surely in these ﬁnancial times, the risk of a similar fate for the Coastguard proposals cannot and should not be tolerated.

Location of Maritime Operations Centres

I have serious reservations about the planned locations for the two MOCs outlined in these proposals and these reservations relate directly to the ability of the Coastguard to recruit and retain staff.

One MOC is to be located in Aberdeen and one in the south of England in the Southampton-Portsmouth area. Clearly, little or no thought has been given to the basic economics of these sites. By this I mean it would be difficult to choose two more expensive and affluent areas of the country in which to place these centres. It is well known that both Aberdeen and the surrounding suburbs and villages and the south coast, particularly around the Hampshire/Dorset area are some of the most expensive in the country, both in terms of their cost of living and indeed property prices. This will, of course have a direct impact on the ability of the MCA to recruit and retain sufficient staff to man these centres. Whilst the document makes vague references to “rewarding our staff” better, it would take a substantial hike on current pay levels, to make that a sustainable reality. When one looks at the profile outlined for the Operations Officer 1 and compare that to the current profile for a Watch Officer, there is very little difference, so I rather suspect that there will not be a substantial difference in remuneration for the post as outlined. Therefore one has to be very sceptical of the ability of the MCA to properly staff such centres without substantial pay increase which would, of course, in turn result in substantially increased budgets for this project. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Information Technology The consultation document continually refers to “new” and “modern technology” that will enable all of what is proposed to go ahead and give us the “fully integrated national network” they say that it will provide. This whole argument is, frankly, pie-in-the-sky and wishful thinking, dangling the baubles of super technology before respondees like some latter day colonial trying to appease the natives. The trouble is, the technology they are talking about is neither “new” nor is it in any way reliable or capable of providing what they say it can. The MCA cannot give any guarantee whatsoever that this whole project will not, in the end, go the way of so many other similar public service projects at enormous cost to the taxpayer. Technologies such as AIS, EISEC, DSC (Digital Selective Calling) etc already exist and are installed in all the current Coastguard Operations Centres. For example, great play is made of the ability of AIS to track vessels in “real time” and this helps either avoid incidents or increase response times to them. This is complete nonsense. In the first place, of the hundreds of thousands of vessels large and small operating around the coast of the UK, over 90% of them do not have AIS fitted. It is only required to be carried by larger commercial vessels so its efficacy in either preventing incidents or increasing response times to them is, to say the least, moot. Furthermore, it requires someone to be actually looking at the screen at the time something happens in order for it to be of use and no one is suggesting that anyone should be constantly monitoring AIS! This would of course be both impracticable and, under current display screen regulations, illegal. DSC likewise is only required to be carried by “SOLAS” registered (International Convention on the Safety Of Life At Sea) vessels, ie those over 300GRT (Gross Register Tonnes) so again, the number of vessels actually carrying this equipment, compared to the total is very small which again calls into question its value. Yes they are useful tools, but they are not the “all singing, all dancing” technologies that this document suggests they are. Furthermore, they are all subject to the same vagaries of atmospheric/weather interference and Remote Radio Site failures as all our other Radio equipment, since they rely on the same VHF transmission technology as voice radio. They are a handy addition to, not a replacement for, VHF Marine Band Radio communications or Satcomms (Satellite Communications). To suggest that “the power of our technology” can be the basis on which to completely dismantle the current Coastguard configuration is misleading in the extreme. Furthermore, we are all no doubt aware, of the significant number of previous IT projects of this nature that have either failed completely or simply do not work as they should, because the IT has been woefully incapable of producing the results expected of it. As well as the recent FiReControl fiasco, I’m sure we all remeber similar disasters with systems for the NHS, NATS, Child Support Agency, Dept. for Education and Training, Passport Agency, Immigration Service to name but a few. Indeed the Select Committee on Communities & Local Government, when examining the FiReControl Project, quoted from the Outline Business Case for the project that: “The recent history of delivering IT/change projects in the public sector has demonstrated a less than 50% success rate. There is therefore a risk of unsuccessful delivery of the infrastructure and change components of regional controls which could result in delay or even total project failure.” Given the above then it can be argued that the MCA has a less than 50% chance of delivering what they propose which in good times would be a poor return on investment but in the current economic climate is, I would venture to suggest, reckless and foolhardy and does nothing to protect the public purse, something which all Government departments have a duty to do.

Conclusion In light of all the evidence I have presented I conclude that the proposals by the MCA as they stand are flawed and fundamentally unsound, based as they are on evidence which is flimsy at best and at times downright misleading. They represent a significant threat to the saving of lives around our coast, through the substantial loss of local knowledge, to which the MCA has a singularly cavalier attitude, increased response times, and a lack of resilience through putting “all our eggs in one basket”. They also represent a substantial risk to the public purse of, at the very least delays and substantial budget overruns to complete project failure, as in the case of the very similar FiReControl project.

Recommendations i would like the Committee to Consider — On the basis of the proposals’ similarity to the FiReControl and other, failed public sector projects, these proposals represent a significant risk to the public purse and should be returned to the MCA for reconsideration and amendment. — Absent any financial considerations the proposals in any case are not sound and represent a potential threat to life saving around the UK coastline through the closure of so many coastguard stations and the subsequent substantial loss of local knowledge and increased response times. The MCA should therefore be asked to withdraw them and consider alternatives. — Any future proposals should be supported by concrete evidence to back those proposals and alternatives should also be presented so that a properly informed judgement can be made. — On the basis of the significant risk these proposals represent to the public purse the Committee may wish to consider having them examined by the National Audit Office. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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— The MCA in future needs to reconsider its attitude towards consultation and should, in future, consult on a serious and meaningful basis and any results obtained by such a consultations process should be independently veriﬁed. — The Committee may again wish to highlight the importance of Local Knowledge and question the MCAs persistent refusal to acknowledge the same. February 2011

Written evidence from Ian Graham (MCA 37) I am the PCS Union Branch Secretary for Northern Ireland Coastguards and an SMC Qualified Watch Officer at MRCC Belfast. Two questions that the select Committee needs to ask are: “Under the proposals in the Consultation Document, what would be the procedure for routing distress calls via VHF/DSC, 999 or routine telephone call between Casualty, MOC and Sub-station; and whether the SMC (SAR Mission Co-ordinator), Search Planner and Initial Call Taker would be co-located in the same room at all times.” and “How both MOCs will be sufficiently manned at all times to provide cover in the event of a catastrophic failure at the other MOC.” The first question is important as it is vital, under HMCG SAR Co-ordination Principles & Procedures, for the SMC to have direct, physical contact with the initial call-taker. Anything else would compromise the quality of service. The second is important because we believe that the proposal is subject to exactly the same constraints as the current “pairing” system in terms of resilience, but on a National as opposed to Regional scale. February 2011

Written evidence from a Serving Coastguard in Aberdeen (MCA 38) I am a serving Coastguard Officer but would like to remain anonymous. I would like the Transport Select Committee to ask the following questions of the MCA Chief Executive— Sir Alan Massey when he appears before you: (1) Why is the Consultation document so full of misleading or indeed plainly wrong statements? It suggests HM Coastguard is operating as it did 40 years ago. But we are widely recognised as a world leader in maritime SAR and have responded flexibly to frequent changes in numbers of stations and new equipment in the last 40 years. Other examples are: The graph (p17) purporting to show pattern of demand by time when it actually shows only the time an incident starts—no account is taken of incident duration or severity. Statements such as “Peak periods at the busiest stations are over 20 times as busy as the quietest stations at periods of lowest activity, yet the latter will have the same number of officers on duty.” (p17). This is rubbish. Busier stations have been given greater staff and for over five years we have been adjusting the manning levels of all stations to reflect the predictable demand using a risk assessment tool. (2) Resilience. How can concentrating all equipment at two sites nationally, improve resilience? A more distributed network that is highly interconnected would be far more resilient. With all the eggs in two baskets we are even more reliant on British Telecom networks. If one MOC fails for some reason the other MOC can only offer a reduced service to half the country as they will not be connected to all aerials in that half. (3) Making most Sub-centres close each night will involve complicated handovers twice a day between them and the MOC. These handovers will not be face to face and there is a grave risk of vital information being missed Would it not be far better for all remaining Sub-centres to operate 24 hours a day? (4) Do you not think that persons working in the new MOCs or Sub-centres require their own local knowledge, knowledge that is required to be able to get the best information out of a first informant during the initial call? February 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Written evidence from Karen Thompson (MCA 39) There are a couple of main points made which may change the whole nature of the consultation document and therefore it would have to be revisited—it would appear that the author of the Consultation Document has failed to do his homework. 1. Closing stations may well be illegal under current UK laws and this point should be investigated in detail: As pointed out in the introduction, the United Kingdom is a signatory to UNCLOS and abides by the laws of the EU and the IMO; therefore the proposal that we reduce the number of rescue coordination centres and in doing so reduce the number of search and rescue regions is not only a retrograde step, it is illegal under IMO SAR Convention 1979 Annex 1998/2000 Ch 2, Paragraph (ii), and would seriously affect the ability to carry out our obligations under MarNIS, (EMSA), Directive 2002/59/EC, also illegal especially with changes to Directive 2002/59/EC and the Council Directive 93/75/EEC pending for 2012. 2. Transference of control in an emergency to the Admiralty could not be done by a private company—see The Coastguard Act 1925: It should also be noted that training and skills development for MSAR, when undertaken by HM Coastguard themselves, is quite legal and moral. If training was taken over by a privately owned, proﬁt—making company, then questions could be asked as to the mercenary nature of this training and deployment of UK trained personnel in sea areas of countries who are not full signatories to UNCLOS, SOLAS and IAM SAR. It may also be in contravention of rules under MarNIS and the United Nations (IMO) and the worst case scenario would be breaches to National Security. The Coastguard Act 1925 (2:Transfer of control of coastguard to Admiralty in case of emergency),12 would also have be seriously considered and possibly re-written if any f changes were made to the nature of stafﬁng the Coastguard including the operation of MRCC’s and MRSC’s. Private companies could not undertake the role as the Coastguard can at present, so outsourcing duties, buildings and facilities would be out of the question. February 2011

Written evidence from Shetland Coastguards (MCA 41) I watched the meeting of the Transport Select Committee questioning the Maritime and Coastguard Agency on the 8 February; with regard to the ETV contract I feel the evidence/explanation by the MCA representatives is misleading therefore I would like to draw the attention of the Honorable Members to normal work instruction/ practice when the ETVs are sent to an incident. Once on scene, if the ETV makes a connection (tow line) to any other vessel it immediately goes “off contract” to the MCA and a commercial contract is always negotiated with the ship company/owner/agent and the operator of the ETV. I would also like to point out that for years the standard work instruction/practice when tasking an ETV has generally been a joint decision between the Coastguard Watch Manager/SAR Mission Controller, and the (MCA) duty Counter Pollution and Salvage Ofﬁcer (CPSO) however, shortly after the proposed withdrawal of the ETV was announced the work instruction was hastily revisited; the decision to task the ETV is now referred to a member of the senior management. In effect this makes tasking of the ETV more difﬁcult and lengthens the response time. February 2011

Written evidence from Guy Boily (MCA 45) I totally agree with Miss Amanda Darling. The coast guard is such an important and invaluable asset to saving lives and ships at sea. In 2008 I travelled from France to Iceland on a small sailing vessel (30 foot). On one occasion on the Isle of Man, our ship was anchored in the bay and for some reason the anchor broke loose. We were not on the ship at the time but the man in charge (John Moore) noticed the runaway vessel and called his troops. They were out in a very short time and saved our ship from smashing against the stone break water near the entrance of the bay. This is why the coast guard is there. This is why these volunteers are there and why they do a great job. If we had been on the vessel at the time and hadn’t managed to turn the vessel around, who knows what could have happened. We could have been in grave danger or maybe have lost our lives. I know that cuts are being done everywhere in all countries but this is like not ﬁxing a leaking roof and hoping 12 (1) Whenever any emergency arises which, in the opinion of the Admiralty renders it advisable that His Majesty’s Coastguard shall be placed under the control of the Admiralty, the Admiralty may by order direct that the management and control of His Majesty’s Coastguard shall be transferred to the Admiralty, and while any such order is in force, the powers and duties of the Board under this Act in relation to His Majesty’s Coastguard shall be exercised and performed by the Admiralty, and the ofﬁcers and men of His Majesty’s Coastguard shall be subject to the Naval Discipline Act . . . with such respective ranks and ratings and such pay and emoluments as may be determined by the Admiralty. (2) Any order made under this section shall be revoked as soon as the Admiralty is of opinion that the emergency has ended, but without prejudice to anything previously done thereunder. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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that it doesn’t rain (not a good way to save money). The following images tell the story to a happy ending but the outcome would have been so different if they hadn’t been there. Thank you Mr. John Moore and your team. February 2011

Written evidence from Eric Greenough (MCA 48) THE CLOSURE OF HM COASTGUARD MARITIME RESCUE CO-ORDINATING CENTRES (MRCCS) 1. Introduction As a member of H.M. Coastguard’s Reporting Members I wish to express my grave concern about the planned closure of the number of Maritime Rescue Co-ordinating Centres (MRCCs), I feel the consequence of this action in particular the Liverpool Centre will expose the users of Morecambe Bay in additional peril.

2. Experience In the March of 2008 I retired from the Morecambe Coastguard Team after 24 years service and was recruited into the ranks of Reporting Member Ashore because my home overlooks the bay. With this depth of knowledge and experience I feel I can offer meaningful comments on these proposed closures which I believe to be a mistake and will place visitors to the seaside and local residence in further danger. I appreciate the advances in technology that have taken place in Maritime Rescue Centres but this technology will never replace local geographical and logistical knowledge in relation to the types of rescues local teams attend ie mud rescues, cliff edge falls.

3. Evidence Against Closures of MRCCs The majority of calls to the Coastguard come from the public (ref Raynor Report) many are made by visitors to the area and thus are not familiar with their precise location. When as an example a 999 call or enquiry is received at say Liverpool, the watch staff there will have a better knowledge of where the person making the call is located, and be able to explain to the local Coastguard Station Officer the nature of the rescue the team will be required to undertake ie quicksand. Allied to this is that local residents tend to use a local name eg Throbshaw Point, Heysham, this feature does not appear on Ordinance Survey Maps. This degree and speed of local knowledge will then hasten the tasking of the local Coastguard Team thus reducing their response time which, is a vital element in the bay. This knowledge will also ensure that the right team with the correct equipment is responding. The watch officers in for example the Liverpool Rescue Centre have much of this information at their fingertips and therefore do not need to interrogate a data base system, computer systems do fail, information can be incorrectly entered omitted or corrupted. I view with apprehension a situation, which will arise with the closure of MRCCs. A hot Saturday afternoon numerous incidents occur, multiple calls from mobile phones via the 999 system reach the MRCC resulting in a system overload. The managers of the service must never forget the situation which arose at Liverpool MRCC during the Cockling Disaster, Gas Rig Helicopter Ditching and River Dance incidents when the Liverpool duty watch staff were overwhelmed with incoming calls from the media. At the scene of the Cockling Disaster at Morecambe Lodge I found myself with my Sector Manager dealing with the media as well as trying to function as a searching Coastguard. The lesson that must not be forgotten is that it takes time to assemble a Coastguard PR Team who can take over media management. The media today act faster, therefore any delay in their attempts to gather incident information means these enquiries fall on the staff of the MRCC or the on scene Coastguard Team. In 1985 when I became a member of the Coastguard as an Initial Response Team Member we where dealing with six to eight call outs per year, mostly of a minor nature. The Liverpool MRCC then handled about 240–250 999 emergencies each year and the Coastal Teams nationally had the support of over 80 Regular Sector Officers. In my last year of service, 2007, the Morecambe Team was responding to 68/70 taskings per year and the nature of these incidents was far from routine or trivial but by then coastal teams had the support of just over 60 Regular Sector Managers nationally. The Liverpool MRCC was by now handling over a 1,000 incidents each year.

3. Conclusion In a recent interview the new head of the MCA Sir Alan Massey made much of the wealth of local knowledge held on the coast by the local rescue teams. However, with the closure of MRCCs it will increase the demands on the local volunteer Coastguard Rescue Teams at a time when they receive a reduced support from the regular Coastguard Sector Managers. I hope that you will consider very carefully any decision to close Liverpool Coastguard Rescue Centre and other centres as by remaining open they will be in the best interests of locals, visitors and users of Morecambe Bay. February 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Written evidence from Michael D Cowsill (MCA 51) Summary I object to the MCA proposed reorganisation which would lose the Stornoway 24 hr cover (or indeed that in Shetland on the same grounds). 1. The Coastguard provision at Stornoway is an essential Maritime, Aviation and Community service whose uniqueness in proficient operation cannot be substituted by geographically remote services. 2. Continued removal of professional services from very remote rural areas such as ours contributes to the decline of the Communities and promotes very real barriers to the potential for regeneration by attracting inward investment and population. 3. Provision of Aviation and Maritime protection forms a considerable underpinning of both the tourist and fishing industries- in reassuring those who do visit/work here of their level of security. 4. The coordination from a remote location supposing long distance communications remain intact at times of considerable climatic disturbance are uncertain ,and the fewer nodal points in existence increases the probability of a failure being catastrophic—ie failure of service resulting in loss of life due to delays or lack of coordinated response. 5. The likelihood of survival in seas around the Hebrides (as the north Sea) can be measured in minutes and is not exempted during hours of darkness—life does not wait for daylight and a “shop” of Coastguard coordination to open before expiring- to open only during daylight hours is crass moneysaving. 6. The provision of a local service with local knowledge can be the difference between life saved and body recovered—to expect a remote location to hold officer knowledge from the whole of Scotland’s coastline (some 60% of the UK’s coastline in length is Scottish Mainland and Islands). 7. Item 6 is above is exacerbated by the multiplicity of place names in both English and Gallic. 8. The current Stornoway service provides a service second to none, combining local knowledge including tidal and sea states/weather effects unique to the area. It is not possible to replicate this on a map or electronic device alone since at any time there is a failure, the further way the backup exists, the more likely lives will be lost by error of judgement caused by knowledge gaps or indecisions caused by time taken to locate actual incident locations. I respectfully seek that given there has been no professional risk analysis to the above proposed changes by the MCA that the decision cannot be allowed to proceed. This is clearly a money saving exercise carried out in hast- had the MCA been reviewing this as a boat owner leaving port without safety equipment on. Money saving grounds saying “it looked like the weather was fine” condemnation would have been forthcoming—ill feel the same about this plan. February 2011

Written evidence from Blundellsands Sailing Club (MCA 53) The Port of Liverpool 1) The Port of Liverpool handles over 34 million tonnes of cargo per annum. Together, the Port of Liverpool and the Manchester Ship Canal generate 15,000 vessel movements each year on the River Mersey handling the most diverse range of international trade. Liverpool is ranked among Britain’s largest deep sea contained ports and is the UKs major gateway for trade with the United States and Canada and serves more than 100 global destinations. The Seaforth Container Terminal handles nearly 700,000 containers a year and a second container terminal is planned for development on the River Mersey which will handle another 600,000 containers. The Port of Liverpool imports more grain and animal feed than any other UK port, exports more scrap metal for re-cycling and includes among the trafﬁc crossing its quays, timber, steel, other metals, coal, cocoa, crude oil, edible oils, liquid chemicals and much more. In addition Liverpool is the major British port for trade with Ireland and, in addition, carries nearly three-quarters of a million passengers with eight sailings a day. It is also the major British port for trade and the carriage of passengers with the Isle of Man. By any criterion the Port of Liverpool is a signiﬁcant player in the economy of the UK.

The Significance of the East Irish Sea to the UK Economy 2) The East Irish Sea also plays a significant part in the economy of the UK. With 7.5 trillion cubic feet of natural gas and 176 million barrels of petroleum estimated by the field operators as being initially recoverable hydrocarbon reserves from the existing fields in the East Irish Sea it is regarded as a mature exploration base. For example, oil is produced from the Lennox and Douglas fields and gas is produced from the Hamilton, Hamilton North and Hamilton East reservoirs. Other gas fields in the East Irish Sea include Lambda, Darwen, cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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Asland, South Morecambe, North Morecambe, Dalton, Crossens and Binney, and are part of the Rivers Gas Fields. In addition Gateway Storage and Petrofac are together developing a 1.5 billion cubic meter offshore storage site which is due to provide up to one third of the UK gas storage capacity in the East Irish Sea. Nor must the generation of electricity from the three Nucleur Power Stations Sellaﬁed, Heysham and Wylfa sited on the East Irish Sea be forgotten. Furthermore, the East Irish Sea contains the Barrow, Burbo Bank, North Hoyle and Rhyl Flats Wind Farms that currently feed 330MW into the National Grid. Moreover, a further 5,644MW of power will become available on completion of the Burbo Bank Extension, Gwynt Mor, Walney I and II Solway Firth and Irish Sea Wind Farms when they are completed. The supply of gas, petroleum and electricity from the Irish Sea is an essential element in the future prosperity of the UK. To be aware of and oversee such UK strategic resources from unfriendly agents or terrorist attack it is essential that a professional Coastguard with deep and detailed local knowledge gathered over many years of the Irish Sea and its shoreline be in place at Liverpool Coastguard Station on a seven days a week 24 hours. Not in Aberdeen or Southampton /Portsmouth Maritime Operations Centres or even London where, with the best will in the world, despite any technological advances, such local knowledge will simply not be available! It is accepted that from the point of view of keeping Northern Ireland in the Union a favourable case might be made for Belfast. Nonetheless, in terms of coastline length, communications, workload and strategic importance to the UK on the basis of the evidence presented above the retention and, if necessary, the modernisation of the Coastguard Station at Liverpool would make good economic and strategic sense.

The Question of Resilience of the Coastguard 3) A worrying feature of the Coastguard Modernisation Consultation report is the question of resilience. In an attempt to get value for money there seem to be an attempt to cut stafﬁng levels to the bone. Whilst the evidence in the report of typical pattern of demand by month and typical pattern of demand by time may prima facie be persuasive it does not give details of the seriousness of an event or longevity of an event or whether such serious or time consuming events take place during the night time or day time. Moreover, say a serious incident takes place in the Irish Sea at night—which as mariners sailing pleasure craft we know can be frequently the case—and the Aberdeen MOC has a similar event ongoing in the North Sea together with another event on the West Coast of Scotland, with the best will in the world and all the modern technology available it appears highly unlikely that a successful conclusion may be brought to all three incidents. For example, a very serious incident in North Sea might take all the resources of all the staff at the Aberdeen MOC to deal with the incident in a professional way. Can the same staff also give their best endeavours to the incidents in the Irish Sea and the West Cost of Scotland? It is to be doubted!

The Cost of the Preferred Option as Against Upgrading the Present System 4) The proposals set out in Chapter 6 of the consultation document suggest that in both long running costs and capital expenditure, in Net Present Value terms, there would be a saving of £123 millions over 25 years. This amounts to savings generated by the preferred option of ONLY £4.92 million/annum. This is based on the upgrade of the current 18 MRCCs costing £639 millions over 25 years or £25.56 millions/annum as against the Preferred option costing £516 millions over 25 years or £20.64millions/annum. As against the strategic importance of guarding and monitoring the UKs offshore oil and gas wells, wind farms and nucleur power stations a saving of only £4.92 millions/annum is an insigniﬁcant amount. For the Department of Transport to say this level of expenditure is unaffordable beggars belief!

The Liverpool Coastguard Station is to Remain Anyway 5) During a recent visit to Liverpool Coastguard by 30 members of the Blundellsands Sailing Club we uncovered the fact that the Liverpool Coastguard Station is NOT going to close anyway! It is simply that under the Preferred option put forward by the Consultation Team the Coastguard Staff who currently occupy the building will be withdrawn! This information was elicited when we asked who else occupied the building. The Coastguard Management Staff will remain, the MCA’s Surveyors will remain, the Coastal Pollution staff will remain and the Administrative Staff will remain! Moreover, the staff will continue to service the necessary administration regarding Seamen’s Discharge Books and ABs Ticket’s. Furthermore, the Liverpool Coastguard Station operates as a weather station for the Liverpool Bay area and NW of England. The Liverpool Coastguard Station is a purpose built modern building with up-to-date facilities. The MCA’s Chief Executive in an interview last week on radio said that the technology used by the Coastguard was forty year out of date yet, during the course of the visit by the Blundellsands Sailing Club, there was no evidence of the technology used by the staff as being out of date! The question is, if the Station is to remain anyway, why withdraw the Coastguard Staff who currently operating from this building? During the Club’s visit there were only three members of staff on duty doing a twelve hours shift. So why withdraw Coastguard Ofﬁcers from a modern purpose built Station overseeing a maritime area of strategic economic importance to the UK and the Port of Liverpool if the building is going to remain in situ anyway!

Conclusion 6) There is undoubtedly a need for the Coastguard to take advantage of the latest technology and, perhaps, to be reconﬁgured to deliver a more integrated and improved level of service. Moreover, there is an acceptance cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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that under the current economic conditions there is an imperative to deliver efﬁciencies and reduce costs. Furthermore, there is a good case to be made for new and enhanced roles and responsibilities of staff manning the Coastguard Service. The question is whether the proposals in the Coastguard Modernisation Consultation Report will achieve this end. The Blundellsands Sailing Club is of the opinion that the proposals contained in the Report lack the operational integrity and resilience to ensure that the Coastguard can help to manage the use of our seas and protect those who use them. It is the view of the members of the Blundellsands Sailing Club that for operational resilience there should be three not two Maritime Operations Centres one of which should be on the West coast of the UK. The broad argument for sub-centres is accepted but not the cut in the numbers of centres being suggested. Moreover, from a security point of view, such sub-centres should be manned throughout the 24 hours for fear of being broken into and damaged by criminals or terrorists set on damaging the economy of the UK. To rely on the burglar alarms or on the Police to ensure Coastguard Stations outside day light hours are free from attack is simply not realistic in today’s day and age! The security of Coastguard Stations will be a vital element in any modernisation programme and this, regrettably, has not been addressed in the Consultation Report. In conclusion the Blundellsands Sailing Club strongly recommends that for all the reasons given above that the Liverpool Coastguard Station be retained. February 2011

Written evidence from AN Sulaire Trust Ltd (MCA 54) I am the secretary of a group who take a traditional dipping lug sailed boat out sailing. It is called AN Sulaire Trust Ltd. We have 150 members and we regularly go sailing in the Minch. Possibly two or three times a week. The boat has gone to all the islands on the West Coast of Scotland over the past 15 years and also it has gone to Orkney and through the Pentland Firth. It is a 33 foot open boat. “An Sulaire” has no fancy electronics. When we do our annual big trip we have on board up to eight people and rely on a handheld VHF radio for contact with the Coastguard. We are appalled at the proposals to reduce Coastguard coverage in Scotland to only one main station in Aberdeen. We do not have DSC, nor AIS, most leisure craft do not. It is widely acknowledged that the leisure sailing industry is an increasingly important one in the economy of not only Scotland but in Britain. Small crafts simply do not have the technology that Vice Admiral Sir Alan Massey seems to think is ﬁtted to all vessels. Many smaller craft like kayaks and canoes have even worse coverage than a yacht due to their height above sea level. We cannot rely on a system of radio aerials to relay information across the country. Here in the Outer Hebrides we often have our internet and broadband down, even in the town of Stornoway, so for relying on it to convey life or death information is a bit too presumptuous for our liking. We need a system that is as foolproof as possible, with as few areas for delay as possible. Delays cost lives. The radio coverage we get is far from total and there are many black spots. At these times we may have to rely on mobile phones which in themselves are not always good for coverage. 90% of Coastguard work comes from small craft usage and with the sailing leisure industry increasing year by year, we need to take this very seriously indeed. Even as the situation stands at present the Stornoway Coastguard can ﬁnd themselves trying to call volunteer Coastguard teams out for 10–15 minutes. There can be small black spots behind hills or up lochs, or larger areas. It is always good for us to know that we can rely on our local Coastguards with their extensive local knowledge of areas, tides, particular anomalies in the treacherous waters of the Minch and around the Outer Hebrides. Often with this they can pinpoint where a situation is located within seconds, and with sketchy radio/phone coverage, this is vital. Time is of the utmost, paramount importance, delays means loss of life, minutes are minutes of life ebbing away. Vice Admiral Sir Alan Massey scornfully mentioned “only a handful of minutes”; he should try being in the sea waiting to be rescued for a “handful of minutes”, and with the proposed new plans the delays could be much more than his “handful of minutes”. There would be blood on his hands. Critical loss of local knowledge would take place, the geography, place names, culture, topography, the people and personalities involved in incidents and general day to day maritime activity. The Stornoway Coastguard are currently familiar with all of this and it is this vital information and inside knowledge that leads to so many successful outcomes. The Gaelic language which dominates the place names of the area is often spelt or pronounced in a completely alien manner to anyone without some knowledge of it. The loss of all this is unthinkable, with only one assured outcome and that is that lives will be lost. The Donaldson Inquiry recommended after the Braer Disaster to have the Coastguard Tug boats implemented and since then these tugs have saved millions in preventing oil spillages, or wrecked boats, nuclear submarines etc messing up our coastline. In our view it is imperative that these are kept on to escort large tankers through the pristine waters of the Minch, or to be available to haul crashed boats from rocks before a major oil spill can take place. Events even in the last month have proven the worth of these tugs, even the Royal Navy Nuclear Submarines with the latest state of the art navigation technology, has run aground in Skye and needed the Coastguard Tug to come and help. This proves to that the latest technology is not always the best thing to use, nor does it always work. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:12] Job: 010828 Unit: PG01

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In terms of closing stations in a purely cost cutting exercise the two most expensive stations to run are the Southampton and Aberdeen stations. If this is cost cutting exercise then why pick these two stations? Not only is Aberdeen a very expensive station to run, the property is not even owned by the MCA. Aberdeen has a very high turnover of staff due to loss to the oil industry. There is a danger that a lot of very valuable experience would be lost. Stornoway Coastguard building purpose built, modern and spacious is actually owned by the MCA so why in terms of cost even consider closing it? It is situated in a strategically perfect spot for the West Coast of Scotland and doesn’t cost anything in rent or lease. It is a Coastguard Rescue Team base, the Sector manager for the Volunteer Coastguard, regional support team and Coastal Safety manager are all located in this building. It is all very well to think that with DSC emergency calling that coverage is complete but it has to be remembered that much of the Stornoway and Shetland Coastguard work is for small craft. The Stornoway Station is co-located with a Medium Frequency aerial. The place names and geography and varied intricate coastline even around these islands alone, never mind the whole of the West Coast of Scotland, is not something that can safely be transferred to a database, or that someone with no knowledge of the language could possibly understand. Databases, Google Earth and other GIS Systems that the MCA are to rely on will not recognise nicknames, colloquial place names, Gaelic spelling and are no replacement for human local knowledge. Perhaps Vice Admiral Sir Alan Massey could note this when he advocates Google Earth as a navigational tool and remembers the disastrous Royal Navy Nuclear Submarines grounding, not once but twice. We beg the question, has he ever been to sea? Attempting to rely on databases, Google Earth and other GIS systems could lead to unacceptable delays and potential loss of life. Unfamiliar operators will then have to rely on third parties who are mostly volunteers. This is unacceptable exploitation of human resources. As volunteers they may not be always available and this could result in delays and yet more loss of life. The new plans advocate a 24 hour on-call officer, and only 16 extra throughout the UK. This could mean an increase of one person in the Western Isles. There is no guarantee that the on-call officer would have any knowledge of the area of the incident, may not even be available at that particular time, may already be dealing with an incident elsewhere. It is not uncommon for a hillwalker to get into difficulties in Skye, and a boat to be in difficulties on the West side of Lewis, and indeed perhaps something else on the West Coast of Scotland. This isn’t rocket science we are talking about here, its is simply common sense. People in difficulties need response measured in seconds, not minutes. The average turnover of staff in Stornoway is very low, at 4.3% compared to Aberdeen at 9.7%, where the staff leave due to oil industry better pay. Scotland has 60% of UK coastline, why are we only considering having 25% of the Coastguards? The notion of only opening during daylight hours is beyond rational belief. Winter daylight hours are only six hours and summer can be as much as 18, where is the rational in that? The last month’s Rescue mission by the Coastguards have involved many rescue coordinations in darkness. Accidents happen at night in the winter too. Finally, we consider the MCA refusal to listen to the Scottish Parliament on their objections to the new proposals a blatant deliberate attempt to scorn democracy. Many people, tax payers, voters, will assume that their MSP will be able to voice the concerns shared by the Scottish people and that an Agency such as the MCA would listen to those concerns whether raised by a UK Government, or a devolved UK Government, of which Scotland is one. Concerns on these diabolical proposals ought to be listened to from whichever source they come from, but particularly a democratic Parliament. It is our opinion that Vice Sir Alan Massey should resign over his stupid inconsiderate and ill informed statements and these frightening proposals. February 2011

Written evidence from Shetland Youth (MCA 57) I am writing on behalf of Shetland Youth Voice, Shetland’s local youth forum. I would like to express the disapproval of many of Shetland’s young people regarding the Government’s recent plans to close coastguard stations around the UK. Shetland Youth Voice is ﬁrmly against the Government’s proposal to close Shetland’s Coastguard Station. These plans are clearly part of a strategy that aims to save money. In modernising the system, the Government are going to risk lives. Both the Lerwick and Stornoway coastguard services are vital to the safety of the people who travel and work in the waters around the isles. The coastline of Shetland is dangerous and complex. A mainland counterpart could not replace the knowledge of the local waters that our coastguard team has built up through years of experience. The Shetland coastguard covers 36,000 square miles of sea. This vast area is not only occupied and used by Shetland boats, but also boats of many different nationalities. Emergency services are vital to the safety of these seamen. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Land-based emergency services such as ambulances and ﬁre services would not be closed in such a way, yet they have the same purpose: to protect lives.

It has been announced that the services that do remain open will only operate during the day. Accidents are not limited to daylight hours; the sea can often be more dangerous at night. It would be short sighted to assume that coastguard services are only needed during the day.

The Western Isles and the Northern Isles are very different places, with very different conditions and problems to face. The Government should take into account not only the needs of an Island community but also the 210 miles that separates Lerwick from Aberdeen. With the recent removal of the tug that offered reassurance to those working in the waters around Shetland, the coastguard is a necessity.

In the consultation report, the coastguard service was said to generate higher than necessary stafﬁng costs due to the uneven workload. Emergency services for small communities such as Shetland will not constantly be in demand but this does not mean that they are not needed. Lives should not be put at risk to save money and Shetland Youth Voice will strongly resist any attempt to remove Shetland’s coastguard service. February 2011

Written evidence from David Cairns MP (MCA 58)

Introduction

The Coalition Government is currently consulting on its proposals to reorganise the Coastguard service. Understandably, attention has focused on the proposal to change the existing structure of 18 Maritime Rescue and Coordination Centres (MRCCs) to a new structure of two Maritime Operations Centres (MOCs) with six sub-centres. Many MRCCs, like Clyde in my constituency, are proposed for full closure. I hope this document sets out these proposals are wrong, unproven and dangerous; and why MRCC Clyde should continue with its responsibility for ensuring maritime safety around the west coast of Scotland. As the constituency MP for MRCC Clyde, I am unashamed about the fact keeping MRCC Clyde open is my main concern.

I have responded chapter by chapter, in an attempt to use the structure which the MCA have asked for.

Consultation Document Chapter2

Limited resilience

The problem of the limited resilience of the Coastguard network needs addressing, but MCA have not explained why creating interoperability across more, or all, of the current centres is not a better response.

By concentrating responsibility for coordinating all responses into just two centres the MCA would be facing the same issue of resilience—except that if both Maritime Operations Centres faced problems, the whole of the UK would be without cover.

If the existing MRCCs were all interoperable the workload could be better spread between stations at peak times.

Staff point out that quieter times are used to carry out training and paperwork, and shift patterns reﬂect demand with lower stafﬁng levels at night.

In the case of the Clyde Centre, the graphs in the consultation show that it has a much more steady level of demand through the year and during the day/night than other centres.

The Consultation’s graph does not show the duration of incidents—staff point out that nighttime incidents tend to be longer and more complex.

Whilst the graphs in the consultation document tell one story, different data show something slightly different. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Total SAR hours

2500 2348

2000

1472 1500 1201 1094 1037 1000 840

500

0 Aberdeen Belfast Clyde Forth Shetland Stornoway

Figure 1 shows total Search & Rescue Hours, with Clyde far ahead of Aberdeen in the time spent carrying out Search & Rescue. Number of Coastguard Rescue Teams dealt with by each MRCC.

45 41 41 40

35 32

s 30 m

a 26 e t

f 25 23 23 23 o

r 20 number of teams each MRCC deals with e

b 20 17 17 m

u 15 15 15

N 15 12 13 13 13 10 10

0 l r t t r h s n d d n h d n y h a e t m o t e n s t e e e n a o n e a e d r u a o u b e a v v a l e d s a e y f o l w l m o h l p l o o a t t o h n n r d m F o x a e r r i C e y D m o a e m u H S l l r n h o

r e B h r v L o a w i H T B d a b P o S r L F t H S Y A o S f l i M MRCC's

Figure 2 shows that Clyde and Stornoway liaise with 41 Coastguard teams each, far more than any other centres. Whilst they might have fewer incidents to deal with than some other centres, this shows they have to manage a much longer and more geographically complex coastline than elsewhere, as well as developing and maintaining relations with a larger number of coastguard teams. CG Station 2009 2010 Aberdeen 1,082 994 Belfast 572 647 Brixham 1,324 1,355 Clyde 1,491 1,395 Dover 968 811 Falmouth 2,380 2,275 Forth 508 532 Holyhead 987 857 Humber 1,574 1,581 Liverpool 1,295 1,203 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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CG Station 2009 2010 London 741 945 M-Haven 770 784 Portland 1,447 1,319 Shetland 342 392 Solent 2,376 2,310 Stornoway 442 418 Swansea 1,836 1,766 Thames 1,304 1,217 Yarmouth 1,008 975 Total 22,447 21,776

MRCC 2009 2010 Average Solent 2,376 2,310 2,343 Falmouth 2,380 2,275 2,327.5 Swansea 1,836 1,766 1,801 Humber 1,574 1,581 1,577.5 Clyde 1,491 1,395 1,443 Portland 1,447 1,319 1,383 Brixham 1,324 1,355 1,339.5 Thames 1,304 1,217 1,260.5 Liverpool 1,295 1,203 1,249 Aberdeen 1,082 994 1,038 Yarmouth 1,008 975 991.5 Holyhead 987 857 922 Dover 968 811 889.5 Milford Haven 770 784 777 Belfast 572 647 609.5 Forth 508 532 520 Stornoway 442 418 430 Shetland 342 392 367

Figure 3 shows the number of incidents each MRCC has responded to in 2009 and 2010—Clyde responded to the ﬁfth largest number of incidents (as opposed to events, shown the consultation document). The costs associated with variation in demand between centres might be addressed by closing a handful of the MRCCs with the lowest demand, and making the remaining centres interoperable. Has this approach been considered?

Consultation Document Chapter 3 A Nationally Networked System: There is a strong case for establishing a nationally networked system, but the case for the MCA’s proposed structure of two MOCs and six sub-centres is not clear. Staff have raised major doubts about whether the technology is in place to cope with the demands of centralising all calls and signals through two centres. MCA proposed two MOCs—but what would happen if one was knocked out by an event such as a fire? If this model is to be followed three MOCs should be the minimum. The Consultation is incoherent—after having made the case for rationalising the structure into just two MOCs, it then makes the case for creating six sub-centres. The reasons given for creating the sub-centres apply equally to the argument for keeping the present MRCCs: — Specific operational issues that require particular capabilities to be tied to certain geographical locations, either for technical reasons or because of specific local liaison requirements. — Helping the Coastguard maintain and develop its links with regional civil resilience forums and civil contingency planning. — The desirability of sustaining a regional presence for the regular Coastguard, maintaining strong linkages between the Coastguard Rescue Service and the communities it serves. — Preserving regional expertise while widening the geographical pool for recruiting future Coastguard Officers. Clyde has a particularly strong case across all of these points: — Being the home of the UK nuclear deterrent, cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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— In the highly-populated central belt of Scotland (with the largest police and ﬁre service in Scotland, and the possibility of being the headquarters of future national Scottish emergency services structures), — With the longest coastline of any MRCC, the largest number of coastguard teams and RNLI stations, — With a position close to Glasgow allowing the widest possible recruitment pool for future ofﬁcers. The case for subcentres only operating during the day is questionable—how will operations be handed over at the beginning and end of the day? Centres should operate 24 hours to ensure continuity and consistency.

Local knowledge The Consultation document makes no mention of the importance of the local knowledge held by staff in MRCCs. There appears to be a deliberate attempt by the MCA to play down this issue, despite the fact that currently all Coastguard staff have to take exams testing their knowledge of the coastline which they are responsible for; including navigational hazards, coastal features, shipping activity, and potential problems. Staff with responsibility for the whole of the UK coastline simply will not have the deep geographical knowledge that MRCC staff currently possess. MRCC Clyde is responsible for the longest stretch of coastline of any MRCC; a 2,500 mile complex coastline with islands, sea lochs and sometimes confusing place names. On occasions when calls can’t be easily located by technology local knowledge is crucial for identifying the location of a person in trouble, and good local knowledge is vital to inform the response to the call. It is ironic that back in 2005 the Shipping Minister, Mike Penning, who is putting forward these proposals; argued convincingly against centralising ﬁre service control centres because of the loss of local knowledge. Why is there is one rule for the ﬁre service and another for the Coastguard?

Consultation Document Chapter4 Maritime Operations Centres As stated in my response to Chapter 3, I am not convinced that the structure of two MOCs and six sub- centres is the correct one. The comments below on the proposed location of the MOCs and sub-centres do not imply that I support the policy being set out by the MCA. Aberdeen might be the only current MCA site in the north capable of hosting a MOC, but it is not an obvious choice: — The Aberdeen site has the highest running costs of any MRCC—more than twice the cost of Clyde and all the other MRCCs. Is it the most cost-effective location for a MOC or should the MCA look at identifying a new site or expanding another site? — Aberdeen has a very high cost of living, and high rates of employment. In the consultation document it states that sub-centres should “sensibly be located in areas with good communications, with a reasonably large population and with good job markets to facilitate future recruitment”— surely this applies to MOCs even more? — Would Clyde be a better site for a northern MOC—having better transport links, a lower cost of living, and being close to Glasgow, the largest city in Scotland?

Subcentres The Consultation’s omission of Clyde as a proposed sub-centre is inexplicable. Falmouth, Swansea and Humber are proposed as sub-centres—Figure 3 (showing the number of incidents responded to) indicates that the workload of these centres justiﬁes their maintenance. The Clyde Centre takes the next place in the table of incidents responded to, after Solent, Falmouth, Swansea and Humber. It is the busiest centre proposed for full closure. As stated earlier, it monitors the longest stretch of coastline, has relations with the most coastguard teams and RNLI stations, has a steady workload throughout the year and day/night, and a position close to Glasgow allowing the widest possible recruitment pool for future ofﬁcers. The Consultation proposes keeping either Belfast or Liverpool, and Stornoway or Shetland. Keeping two of these stations whilst closing Clyde is perverse. In addition to the reasons listed above, Clyde is a far busier station than any of the four proposed to be kept, and it has a better location, positioned perfectly to cover the area from the Irish Sea to the north of Scotland. The proposal to separate responsibility for the Scottish islands (Shetland or Stornoway) and the Scottish mainland (Aberdeen) is also highly questionable. It creates a geographical anomaly whereby the Scottish west cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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coast will be monitored from Aberdeen, whilst the islands lying off the Scottish west coast could be monitored from Shetland. A more logical division of duties would be to separate the east coast, Orkney and Shetland (perhaps based at Aberdeen); from the west coast and the Western Isles (based at Clyde).

Conclusions — MRCC Clyde: — responds to the fifth highest level of incidents in the UK; — has the highest level of search and rescue hours in Scotland; — deals with the highest number of Coastguard Rescue Teams of any MRCC in the UK; — has steady demand through the day and night, and during the year; — is responsible for the longest stretch of coastline of any MRCC; — is the home of the UK’s nuclear submarines; — is located in the highly-populated central belt of Scotland (with the largest police and fire service in Scotland, and the possibility of being close to the headquarters of future national Scottish emergency services structures); and — has a position close to Glasgow allowing the widest possible recruitment pool for future officers. — Creating interoperability across the existing stations in the network would improve resilience, in contrast to the MCA’s plans for two centralised centres. — Interoperability across the existing stations in the network would also allow workload to be better spread at peak times. — The costs associated with variation in demand between centres might be addressed by closing a handful of the MRCCs with the lowest demand, and making the remaining centres interoperable. — If the MCA’s model of MOCs is to be followed then three MOCs should be the minimum, to better guarantee resilience. — Subcentres should be open 24 hours a day to avoid problems associated with handing over incidents. — The importance of local knowledge has been dangerously underplayed by the MCA. MRCC staff need to have good knowledge of the geography of the coastline they are responsible for. — Clyde is a more suitable venue for a northern MOC than Aberdeen, should not be downgraded from its current status, and should not be closed. March 2011

Letter from the Ofﬁce of the First Minister and Deputy First Minister to the Transport Committee (MCA 61a) REQUEST BY HOUSE OF COMMONS TRANSPORT COMMITTEE FOR A REPRESENTATIVE FROM THE NORTHERN IRELAND EXECUTIVE TO GIVE ORAL EVIDENCE TO THE COASTGUARDS, EMERGENCY TOWING VESSELS AND THE MARITIME INCIDENT RESPONSE GROUP INQUIRY Your e-mail of 28 April refers. Unfortunately, due to diary pressures following the recent Election, the First Minister and deputy First Minister are unable to attend the Oral Evidence Session on the 24 May. Ministers continue to take an active interest in the retention of the Belfast maritime rescue co-ordination centre which is based at Bregenz House in Bangor. Closing this station will leave Northern Ireland as the only Devolved Administration without a locally-based coastguard service. The closure would not only lead to the loss of 23 fulltime jobs, but could also potentially reduce safety levels for both commercial and recreational users of our coasts and seas. Ministers have already highlighted their concerns in their comprehensive response to the HM Coastguard Proposals for Modernisation Consultation 2010 and a copy of this was sent to the Select Committee on 21 March. Colleagues in the Department for Regional Development here have advised that they have no comments to make on the current contract for emergency towing vessels. Could we ask you to pass on the Ministers' sincere apologies for their non-attendance at the Committee meeting. May 2011 cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from Coastwatch (Redcar) (MCA 63) RESTRUCTURING OF THE MARITIME COASTAL AGENCY I am writing to you regarding the above matter on behalf of Coastwatch (Redcar) as our station, along with many other similar stations, will be affected by any changes within the MCA and would like to make the following points. 1. Our station which is operational 365 days a year between 8.00am and 4.00pm, with extended hours in the summer months and has declared facility status with the current coastguard operation, therefore we feel that we have some views on any proposed changes. 2. From our position we look out on to one of the countries busiest ports, there is a constant flow of shipping to and from the river Tees, in addition there is a full time local fishing operation. Also the inshore waters are widely used for leisure purposes which include wind surfers, jet skiers and beach use. Our particular concern is with the leisure users and your proposal to have a coastguard service operational for only 12 hours a day. Incidents are just as likely to happen outside of the 12 hours operational time as within it. This in our opinion is putting lives at risk. 3. It is our view that your proposals are aimed directly at the merchant maritime fleet that use our waters. Your proposal to have active stations at Southampton and Aberdeen will be fine for them as with modern navigation equipment they are rarely in trouble. However, our concern is more with the leisure users around our shoreline. These are the groups of people who get into difficulties and require help; these proposals will make things worse for them. 4. The current arrangements with the Coastguard service based at Humber has over the years worked at developing links with services such as ours and as a consequence has built up extensive local knowledge and contacts. All of this would be lost if the only 24hr operational coastguard stations were at Southampton and Aberdeen. Again we feel this is putting lives at risk. 5. These changes just seem to have come out of the blue. We are not aware of any consultations with interested parties; we surely have something to say about such a major change to what is already a very slim service. Surely it would make sense to consult with all organisations involved in sea safety before making proposals. 6. Whatever changes are ultimately made a bigger responsibility is going to fall on organisations such as ours, whether you like it or not we will become part of the front line of coastal sea safety, therefore you have a responsibility to involve organisations such as ourselves under the Sea Safety Group umbrella. 7. We are not opposed to changes as change can bring improvements, but we are against change which will affect us and we have no input into the changes made. We are asking you to have another look at what your current thinking is and involve the voluntary organisations that keep our coastal waters and beaches safe. We think with wider consultation a better way forward can be found. We are concerned that you are ignoring the needs of our growing coastal leisure activities. I have also copied this letter to our local MP who we think should be aware of our concerns. March 2011

Written evidence from the Scottish Government (MCA 65a) Thank you for the committee’s invitation to attend the inquiry evidentiary session in Westminster on 24 May. As you will be aware, following the Scottish Parliamentary election on 5 May, we are still in the process of formally appointing the Scottish Cabinet and associated Ministerial posts. All appointments require the approval of the Scottish Parliament which will not take place until Thursday of next week. In this context, I regret that I will not be able to attend the session as I will not have been formally appointed at that point. However, I would stress that the Scottish Government has significant concerns about the impact of all three of these proposed changes that could significantly affect maritime safety and increase the risk of damage to the environment. I have personally written to Mike Penning, MP on several occasions highlighting our concerns on these matters. A copy of the most recent correspondence was submitted to the committee as evidence on 22 March along with our response to the Maritime and Coastguard Agency (MCA) consultation on modernisation of the coastguard service for the committee will take into account in its considerations. With regard to the Coastguard consultation I would also re-iterate that one of our main concerns was been the lack of prior consultation with the Scottish Government, or any of the devolved administrations, on what is proposed. Had this occurred we may have been able to advise the MCA on the concerns that this would raise, as evidenced by the significant number of responses received by the MCA. I would also add that we would have been willing to work with the MCA and Scottish stakeholders to help develop proposals for modernisation that would be appropriate in the Scottish context, including the possibility of devolving this function to the Scottish Government. Given the recent comments from Phillip Hammond MP, suggesting that cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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there is to be a re-think of the proposals, it would now seem there is an opportunity for this type of engagement and discussion to take place. As noted in my letter to Mike Penning MP, the Scottish Government has welcomed the engagement with interested parties on the arrangements to ensure that adequate cover is put in place following the withdrawal of the ETV’s in October. We are now a member of the working group set up following a meeting at MCA Greenock on 11 May and look forward to exploring the options that may be put in place to ensure the safety of mariners and our shorelines following the end of the current arrangements. However, I would again re-iterate that despite the willingness of all of those involved, it continues to seem unlikely that an effective solution will be put in place in the timescale we face. It is important that options to extend the current contract are fully explored and implemented until an alternative approach is in place. I understand this possibility has already been discussed in earlier sessions of your inquiry. In relation to the MIRG proposals, I note the point that the changes that will be considered may not form part of a formal public consultation but I would stress the importance of ensuring that all stakeholders with an interest in ensuring that the capacity to fight fires on ships at sea remains available are given the chance to help shape future arrangements. Finally, I would like to commend the committee on its decision to hold this inquiry. The cross border and cross party concern about potential negative effects of these proposals has reflected the feeling of industry stakeholders and members of the public. I look forward to seeing the committee report and recommendations following the inquiry and would be more than willing to meet with you, or appear before a future session of the committee, following my formal appointment should that be something that you would find helpful. May 2011

Written evidence from Murdo Macaulay (MCA 66a) 1. I am a Coastguard of 12 years service, I joined at the basic grade of Watch Assistant and have served as Watch Officer and am currently a Watch Manager. I am not, as are none of my colleagues, opposed to change— I simply believe this is not the RIGHT change. I wish to further draw some points to your attention along with references to some comments taken from the MCA public meetings held as part of the consultation process. 2. The MCA has sought to sweep away the importance of Local Knowledge held in our operations rooms entirely in this proposal, I feel very strongly in my professional opinion that it is an essential part of our role as Coastguards. But I am aware that it is being misrepresented on various forums and I feel that in some cases it is a deliberate attempt to re-badge operations room coastguard officers in order to lessen the public perception of the risk of the agencies proposals with reference to loss of local knowledge. 3. I will start with the MCA vision of the future—this is one of large Maritime Operations Centres staffed with people who are, in the vast case, recruited from the locality of this centre because very few staff are willing to move. The coastguard officer on watch may well be allocated a particular geographical area which they are responsible for on a day to day basis but this will NOT replace the knowledge held in operations rooms at the present time. Let me expand why I feel this to be the case. 4. Local knowledge is not (in the case of operations rooms) necessarily a detailed field level of detail. It is rather a full understanding of the maritime environment which we are responsible for on any particular day. It encompasses an understanding of place names, geographical features, topography of an area, the weather, the people, the cultures, a working knowledge of the dialects and language used, the regular traffic that uses that area—this is critical and it is only by living and working in a particular area that people can build this up. It is an experience (which is not something which can be taught) not a skill and good judgements are made as a result of knowledge and experience. Any talk of capturing local knowledge to be able to take it out of the heads of individuals “for the greater good” and place it in databases simply illustrates a lack of understanding about what it is we are referring to. Reducing this to an operator sitting at a desk who has never been anywhere near or similar to the casualty’s location is folly and will reduce the quality of SAR co-ordination. This will compound as any residual understanding is lost as operators who have transferred leave. Any delays caused by lack of knowledge will result in an increase in the rate of deaths for certain types of incident. 5. Those who rely on our service need to trust us and once this trust is gone we will stop getting routine reports of activity, we will stop being informed of minor incidents and events, we will stop being asked for safety advice particular to our location and we will lose a large part of our dynamic “picture” of activity held in our operations rooms at any one point in a day—this will make investigation and resolution of many incidents harder and in many cases less likely to succeed. A good example would be a lone kayaker who has informed us of his departure point and car registration, he is subsequently reported overdue by a concerned relative and because we have his details we are at least able to start a search based on his departure point. If he had failed to tell us we would have nothing (frequently in this type of incident the reporting person will have only vague area details). Having this information also significantly reduces the amount of times we need to deploy an expensive SAR unit such as a helicopter. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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6. It is a point made that we only have local knowledge of the immediate area of our station. Again coming back to the point I make above—this is not the case, we are not required to have “field level” detail but what we MUST have is the appreciation mentioned above and this is something we will have as a result of being located in the area of the incident. To take it to an example—staff at MRCC Stornoway are based on a Scottish Island on the West Coast. We have a full appreciation of the different challenges that Island locations place on responders and casualties, we understand the culture of the Islands and the wider West Coast of Scotland and we have built relationships with all our SAR partners, Category 1 responders, regular Ferries, Fishing vessels, regular pleasure visitors etc. This gives us an embedded presence in the maritime and coastal fabric of our area something which a remote operator who has never lived on the West Coast or Islands can ever obtain, again, much to the detriment of the service. My colleagues in Aberdeen will not be able to replace this through no fault of their own and I would imagine many of them are extremely concerned at having to be responsible for an area they have little or in many cases no understanding of and equally I would be of little use if I were to be dropped into a desk running the East Coast of Scotland regardless of google earth or gazetteers/databases. 7. One of the claims the MCA make is that by re-organising the service they will remove the disparity between areas and ensure that coastguard do more varied jobs. But if we have geographic cells allocated to operators who will only work in that area, then surely the job will remain the same as it is now? After all if local knowledge is important (as MCA now admit it is) then will it not be unsafe to rotate tasks leaving operators with no experience of a particular area having responsibility for it. The original proposal document promises more rewarding jobs for coastguards and better career opportunities yet goes on to describe a model where all the management is located in the MOC and the sub centres will only have operator grades overseen by a single manager. Those working in a day station will be put “out to graze” with little career satisfaction, virtually no chance of promotion on station and a second class mentality. The manning levels suggest a planned minimum exposure to incidents and even the IT part of the risk assessment details a system where search planning (a key coastguard skill) is conducted only at a MOC because sub centres will only be able to view search plans created on our SARIS system. 8. I also wish to highlight another point with the MOC/Sub Centre model which I feel will be potentially dangerous and unwieldy and is in direct contradiction of our current operating procedures whereby the station which receives the initial alert of an incident co-ordinates the response wherever possible. These procedures were refined in light of the AQULIA incident in 2009 where handover of an incident in the early stages led to some confusion and delay. MCA Operational Advice Note 711 (Annex A) refers specifically to this procedure. The situation whereby a day centre may take an initial call for assistance and due to lack of manpower and/or because SAR co-ordination is not the role they are allocated they pass the details onto another centre for the co-ordination of the incident is dangerous, it is proven to lead to errors and again will erode the safety of the service we currently provide. Equally as day stations go offline at the end of a shift then any incidents which they may have been handling (if any as role is uncertain) must be handed over to a remote station in either Aberdeen or Southampton. This will be difficult and is yet another path for errors—it is never easy handing over ongoing incidents even when the oncoming watch are in the same room as you, it would be incredibly hard to ensure that it is efficiently handed over if you do not have the people in the same room as you. It is testament to the lack of understanding of our role that the MCA are willing to fly people constantly round the country to attend meetings in headquarters (either National or Regional) for the value of face to face communications during routine business yet they are able to dismiss this value for SAR co-ordination where life is at stake. 9. I will finish my points on the co-ordination centres with an apparent change in nomenclature for operations room officers which I believe to be nothing other than an attempt to mislead the public as to our role as SAR Co-ordinators. It is referred to in many of the public meeting transcripts available on the website www.mcga.gov.uk (as examples—Brixham p10, Falmouth p13, Swansea p13, Milford Haven p12). It is the term Remote SAR Co-ordinator. I have never heard Coastguard Officers referred to as this before in my 12 years service and I take exception to this term (as do many of my colleagues). I do not consider myself a Remote SAR Co-ordinator as I am, like all my colleagues in operations rooms around the country, a part of the community I serve. Most of the incidents I co-ordinate involve people at some level who I know personally—usually the responders but occasionally the casualties. This is a term which is been used simply to distance us from the community and counter criticism at the lack of local knowledge in the future service. There are too many references to shrug it off as an individuals branding of our role and as these are senior managers in the MCA and they use the term “we” this would indicate MCA sanction. 10. ETVs are part of the committee inquiry and I feel that there are many well informed arguments as to why they should be retained. I simply wish to draw to your attention that, again in my opinion, the cessation of this service will increase the risk of catastrophic environmental damage. This risk may not be so evident in an area like the English Channel where there are suitable vessels able to provide emergency towing stationed nearby. However the risk will be much more evident on the West Coast of Scotland where any suitable vessels (by suitable I mean an ocean going tug with high bollard pull) are many hours steaming from an incident location. Two recent examples are the ASTUTE on Skye and the RED DUCHESS on Rum. The ETV was deployed to both and in both cases MCA made attempts to gain towage services from external sources, in each case the transit time was in the area of 18 hours. I am aware of talks being held locally with Towage companies to try to secure a contract for stationing of a vessel but it is highly unlikely that a commercial agreement will be reached without some state subsidy. There may be room for a negotiated contract to bring more salvage cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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money back to the agency and allow some of the expense to be reclaimed thus giving better value for money but again this would be dependent on the operator’s agreement. 11. As a Watch Manager I have never had cause to task a MIRG team and I am aware that they have not been used often. However I would like to make the point that the procedures for tasking these teams are unwieldy and will tie up the person responsible for overseeing the co-ordination of an incident for a lengthy period. This could explain why they have not been used as often as they might have been had simpler and faster tasking been possible. I can see the benefit of having these teams located round the UK coast and the ability to deploy fire fighting/chemical response/industrial rescue teams to vessels at sea will undoubtedly lessen the risk of loss of life and significant pollution within the UK. I hope that these points supplement my original response and are useful to the committee in the inquiry. April 2011

Written evidence from David MacBrayne Ltd (MCA 67) David MacBrayne Ltd (DML), which incorporates Caledonian MacBrayne and NorthLink Ferries, is the UK’s largest ferry operator in terms of vessels operated and routes served. These routes on the West Coast of Scotland and Northern Isles are subject to some of Europe’s most challenging sea conditions and its 38 Masters and 34 small ferry Skippers are professional seafarers with unrivalled experience of the coast and the types of incident to which they are called. It is also worth highlighting that both Caledonian MacBrayne and NorthLink Ferries are partner Search and Rescue (SAR) organisations as referred to in Question 6. We therefore believe we are uniquely qualified to comment on the proposals for changes to the Coastguard services in the Western Isles and Northern Isles. Our formal responses to the questions posed in the consultation document are attached, but we have taken the liberty of summarising these below. At the outset I should say that David MacBrayne Ltd (DML) welcomes the intent to modernise the Coastguard service, which is necessary and overdue, because we want to see a significant reduction in the number of casualties. However we have five fundamental concerns, centred on our interpretation of the proposals as simply a way of making the Coastguard Service cheaper, when they should be about improving Safety at Sea. Our key concerns are: — The Coastguard Review is wrongly fixated on tasks and costs. The Coastguard’s passion and focus should be on a targeted reduction in the unacceptable level of casualties and pollution incidents in our waters, tied to a formal performance improvement regime; — We welcome the intention to introduce new technology, however the focus of this technology must be on improving services and cutting casualties and pollution: not to cut costs; — The proposed changes to the employment and deployment of people and location of operating bases appear to have ignored the inevitable social and economic impacts they will have on affected communities. As a government agency, the MCA must take responsibility for all aspects of their proposed changes, including the effects on remote and vulnerable communities; — The David MacBrayne Group and its seagoing staff fully acknowledge their role in preserving and protecting life at sea. Not only do our people have vast local knowledge and awareness, but our vessels are always willingly committed to rescue. However, our masters and skippers sometimes feel their knowledge is undervalued, and that they have no say in what should be a continual improvement process to learn lessons from every call for assistance; and — Search and Rescue capability is vital when things go wrong, but prevention of the need for Search and Rescue through the setting of high marine standards supported by effective regulation is even more important. The MCA is silent on its plans for its standard setting and regulatory activities. There are problems with these, and we would like to see these services included in delivery of MCA casualty reduction targets. We recommend that efforts to improve Search and Rescues should be executed in parallel with an external review of the effectiveness and application of regulatory standards. Finally, no mention has been made in the consultation document of the proposals to remove the Emergency Towing Vessels (ETVs) from the North and West Coasts of Scotland. Whilst these vessels were not initially introduced to support our operations directly, but as a result of the Braer incident and to provide cover for tankers transiting the Minches, they do nonetheless now provide critical cover for all vessels in these sea areas. The need for such cover has been evidenced on several occasions since their introduction and there are tangible benefits to justify retaining the service. The proposals also seem particularly at odds with good practice established in the US Coastguard Service and even in Europe, where Germany, France, Netherlands & Norway appear to be establishing a similar capability with ETVs that the MCA is planning to dismantle. We cannot understand this, but presume the change is supported by a risk assessment, which we would like to see as soon as possible. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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If you wish further clariﬁcation on any aspect of our submission, or if you wish to take advantage of the expertise which exists within the group as part of your future deliberations please do not hesitate to contact us.

Response to Consultation on Coastguard Restructuring Question 1: We have set out the changes that would affect the way the Coastguard needs to operate. Are there any other changes and pressures that should be taken into account in our plans for a modernised Coastguard service? Please provide supporting evidence for your comments Response: The David MacBrayne Group welcomes the intent to modernise the Coastguard service. Yet we have five fundamental concerns about the proposals, centred on a reading of the proposals as simply a way of making the Coastguard Service cheaper, when they should be about improving Safety at Sea. — We consider the Coastguard Review to be fixated on tasks and costs, whilst the Coastguard’s passion and focus should more properly be on performance improvement, by which we mean a targeted reduction in the unacceptable level of casualties and pollution incidents in our waters; We expand on this below. — We welcome the intention to introduce new technology. However, the intention to use technology to cut costs is completely misguided. It must use technology to improve its services and cut casualties and pollution; We expand on this below. — The proposed changes to the employment and deployment of people and location of operating bases appear to have been formulated without any reference to the social and economic impacts the changes will have on affected communities. As a government agency, the MCA must take responsibility for all aspects of their proposed changes, including the impacts on often vulnerable communities; We expand on this in our response to Question 4. — The David MacBrayne group and its seagoing staff recognise they have an important role to play in preserving and protecting life at sea. Not only do our people have vast local knowledge and awareness, but our vessels are always willingly committed to rescue. However, our masters and skippers sometimes feel their resources are misused, and that they have no say in what should be a continual improvement process to learn lessons from every call for assistance; We expand on this in our response to Question 6. — Search and Rescue capability is vital when things go wrong. But prevention of the need for Search and Rescue through the setting of high marine standards supported by effective regulation is even more important. The MCA is silent on its plans for its standard setting and regulatory activities. There are problems with these, and we would like to see these services included in delivery of MCA casualty reduction targets. We recommend that efforts to improve Search and Rescues should be executed in parallel with an external review of the effectiveness and application of regulatory standards. We expand on this in our response to question 2. The David MacBrayne Group greatly values the contribution that the Coastguard Service, both permanent and voluntary, the RNLI, helicopter rescue services and other response groups make to preserving Safety at Sea. We also appreciate that modernisation of the MCA, including the Coastguard Service, is necessary and overdue. Taking account of the growing demand for Search and Rescue response mentioned in the consultation, the need for modernisation becomes even more urgent. In sharp contrast, the proposals in the MCA’s consultation seem to be focused solely on reducing the cost of the service. We understand the pressure on costs that falls on the public sector when the economy is in poor shape, but cannot accept the limited objectives the MCA seems to have. Information gleaned from the MCA’s last published Annual Report shows that deaths at the (UK) coast increased between 2008 and 2009. It also shows that the number of fishing vessel crew deaths increased to 13 (a nine year high) although there is pleasing improvement in other UK shipping sectors. It is not clear whether the number of pollution incidents is increasing or decreasing. The MCA is in a position of primacy and responsibility when it comes to ensuring action is taken, and is successful in reducing the number of casualties and pollution incidents. Yet it seems not to have quantifiable performance goals, and, as a result, is unable to plan to achieve improvement for itself, for the UK shipping industry and for the increasing numbers of recreational users of our waters. In the absence of published improvement goals, it is not surprising the MCA’s budget is under pressure. Our urgent plea is that the MCA establishes improvement goals before it concludes its consultation. These goals, not a belief that technology can substitute for people more cheaply, is what will command resources, drive internal performance and attract acclaim for the MCA’s future achievements. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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We have no doubt that new technology, both communications technology and web-based knowledge systems, for example, have a huge contribution to make in the MCA’s operations. But we ﬁrmly believe that a modernised MCA should be using these sorts of technology to improve safety at sea and to make our seas cleaner.

Instead we seem to be facing an increase in short term risk, with lack of deployment of technology in the MCA, compounded by the withdrawal and destruction of Nimrod surveillance technology, delay in deploying improved helicopter surveillance and rescue capability, and a proposal to withdraw the three Emergency Rescue Vessels.

No mention has been made in the consultation document of the proposals to remove the Emergency Towing Vessels (ETVs) from the North and West Coasts of Scotland. Whilst these vessels were not initially introduced to support our operations directly, but as a result of the Braer incident and to provide cover for tankers transiting the Minches, they do nonetheless now provide critical cover for all vessels in these sea areas.

The need for such cover has been evidenced on several occasions since their introduction and there are tangible beneﬁts to justify retaining the service.

The proposals seem particularly at odds with good practice established in the US Coastguard Service and even in Europe, where Germany, France, Netherlands & Norway appear to be establishing a similar capability with ETVs that the MCA is planning to dismantle. We cannot understand this, but presume the change is supported by a risk assessment, which we would like to see as soon as possible.

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

Response:

We do not think it is adequate for the MCA to regard increasing demand for Search and Rescue as a rationale for re-structuring coastguard stations. If demand for Search and Rescue is increasing, ie more lives are at risk, the MCA must recognise that it has a prime role to reduce casualties through actions it must take to reduce risk.

The MCA is the prime regulator of safe marine activity around our coasts. If it cannot take action to prevent the cause of casualties rising, we have to question whether it should exist in its current form at all.

Search and Rescue is actually only a minor part of the interface MCA has with marine organisations such as CalMac and NorthLink, our operating subsidiaries. The impact of MCA’s regulatory regime is very significant, not only in time and license to operate commitment, but also importantly in the cost, flexibility and fundamental competitiveness of our business. We recognise that regulation has a vital role to play in the prevention of loss at sea. We want high standards because these help save lives, align with our values, re- assures our customers and should ensure a level competitive playing field. We are therefore disappointed that the MCA’s regulatory service is not included in the review on which you are currently consulting. We would recommend that this weakness in your arrangements is addressed by an independent, external review to ensure regulatory standards are effective and properly applied to counter what MCA describes as “rising demand”.

We cannot make sense of a proposal to cut rescue services through withdrawal of ETVs at the same time as MCA suggests demand is rising.

The requirement for ETVs can be highlighted by some reported examples of their deployment over the past year: — February, 2011: the Anglian Earl was with a 50 degree list onto rocks in force 7/8 winds. — November 2010: the emergency tug, Anglian Prince, rescued the 1300-tonne cargo ship, Red Duchess, after she lost power in a force seven gale near Rum, preventing a serious accident. — October 2010: the Anglian Prince pulled the nuclear submarine, HMS Astute, off a shingle bank near Skye, potentially preventing a radioactive leak. — July 2010: the emergency tug, Anglian Sovereign, helped douse a four-day ﬁre on the bulk carrier, Yeoman Bontrup, which broke out while it was unloading at the Glensanda superquarry in Morvern. — March 2010: The Anglian Sovereign towed the Wilson Dover to safety after it was disabled during a storm north east of Cape Wrath, preventing the loss of its cargo of fertiliser. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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

Response:

We can offer only a limited response on this question because there is no statement about what performance these centres will achieve. We would be supportive if the reorganisation were accompanied by a commitment to reduce casualties.

We would be further supportive if we could be assured that, when the unthinkable happens, and a ship carrying a large number of passengers and crew is in danger of foundering with all hands on Scottish rocks in severe weather, the MCA can assure us they will organise getting everyone to safety.

The consultation document claims that the majority of calls to the stations which are to be re-structured happen during daylight hours, but that does not negate the need for the service to be fit for purpose during the hours of darkness too. (A recent major rescue operation involving a fishing vessel with 14 crew on board took place in the dark off the West Coast of Scotland.) It should also be borne in mind that in Stornoway and Shetland in particular, daylight hours can vary from around 20 hours in the summer down to around six hours in the winter, and this would have to be accounted for when allocating resources. There are other fluctuating risk factors, such as bad weather, and the occurrence of maritime leisure events which would need to be factored in. It is not clear from the consultation document how you will address these.

Question 4: Our proposals for Maritime Operations Centres and sub-centres, locate these around the UK coastline and makes use of the MCA current estate. What is your opinion on the proposals for the location of these Centres and sub-centres? Please provide supporting reasons for your comments. Do you have particular comments or information about factors that should inﬂuence the choice of sites for sub-centres in either Belfast or Liverpool, or either Stornoway and Shetland?

Response:

In the overall scheme of things, we think centres and sub centres should be located where the MCA can demonstrate they will be most effective at supporting the Saving of Life at Sea. The attention drawn to using the existing MCA estate just points to the purpose of the exercise being focused on cutting costs.

The proposed reduction in operating bases, and the proposal to move away from 24/7 working, both seem to us to be signiﬁcant changes, even if MCA was not seeking to improve Safety at Sea performance in the process of change. We would expect such changes to be validated by appropriate Risk Assessment but have not seen these. We would like to see them, please.

Changes in operating base location and in local employment can have far reaching impacts on the communities where a service is withdrawn. This is particularly true in remote islands such as Lewis and Shetland, where the MCA is an important employer, local economies may be fragile, and alternative employment opportunities very thin on the ground.

We accept the need to provide public services efﬁciently and effectively, but we do not think the MCA should draw any conclusions about operating base locations, until it has properly assessed local social and economic impacts and included these in its strategic options. It is very disappointing to note that a government agency appears to have missed these vital considerations.

Without these inputs, it is impossible for us to give a view on any locational or (un) employment proposition.

Additionally, we have some concern that important knowledge held by Coastguard ofﬁcers were lost to the MCA if key people did not wish, or were unable, to relocate to other centres.

Question 5: In your view, are the new roles and responsibilities for Coastguard ofﬁcers at different levels in the proposed structure appropriate to the tasks that need to be delivered? Please provide supporting reasons for your comments

Response:

As stated elsewhere, we strongly believe that the MCA needs to concentrate on the performance it aims to achieve in reducing losses and casualties at sea, reducing the impacts of marine pollution, and therefore setting appropriate targets. Only when it has done this can MCA decide what tasks it needs to undertake, what organisation it needs to get the tasks delivered, and what resources it should therefore be given by government to achieve its targets. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Question 6: Under these proposals the regular Coastguard working in Maritime Operations Centres and sub- centres will draw more heavily on the local knowledge of geography, community and coastal risk provided by the network of local volunteer HM Coastguard Rescue Teams and increased liaison with partner SAR organisations. Do you agree that this is the best way to ensure the availability of such knowledge? Please provide supporting reasons for your statement Response: We do not agree. To be effective, Search and Rescue must have the right resources delivered to the critical location in the shortest possible time. Capable liaison and good local knowledge (of geography, community and coastal risk) are but two important aspects of this. They will not in themselves assure successful rescue, for example if there are no tugs available to pull a stricken tanker away from rocks. It seems to us fundamentally weak to have a system where local knowledge only begins to be assimilated after a call for help comes. For a coordination centre to be effective in deploying resources fast, it must surely have all necessary locational knowledge in readiness for an emergency call coming in. Knowledge can be continuously improved if every possible lesson is learned from previous call outs and incidents. The David MacBrayne Group, through our “CalMac” and “NorthLink” brands, operates 35 vessels sailing between 59 ports on 26 routes. That adds up to some 134,000 sailings per year in the waters off Scotland’s coasts and islands. Our 38 Masters and 34 small ferry Skippers who continuously ply some of the most challenging waters off the UK are often involved in response, and have a huge accumulated knowledge of geography, community and coastal risk, but there is no apparent recognition nor assimilation of this knowledge by the Coastguard Service, through post incident review with the response partners. We have some concerns that, due to the geography and cultural diversity of the areas we operate in, such as the use of the Gaelic language in place names in the West Coast of Scotland, a greater depth of local knowledge is required than is proposed. Incidents at sea would only be exacerbated by the need to rely on someone several hundreds of miles from the scene of the incident with little or no knowledge of the area in which the incident was taking place. For someone in icy waters, the delays that this could cause could easily be the difference between life and death.

Question 7: In your opinion, will the proposed strengthening of management for the Coastguard Rescue Service organisation, including the introduction of 24/7 on-call Coastal Safety Ofﬁcers, provide a more resilient response service to those in need in UK coastal areas? Please provide supporting reasons for your comments Response: We think that the proposals may result in a reduction in operating costs of the service. We do not consider a more resilient response as an acceptable goal in itself. Our response to question 1 provides the rationale for organising the Coastguard Rescue Service around casualty reduction and performance improvement. In any case, it is very hard to believe that the introduction of 24/7 on call Coastal Safety Ofﬁcers is going to counterbalance the huge capability lost from withdrawal of the ETVs. March 2011

Written evidence from Liverpool Coastguard (MCA 68) H.M. Coastguard Radio Equipment Rollout (RER) Upgrade In respect of the equipment upgrade to our Integrated Coastguard Communications System (ICCS), this is the system that give us access to the radio aerials and also the telephone system. We also have pager information and information of General Interest in here, such as harbour master contacts etc. The stations upgraded so far are Solent, Portland, Milford, Swansea, Liverpool and Holyhead. The rollout has been stalled slightly in that headquarters are waiting for a patch to be tested and installed into the system. This is the item that will give all stations the flexibility to connect to any MRCC in the United Kingdom. The server has space for five additional databases as well as your own. When installed the patch will enable each station to “Dial into” three stations North and two stations South of themselves or vice versa, or even choose which five stations they would like to be connected to, albeit only one MRCC at a time. This will be fitted to all 18 current coastguard stations. If that is not flexibility and contingency planning then I don’t know what is! This is all that you would need to assist colleagues in a busy period anyway. There is absolutely no need whatsoever for the set up demonstrated in the current consultation document. The patch is intended to be in place at all six stations mentioned above by the latter part of May 2011 and once installed we are good to go with the rest of the rollout. The timetable, as it currently stands, for the rest of the country is as follows: Clyde, Belfast and Stornoway partnership will commence preparation and upgrade works last week in May 2011 and is scheduled to complete end of July 2011. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Aberdeen, Forth and Shetland partnership will commence preparation and upgrade works middle of August 2011 and is scheduled to complete end of September 2011. Falmouth and Brixham partnership will commence preparation and upgrade works first week in October 2011 and is scheduled to complete last week in November 2011. Dover, London and Thames partnership will commence preparation and upgrade works end of November 2011 and is scheduled to complete middle of February 2010 (This will include a stoppage for Christmas and New Year Break). Humber and Yarmouth partnership will commence preparation and upgrade works last week in February 2012 and is scheduled to complete first week in April 2012. The programme has slipped because the agency have been waiting for the new patch to arrive. Once the patch is installed, as the stations are upgraded they will join the list of stations whose aerials can be remotely taken over by similarly fitted centres. There is flexibility in the system in that you can choose which stations you wish to be connected to which will give added resilience within the system. This will then give us the network resilience in that stations that are busy can ask other stations anywhere in the country to ease their workload and take over their aerials and also handle incidents for them. If that is not resilience then I don’t know what is!! To put it simply, Liverpool could take over Stornoways aerials or Falmouth or Dover or anywhere!! Why do we need to go to the expense of two new MOC’s unnecessarily and spend yet more taxpayers money when we will already have the resilience that is being so trumpeted about by the MCA Senior Management and the Government? It is my firm belief, and judging by the proposals being sent into the consultation process by my colleagues and peers, that the proposed set up is distinctly flawed and inherently dangerous. The world is a rapidly changing and volatile place, as is evidenced by the current climate in the Middle East countries. It would be totally misguided and foolish to erode the current excellent communications network that we have around our coast in the current political and global climate. The United Kingdom Coastguard Service should reduce to nine (9) or possibly twelve (12) stations and no less. We are an island nation and as such our coast changes as you go around. More and more members of the great british public are choosing to spend their holidays at home rather than go abroad. The vast majority of them choose to visit the seaside and also the English Lake District. They should do so safe in the knowledge that if something goes wrong and they suffer a mishap, help will be on hand virtually instantaneously from professional coastguard officers who intimately know the area that they are holidaying in and can task suitable and appropriate resources instantly to their location. Ferry and freight traffic is increasing exponentially, as is oil and gas exploration and production. Offshore Renewable Energy Installations (OREI), are either under construction, being extended or actually complete and producing. The proposed Round 3 construction of OREI all around the UK continental shelf, the proposed floating Liquefied Natural Gas (LNG) Terminal in the Eastern Irish Sea and the construction of the Post Panamax Terminal in the Port of Liverpool. All these things are going to contribute considerably to the number and size of vessels utilising our ports and also the number of personnel working offshore in a hostile environment. We need to have processes in place to deal succinctly and eruditely with problems that may, and will arise. The proposed plan currently before Parliament will not give us that scope or flexibility. There is a gathering sense of disquiet amongst the shipping companies and offshore operators that they are being abandoned by a government who is looking to save a few pounds by slashing the coastguard service. It is a well known fact that H.M. Coastguard, in its current form of 18 stations, costs every taxpayer in the U.K. just £1.33 per annum. Even the Prime Minister, Chancellor of the Exchequer or the Shipping Minister cannot say that this is not good value for money! In respect of the Coastguard Rescue Service (CRS), the last thing that Maritime and Coastguard Agency needs is another layer of management. What the Sector Managers actually need is assistance, between them and the CRS so that all their administration workload is taken from them and allowing them to concentrate solely on training the CRS. The agency have highlighted this as a risk in their document so let us address it easily and cost effectively. The MCA is currently top heavy with managers and quite honestly we could do a lot better by shedding some of the more senior posts and indeed some posts in headquarters, at no cost to Operational efficiency but at a great saving to the wage bill and therefore the overall agency savings! I question what, if anything at all, the current crop of Senior Managers within the MCA bring to the party? If the current consultation plan goes ahead then we will be sacrificing front line Operational Officers in the Maritime Rescue Co-ordination Centres (MRCC’s), the Shipping Ministers words in the National Press not mine, for the sake of keeping our current crop of managers and indeed inventing more, as the proposed consultation will do! This is sheer folly and madness. What we need to do is cut unnecessary bureaucracy and get rid of managers who put their own spin on things and contribute nothing concrete to the efficiency and output of the agency but place a drain on the salary bill that could be more effectively utilised elsewhere. There is absolutely no necessity whatsoever to tinker or amend the current heirarchy of the MRCC staffing. It functions well as a unit and is a proven system. What would benefit H.M. Coastguard is removing the entire Regional Management Structure, with the exception of the Regional Resilience Officer, and seriously look at how we can cut the over burdened bureaucracy that currently exists in MCA Headquarters. The MCA have already spent a huge amount of money on Planning Permits and having architects draw plans up for the new MOC at Daedalus. The plans are so detailed that they actually show the type and number of plants that will be placed in the car park! Estimated cost at todays prices is in the region of £250,000. 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MCA have also purchased three large servers from the I.T. company “Viglen” in preparation for placing them in the new MOC’s. The company had placed a press release on their website which announced that they were pleased and happy to have secured this contract with the MCA and looked forward to a long relationship with them. Inside 12 hours, and after frantic telephone calls the press release was removed from the companys website! Why was the press release removed and why has the agency purchased three new servers for a concept that is just that, a concept and not a reality!! It sounds like the whole consultation process is a sham and that the plan is a done deal and will be pushed through regardless of the cost to the country or in human lives! The Chief Coastguard, Mr Rod Johnson, has stated publicly, most recently at the Search and Rescue Conference at RAF Valley this year, that he will be the last ever Chief Coastguard and that if this consultation plan does not go forward and be delivered then he will resign. I firmly believe that no only he should go but others also. There is most definitely a long line of Operational Coastguard Officers who will all provide them with pens! March 2011

Further written evidence from Liverpool Coastguard (MCA 68a) Email from Liverpool Coastguard to Louise Ellman MP dated 12 February 2011. Mrs Ellman, PSA. Risk assessment sections 8 and 9 have inaccurate information about Liverpool MRCC site. These two sections relate to the rationale of the sub centres. In comparison to the other centres the information is scant and inaccurate. Below we the PCS of Liverpool Coastguard have asked Sir Alan Massey to correct the information. To us, the lack of operational knowledge of their own site means that they have no intention MRCC Liverpool having a place in the future structure Regards Email to Sir Alan Massey from Liverpool Coastguard dated 12 February 2011 Dear Sir Alan Massey, As there is no author or owner of the risk assessment I would like to make you aware of the inaccuracies of the report in relation to the site at Liverpool MRCC. Section 8 The site has a Marine office as stated and a local radio mast. It also has: operational office for CPSO Donald McDonald Crosby CRT and Met Office observation site which is linked to Exeter The risk assessment does not mention that we have SAR responsibility for the IOM territorial waters. This lack of understanding on what the Liverpool site makes us feel uncertain that we were given due consideration as a MOC or sub-centre. This public information needs correcting for people to make an informed response. Yours respectfully, Liverpool Coastguard PCS. Email from Sir Alan on Feb 24th 2011 Dear Liverpool PCS branch, Thank you for your comments relating to the documents published on 11 February 2001. The section you refer to (Section 8) provides a narrative overview. It is not an inventory of each location and does not detail the number of surveyors accommodated in respect of any other location. The document mentions Liverpool’s co-located marine office, radio site and its geographical relationship with the waters of the North Channel and Irish Sea. It would be inappropriate to now retrospectively incorporate any additional information for Liverpool without turning the document into a forum for all stations to add their details. This is not the purpose of the document. The “significance” of the Belfast Marine office comes from its being the only MCA Marine Office situated in Northern Ireland and is not related to the number of surveyors it accommodates. Your comments have been accepted as a consultation response and will be taken into account in deciding on the relative case between Belfast and Liverpool at the end of the consultation period. February 2011 cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from Gill Palmer (MCA 70) Introduction 1. I am a member of the public and a recreational sailor of both sailing boats and heavy displacement motor boats. I have been involved with this hobby ever since I was a small child and I am now over 50. 2. I oppose the MCA’s proposals to modernise the Coastguard for several different reasons, some of which I intend to discuss below. 3. I do not wish to comment on the MCA’s other two proposals regarding the Emergency Towing Vessels (ETVs) and the Maritime Incident Response Group (MIRG.) 4. I very much welcome the Transport Committee’s decision to conduct a full Public Inquiry into the MCA’s proposals for modernisation of the Coastguard. I think it is exactly the right step to have taken. 5. My formal Response form to the MCA’s consultation is attached to this Submission as an Appendix. I have found it very difﬁcult to formulate my Response to that because the questions are “loaded,” trying to lead me to conclusions that I do not agree with and do not reach on my own. Consequently, I think that the MCA’s attempt to harness me into an intellectual straightjacket has resulted in a Response from me which is not the best that I could have produced. Also, their Word response form has been set up so that the number of words one can use in reply to each question is limited, meaning that I feel my replies are often inadequate. Please accept my apologies for these limitations.

Summary 6. I think that the MCA’s proposals to modernise the Coastguard are deeply flawed in several material respects, as I have tried to explain in my Response to the MCA’s consultation document. 7. I think that the MCA have seized upon the idea that centralisation of an emergency service will somehow make it more efficient as well as creating savings. If you start from a woolly-minded premise, you are bound to reach a woolly-minded conclusion as well. Also, “efficient” and “effective” are not the same notion. It does not matter if something is inefficient as long as it is effective, in my view. 8. I think that the first fundamental weakness in the MCA’s proposals is an unwillingness to admit that they are trying to shoe-horn the facts to try to get them to fit into an untested theory about a centralised MOC. 9. I think that the second weakness is that the MCA is falling into the trap which is universal throughout the civil service. The civil service pay rules are so rigid that the only way to offer people pay-rises is to “promote” them into quasi-managerial roles which have only been invented in order to justify the pay-rise. The only real solution to that is a wholesale reform of the way that the civil service functions but it is not within the MCA’s remit to try to do that, even though everything would be much easier for the MCA if the civil service were reformed properly first.

My Concerns 10. At the moment, Yorkshire Police are de-centralising their own command and control arrangements because the Police and the public alike know that their experiment with centralisation has failed. 11. Exactly the same thing happened with the Fire Service. There were numerous complaints about the fact that despatchers in Hampshire will not know enough about the geography of Dorset or wherever. In the end, the present Government killed the whole thing off but I suspect that they did so mainly only in order to try to prevent the scheme from haemorrhaging even more public money than had already been wasted. 12. When two other major and expensive experiments with centralisation have failed, what persuades the MCA to imagine that their own ideas will not simply be the third failure in a row? 13. If anything, trying to centralise the MCA’s SAR efforts are even more complicated than trying to do it for the other emergency services because the possible search areas are often much wider for the Coastguard than for the others plus the sea moves, which terra ﬁrma does not! 14. Also, the majority of the people who need a policeman or a ﬁreman urgently will be using a telephone to summon assistance. With the Coastguard, it is much more complicated because there are so many different ways via which people in distress can contact the Coastguard, either directly or by relay. 15.1 Where is Clovelly Bay? A privately owned boat called Yarmouth Navigator suddenly sank in Clovelly Bay on the night of 30 January 2011, killing her skipper. The relevant Clovelly Bay is an obscure little part of the Cattewater. Where is the Cattewater? It is on the eastern side of Plymouth Harbour. However, somebody who does not know the details of the relevant local area could be forgiven for imagining that Clovelly Bay might be somewhere in Wales. 15.2 With Yarmouth Navigator, a witness realised that she was about to sink so he called Brixham MRCC from his own RIB, using a hand held VHF radio that did not have a long range and did not have GMDSS either. The witness saw the Navigator’s skipper inside her wheelhouse and shouted to him to abandon the cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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vessel immediately. It was dark, the skipper was seen to leave the wheelhouse and then the boat sank. The witnesses looked for the skipper, hoping that he had managed to escape from the Navigator and that he was in the water, on the surface. 15.3 Brixham MRCC wasted absolutely no time. Everyone agrees that they were superb. They knew instantly exactly where the incident was happening. They sent three volunteer Coastguard rescue teams with floodlights and ropes, Plymouth’s big, all-weather RNLI lifeboat, a small, locally based volunteer lifeboat, a Border Agency boat that happened to be in Plymouth Sound at the time, a SAR helicopter with night vision and heat seeking equipment, plus Brixham MRCC also sent police divers. No effort was spared and not a moment was wasted because everyone knew that the skipper could not survive for long in the sea in winter. The sea is viciously cold by January and it does not start to warm up again until about June or July. 15.4 There was no sign of the skipper that night, despite the most strenuous possible efforts to find him. Unfortunately the police divers found his body the next day, down below inside the sunken hull of the Navigator. Nobody knows why he went below instead of abandoning the boat. However his family do at least have the comfort of knowing that everything possible was done and that it was done without a moment’s delay. 15.5 There is also no danger of anyone trying to sue the Minister for Transport because the evidence is that HM Coastguard wasted absolutely no time and could not possibly have sent any more help than they did, all of which arrived fast enough to be in with a realistic hope of being able to find the skipper in time to save his life. 15.6 The dead skipper was a man called Commander Robert Tallack. I did not know him personally but I know the witness who raised the alarm and I have also known Yarmouth Navigator and her previous owner for many years. Cdr Tallack had been a sea-going deck officer with P&O for several years. After he retired from P&O, he set up a marine consultancy called IDG Maritime and did quite a lot of consultancy work for the MCA. There is no way that Cdr Tallack was “just some twit of an amateur yottie who did not understand what he was doing.” 15.7 I simply do not believe that the MCA’s consultation document describes a scenario in which a Coastguard call centre 200 miles away, staffed by people with little or no relevant, personal local knowledge, could have done anything like as good a job as Brixham MRCC did on the night when Yarmouth Navigator sank. The call centre might just as well be located in India for all the use that it would have been, frankly. 16. I am greatly indebted to Members of the Transport Committee for raising similar concerns during your earlier oral evidence meeting with the senior team from the MCA. I hope that you will investigate the sort of scenario that I have described during your Public Inquiry. The Transcripts of the public meetings convened by the MCA demonstrate numerous examples of similar fears, raised by Master Mariners, commercial fishermen and suchlike. This is not a case of a few amateur yotties complaining and worrying simply because we have nothing better to moan about at the moment! 17. I am aware that HM Coastguard went on strike for the first time in their history in 2008. I had heard that HMCG Officers are not well-paid compared to the response staff in the other emergency services. However I was not aware until very recently that their Coastguard Watch Assistants, Watch Officers and Watch Managers are on the three lowest pay-grades in the whole of the MCA. I had not known that the pay problem is so acute. 18. This is exacerbated by the fact that the MCA is very poorly paid compared to many other departments and agencies within the civil service. MCA staff all enjoy 30 days of paid annual leave each year, in addition to Public Holidays, because the extra annual leave was agreed between the Unions and the MCA some years ago as a quid pro quo for the very low pay. (I understand that the reason for the appallingly poor pay is not because the MCA’s Managers are stingy. It is something to do with the fact the MCA’s payroll comes out of the DfT’s XYZ Budget whereas the DfT’s ABC Budget pays the staff of the Marine Accident Investigation Branch at a substantially higher rate.) 19. I strongly suspect that the real reason for the MCA’s current proposals is that they have tried to find a way of improving the salaries of the HMCG staff. However, the civil service pay-structure is so rigid that the only way the MCA can offer them higher pay is by promoting the HMCG Officers concerned. 20. Financial constraints are now such that it is impossible for the MCA to indulge in a bit of “job-creation and promotion” unless they make a substantial number of the existing HMCG staff redundant. The MRCCs are all too often under-manned as it is, so reducing their manning levels still further necessitates closing them altogether. 21. If you close the MRCCs, you have to relocate the workload and try to handle that from somewhere else. At the same time, you can’t pay the HMCG officers more money unless you are seen to promote them into higher-grade jobs. I think that trying to accomplish all this has spawned the tortuous idea of somehow trying to centralise the HMCG workload into a new concept called an MOC. 22. I can well understand that an MOC seems to be the only way to try to tackle the problems that I have described above. However I think that what then happens with a small team of “concept designers” is that instinctively, they do realise that the concept is seriously flawed but there doesn’t seem to be another way of trying to fulfil the MCA’s goals. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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23. Human nature being what it is, I think the designers then become fed up with the concept precisely because it is so tortuous. From there, it is but a short step to trying to gloss over the ﬂaws instead of admitting them, explaining what the underlying problems really are (and my own suspicion is that it is salaries) and asking whether anyone else can suggest anything that will solve all the various strands of the problem? There is no harm or shame in admitting defeat but civil service Managers are usually reluctant to do so, fearing that it will imply that they are incompetent. 24. I hope very much that the Public Inquiry will focus on trying to discover what the underlying problems really are. I think that if the Members can get to the bottom of that then you will have a realistic chance of making recommendations that will try to ﬁnd solutions to the problems and will assist both the MCA and the Minister in working out how best to solve them satisfactorily. 25. I think that the MCA’s present proposal simply gets rid of one problem by creating ten others and by creating a situation that is potentially life-threatening if you are unlucky enough to become a casualty.

Conclusion 26. Alas, I cannot offer any sensible suggestions about how to solve the problems but I hope that at least I might be able to help with identifying what some of them are. I don’t think that the MCA are attempting cost- cutting per se. I suspect that it is really all to do with the salaries but that, for reasons I do not know, the MCA’s senior managers are unwilling to admit the real truth of this matter in public. 27. I am very grateful to the Members of the Transport Committee, and to your staff, for taking the time and trouble to hold a Public Inquiry and to invite and consider comments from anyone with an interest in this subject. March 2011

Written evidence from Robin Ward (MCA 71) 1. I write as an individual who lives, and regularly sails/canoes/walks/etc, along the North Coast of Scotland. 2. I ﬁrstly write to object to the proposal to remove 24/7 coastguard cover from the coastguard stations in Stornoway and Shetland. 3. My wife and I live on the North East Coast of Scotland and have been sailing our 30 foot yacht on the North West Coast of Scotland since 1982. We regularly cross The Minch from our mooring on Loch Torridon. It is a very beautiful but very dangerous area for amateur sailors such as ourselves. So far, we have been lucky enough not to have needed to call upon the coastguard for a mayday or pan-pan emergency. However, having a 24/7 locally knowledgeable and expert coastguard service immediately available in the event of our needing one is a vital factor in our desire to continue to sail in this area. IF the 24/7 coastguard cover is removed from Stornoway and/or Shetland then additional lives WILL be lost at sea in Northern Scotland. I do not want ours to be two of them. 4. I secondly write to object to the proposal to not renew the contact for Emergency Tug Vessels (ETV’s) in September 2011. I think the ETV’s are an essential means of helping to preserve the high quality environment that attracts holiday makers such as ourselves to the coastline and seas around Northern Scotland. It only needs one major pollution incident to do enormous damage of our beautiful but fragile ecosystem and millions of pounds worth of damage to our economy. In my opinion, our country cannot afford NOT to have the service of these ETV’s. March 2011

Written evidence from MRCC Clyde (MCA 72) On 25 August 2010 MRCC Clyde was in receipt of an e-mail from Keith Oliver (Search and Rescue (SAR) Resources Manager) for the MCA in which he lays out the RER (Radio Equipment Replacement) timetable for the Coastguard service. At that time, it was noticed that the MF (Medium Frequency) Radio, PW (Private Wires) lines, linking the MF aerial on Tiree to the Operations’ Room at Clyde were to be transferred to Belfast MRCC. Our IT senior management were contacted at the time and we were reassured that the routing of the lines was immaterial as every MRCC would have access to the equipment—albeit a strange decision since, up till this point, Belfast MRCC has only had an MF watch keeping receiver. The pricing of BT’s Private Wires are by Kilometer and there can be no saving in costs as Belfast is 220 kilometers from Tiree while Clyde is only 140 kilometers as the crow ﬂies, the distances by BT Private Wires will be much longer to Belfast as the lines will be routed through mainland Scotland. This arrangement may be workable with regard to voice reception and transmission, but will not apply to the use of MF DSC (Digital Selective Calling). These transmissions will go to Belfast and not Clyde. This, in cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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effect, will mean that Belfast will assume co-ordination of Search and Rescue (outside VHF coverage) in the Clyde SRR (Search and Rescue Region).

It is also noted on page 10 of the RER timetable that Belfast would broadcast the MSI (Marine Safety Information) on MF, which, at present, is part of MRCC Clyde’s operational responsibility. Since this information was published in August, and the Consultation Document was not published till December, one can only assume that the decision had already been take to close Clyde MRCC and keep Belfast MRCC.

We have been assured by all MCA management up to the Chief Executive that the Consultation Process was not a “done deal.” In fact, Inverclyde MP, Mr. David Cairns had a meeting with Mr. Penning earlier this year, in which the Minister assured him, that the future of Clyde MRCC was, by no means a foregone conclusion. To make matters even more interesting, there is now evidence that the future of Navy Buildings may change and, although the Royal Navy may pass on ownership/stewardship to another agency, it may very well remain as a location for Clyde CG.

Once again, the integrity and truthfulness of the MCA senior management must be called into question and these underhand tactics must be stopped immediately. One more thought—does Liverpool MRCC have any idea that Belfast MRCC has been so favoured?

Again there has been no staff consultation, as with VHF Direction ﬁnding. This equipment transfer must be stopped immediately.

To all addressees, this is a matter of some urgency, as the timetable for these equipment upgrades has been brought forward from mid September to start on 6 May, which is right at the end of the Consultation Period. March 2011

Written evidence from Matthew Mace (MCA 73)

1. Most current Coastguard Watchkeeping Ofﬁcers accept that there is need for change and some have been pushing for it. The industrial action, which has involved strikes, has still not been resolved. The main area of dispute is the low level of pay that Coastguard Watchkeepers of all grades earn for the current work they do and the responsibilities that they bear. The proposals in the consultation will do nothing to address this. The consultation leapfrogs the issue with a vague promise of better pay, but that will be for those that remain (approximately half the existing staff) and will be for jobs with even more responsibility. This is an important point of context that should be remembered.

2. The consultation document is vague on many points and is downright misleading on many others. In particular: 2(a) Statements such as the “system which is some 40 years old” pages 7 and 15. The only thing that is 40 years old is the change from visual lookout to radio watchkeeping using remote sites. The numbers of stations has steadily reduced over the last 40 years after previous reviews and the equipment has been upgraded or renewed several times. 2(b) Loading. The graph used to demonstrate existing “loading”, “demand” and “workload” by time, on page 17 is purely based on the time a button on a keyboard was pressed to create an incident. It does not measure the duration or severity of the incident. Yet this graph in particular is used to show how “busy” stations are and forms the basis of much of the consultation. In my experience night time incidents tend to be more complex and last longer because they are more likely to be commercial vessels that only request assistance when they really need it. They operate further offshore in deeper and rougher water, while any resources available take longer to get on scene due to the distances involved and their reduced night time readiness state. I only have access to data from MRCC Aberdeen but the graph I have produced (below) and using only SAR incidents, shows the difference that taking account of duration of incidents makes. At the “busiest” hour of the day (2–3pm) there are just over twice as many incidents ongoing (84) as start (38). At the “quietest” hour of the day (5–6am) there are seven times as many incidents ongoing (28) as start (4). The “busiest” hour is over nine times as “busy” (38 compared to four incidents) as the “quietest” hour when only accounting for start of incident. When taking into consideration the duration of incidents this difference is reduced to three times (84 compared to 28 incidents). I am not claiming that this measures workload (unlike the consultation document!), but it does smooth out somewhat the peaks and troughs. If the MCA wanted to accurately measure workload they could. They could take into account duration and severity of incidents as they did the last time we went through a major review—before the closure of Pentland, Oban and Tyne Tees Coastguard stations. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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MRCC Aberdeen. Number of SAR incidents commencing and ongoing by hour for the 6 months January to June 2009 90

Number of times an incident commenced 84 80 within the hour Number of times an incident is ongoing 78 within the hour 73 70

63 63 62 60 58 58 58 56

50 51 51 48 45 45 40 38 38 36 37 34 31 32 30 30 31 30 31 28 27 28 25 25 24 23 21 21 19 20 20 18 15 15 13 12 11 12 9 10 9 10 4

0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 8 9 0 1 2 3 0 0 0 0 0 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 2 2 2 2 Hour of day

2(c) Costs. Again on page 17. Quote—“Peak periods at the busiest stations are over 20 times as busy as the quietest stations at periods of lowest activity, yet the latter will have the same number of officers on duty.” The consultation document measures how “busy” a station is by how often and at what time a button on a keyboard was pressed. The accuracy of that has been disputed above. The number and grade of staff on duty at any Maritime Rescue Co-ordination Centre (MRCC) over any 12 hour shift is currently based on a dynamic risk assessment of the staffing level required given the historical demand at that time of year and day, together with predictable events such as school holidays, programmed events and medium range forecast weather. Following these risk assessments there is no way that the “quietest” and “busiest” stations would have the same number of staff on duty and it is a lie to say so. When risk assessments allow, any staff not required to be on watch can undertake other duties such as training, liaison visits etc. 2(d) Resilience. It is true, under the present system, that if both MRCCs in a given pair are affected by a problem then communication links cannot be transferred to another station. This would lead to no, or very limited, service provision to a significant part of the UK coast. When all the equipment is in the two MOCs as is proposed, they will effectively act as a pair. Should a problem affect both those sites then there will be no service provision to the whole UK coast. This would hopefully be a very rare event but the consequences would be dire. You do not increase overall resilience by concentrating equipment and resources into fewer sites. You do it by increasing the numbers of connections between existing sites to allow for a more distributed workload over many routes. There is also no mention in the consultation document of a third backup centre to the two MOCs but it has been mentioned in some of the public meetings. 2(e) Connections to radio sites. It is not clear what connections each MOC will have to the coastal radio sites. If each MOC had direct access to every site throughout the country that would be great. However what is intended, I understand, is that each MOC will be connected to every site in its part of the country and a selection of key sites in the other half. Should a MOC suffer a major problem then the remaining MOC will provide a full service to one half of the country and a reduced one to the rest. 2(f) Shift patterns. It is claimed that the current pattern is rigid. It is only as rigid as the staff working it. Many Watchkeepers already swap shifts around in order to cover the staffing levels that are required as a result of the risk assessment and consequently reduce the overtime cost. On this station the overtime is invariably caused by short notice staff sickness which any system has difficulty in coping with. 2(g) Changes to the Coastguard Rescue Service. I am less concerned by the changes proposed here. However, it does seem to be becoming a top heavy structure. The main problems that current Sector Managers face are to do with too much paperwork and not enough paid training hours allocated to the Coastguard Rescue Officers. Neither of these are addressed in the consultation. 2(h) Part of the changes to the Coastguard Rescue Service is that they would deliver the co-ordination function for land-based incidents. I think that this would be an improvement but it would have to be very carefully defined, particularly as to who is responsible for determining the area(s) to be searched. The new MOC or sub-centre would still be far better placed to co-ordinate the actions cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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of any vessel or aircraft assets involved along the shoreline even if they were not responsible for determining the search area(s).

The future—assuming we go down the route proposed 3. It would appear to me that the number and location of stations required is being driven by cost rather than need. The MCA may well admit to this if pressed. Other than being on the coast within a reasonable catchment area for future recruitment and with good telecommunication and transport links, the location does not matter. This however will be a real local issue. What does really matter is the number of sites remaining and the period they are open for. As an experienced Watch Manager who hopes to remain a watchkeeping Coastguard for quite a few years yet, I cannot stress enough how important it is that any station remaining open does so 24 hour a day. If stations are open for less, then there has to be a hand over to, and from, a 24 hour station twice a day. This cannot be face to face and cannot involve any paper information such as chart plots etc. Important information will be lost and it is so unnecessary. Make every station a 24 hour station. Each station retains full defined responsibility for a stretch of UK coastline. Using risk assessments (like now) adjust the manning for day/night and seasonal demand. Reduce the proposed MOC manning to account for this but keep the 24 hour Shift Leader and possibly all the Team Leader posts at the MOCs. Decide how much equipment is needed/can be afforded and where best to install it. Interconnect the remaining stations as much as possible to provide resilience. Two MOCs each with 3 x 24 hour sub-centres would be a much better arrangement than two MOCs with 2 x 24 hour stations and 5 x 12 hour stations. 4. Pay levels and details of working patterns will be crucial. The historic low pay has to go. Pay levels in the new structure will have to be increased by at least 50% for equivalent work in order to correct the long term slippage, reflect the enhanced work and encourage new employees with the right skills and attitude. We are already seeing evidence of Coastguards deserting the sinking ship, particularly at stations that are to be closed under the proposals. Ask what the current full-time staffing level is at Yarmouth or Forth MRCCs compared to what it should be if there were no vacancies.

Emergency Towing Vessels 5. They are costly but so are the consequences of a large vessel spilling oil cargo or bunkers into the sea. The reasoning behind their inception has not changed. They do other work such as civil hydrography and could do much more such as cadet training. A straight forward cost/beneﬁt analysis should be undertaken by an independent body and the results accepted by the Government.

Maritime Incident Response Group 6. For the numbers of times these groups are used and the difﬁculties in deploying them, particularly in more remote areas, I would suggest that they can no longer be justiﬁed. March 2011

Further written evidence from Matthew Mace (MCA 73a) I am an experienced Coastguard Ofﬁcer at MRCC Aberdeen and I offer you some observations on the consultation from my perspective as one of the persons responsible for delivering the services to the public. I hope that you will respond to the consultation on behalf of your constituents. The consultation document can be found at: http://www.mcga.gov.uk/c4mca/consultation_on_the_proposals_for_modernising_the_coastguard.pdf and supporting information at: http://www.mcga.gov.uk/c4mca/mcga07-home/shipsandcargoes/consultations/mcga-currentconsultations/hm_ coastguard_proposals_for_modernisation_consultation_2010.htm I would also urge you to consider signing EDM 1256 if you have not already done so.

My Observations Chapter 2 Resilience—It is claimed that concentrating staff and equipment into far fewer centres will improve resilience. This ﬂies in the face of current thinking that the most resilient networks are those which are widely distributed and highly interconnected. Currently both stations in a given pair have to be affected before there is a complete loss of service. The MCA is proposing to concentrate all equipment into two stations. The likelihood of both those stations having a problem is surely the same likelihood as both stations in a current pair. However the consequences would be far greater—a nationwide failure instead of a local/regional failure. The concentration of equipment into two sites also places greater reliance on the BT network. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Loading—The graph showing demand by time (p17) is only based on the time the incident started. It does not take into account the duration or severity of incident. Data that takes into account duration of incidents markedly decreases the difference in loading between day and night. Night time incidents tend to last longer because there are not as many short duration beach/cliff and close inshore pleasure craft incidents at night. Night time incidents are much more likely to involve commercial shipping and ﬁshing vessels which will be operating much further away from shore and in poorer weather conditions. These incidents are more complex and take longer due to the distances involved.

Costs—The manning of stations is already adjusted on a day to day basis based on predictable demand using a risk-assessment tool. This has been the case for the last ﬁve years at least. Predictable peak periods at the busiest stations are covered by enhanced stafﬁng. Quieter periods allow staff to come off watch to do training, attend courses etc.

Chapter 3

Maritime Operations Centres (MOCs)—The consultation document states “Maritime Operations Centres would be linked directly to all Coastguard aerial sites …..”. If each of the MOCs was connected directly and independently to every Coastguard aerial site that would be the best possible arrangement with only two MOCs. However the consultation document is misleading. Senior management have conﬁrmed that each MOC will be directly connected to every Coastguard aerial site in their half of the UK and also connected directly to a selection of key sites in the other half. Therefore if a MOC fails normal service will be maintained in half the UK but the rest of the UK will suffer reduced service.

Regional Sub-centres—Nationally ﬁve sub-centres are proposed which would be staffed during daylight hours only. Responsibility for SAR at night would be handed over to the MOCs with a return handover from the MOCs to the sub-centres the next morning. These handovers will cause problems particularly as they cannot be face to face. Information will be lost. All sub-centres must operate 24h a day, giving the seafarers and public who rely on the MCA a consistent service.

Chapter 4

Location of MOCs and sub-centres—The location of the MOCs and sub-centres is not as important as the numbers of them and how long they are open for. Their location will however be a very important local/ regional issue.

Watch Levels—In the consultation document there is mention of an analysis of current workload but there is no evidence provided. I understand that the analysis is purely the graph in Chapter 2 which shows the time incidents start. No consideration has been given to incident severity or duration. How can decisions on numbers of staff required be made on that?

Shift Patterns—The current shift pattern is not rigid. Coastguard Ofﬁcers already change shifts to cover gaps in the Watchbill which would otherwise be covered by overtime. The current pattern is popular and offers a better work/life balance than the proposed alternative of annualised hours.

Chapter 5

Local Knowledge—The Local knowledge needed by a full-time Coastguard Ofﬁcer on the coast and one who works in a Maritime Rescue Co-ordination Centre are fundamentally different but they both need to have their versions of it. We already draw heavily on coastal ofﬁcers for detail of local geography, community etc. We cannot draw on them for information that we require during receipt of a distress or 999 call. Personnel at the Co-ordination Centre have to have their own local knowledge to accurately position the incident and callout the correct resources. April 2011

Written evidence from the MacGregor Family (MCA 74)

My family has worked in the ﬁshing industry both here in Shetland, the West Coast of Scotland and in Peterhead, where I am from. We know the importance of local knowledge and expertise in an emergency only too well. The local Coastguard has been called out many times over the past months, since the threat of closure has been raised. Each time shows how wrong it would be to close it down. My family also feel this applies to the Western Isles. As islands, they also have the same needs as Shetland and I urge you NOT to close either of these Coastguards. March 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from James Wiseman (MCA 75) Retention of Shetland Coastguard 24/7 I write to you as one who has more than 60 years experience of going to sea, as a ﬁsherman, latterly owning my own boat (Nil Desperandum), and ﬁve years as a marine pilot during the construction of the Sullom Voe. Firstly, I would like to express my appreciation of the support of the Shetland Coastguard during my years at sea. Just knowing that the Shetland Coastguard was there when needed made a tremendous difference.

Geographical Position of Shetland—69 North Shetland is much further north, with a vast expanse of the North Sea in all directions.

Local Knowledge Local knowledge is crucial in the management of an emergency in the North Sea, and much of that would be lost if Shetland closed.

Communications Breakdowns As you are no doubt aware, there was a recent loss of communication during an incident at sea, and loss of communication is more likely to occur during bad weather, when marine emergencies are more likely to happen.

Probability of Deep Water Drilling for Oil in the North Sea With the current shortage of oil and the ever growing demand for oil this appears to be expected to happen, in which case there will probably be more emergencies in this area. Please give serious consideration to the points I, as a lifelong seaman, have made. March 2011

Written evidence from Eileen Thomson (MCA 77) The biggest issue here is safety. There are always accidents of all kinds in the sea around here [Shetland] and we need a prompt response, lives are sometimes lost here, but occasionally. I fear the death rate will skyrocket if we lose the coastguard. April 2011

Written evidence from Brixham Coastguards (MCA 79) 1. Introduction 1.1 There is a demand for cost saving at the moment due to the current global economic climate. HM Coastguard officers are aware of the fact that the organisation must evolve, ensuring that changes in the marine environment and an increase in maritime domain awareness are considered as part of the evolution process. However, this evolution should not lower the standards set at this time or increase the risk to the members of the public. 1.2 We (Coastguard Operations Room Officers) believe the current proposals that were issued by the MCA in December 2010 would not only lower standards but could also put the safety of mariners at risk and also all people that use the coastal areas for leisure. 1.3 20th Century IT computer equipment that is upgraded and patched to aspire to be a 21st century solution which is not a credible substitute to the technology currently available. 1.4 The proposed two large operational centres at Aberdeen and Southampton/Portsmouth would lead to an unhealthy, stressful and unmanageable environment on many levels. Staff turnover could become an issue which in turn would incur training expenses for new staff. 1.5 Noise levels would be much higher compared to the current operations rooms around the coast, especially in the busy periods and regardless of any noise shields which would not be sufficient to alleviate the cacophony that would ensue. 1.6 Unmanageable number of aerials to listen to will more than likely lead to missing Distress (Mayday) and Urgency (Pan Pan) transmissions especially as it is intended for officers to monitor via speakers rather than headphone. 1.7 Unmanageable large areas of coastline being monitored by staff without local knowledge of that area of coastline would put safety at risk. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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1.8 The fire service and the West Yorkshire police force both tried the centralised control room’s concept and both now have returned to a local control room model which is testimony to the failings of such a configuration for whatever reason. 1.9 We do not agree with daylight stations only. We are not a part time emergency service we are available and ready 24/7 365 days as are all the other emergency services. 1.10 Having two main centres will jeopardise coastal resilience because if one centre goes down the remaining centre will only be able to take 104 aerials out of the possible 154 thereby leaving many more communication black spots than there currently are. 1.11 Having only two main centres would make an easy target to terrorist attacks and pandemic flu viruses. With the outage of one of the main centres, large areas of coastline would not be able to be monitored, thus rendering those areas unsafe. 1.12 A Rolling Daisy Chain Configuration linking three MRCCs directly, including each Remote Radio Site, so that if any MRCC suffer a total outage the flanking stations on each side will support it, this would be much more resilient than the present pairing and will link the whole of the UK coastline which will minimise the likelihood of any loss of large areas of the UKSAR region. 1.13 We know that by keeping the UK in manageable smaller areas, as we have now, would promote a more secure and safer environment. As stated by a senior MCA executive “stations are currently where they are because they are in the most strategic positions”. 1.14 As frontline Operation Room Coastguard Officers we have developed the “RAP Plan” (Realistic Alternative Proposal) to the consultation for modernising HM Coastguard. We are not adverse to change for the better within the service and we recognize that there is scope to modernise and improve the service that we deliver to the maritime community and general public.

2. Current SAR Co-Ordination Structure 2.1 The MCA currently provides the United Kingdom response to Civil Maritime SAR via a network of 19 Maritime Rescue Co-ordination Centres (MRCCs). 2.2 All Operational Partnerships between MRCCs are able to “pair” fully except MRCCs Stornoway & Shetland, then there are further restrictions in so much as MRCC Thames is unable to assume complete control from MRCC Dover due to the implications for CNIS used at Dover. Similarly MRCC London does not have the facility to take control of MRCC Thames systems. 2.3 The pairing of MRCCs facilitates “on watch training”, mutual support during high intensity operations and provides resilience. There has not been an occasion whereby both stations in a pair have suffered outages at the same time. 2.4 The technology to support such ﬂexibility is proven and it is presumed that further technological progress will be made, hopefully making systems more robust and reliable. 2.5 Most MRCCs operate independently, assessing watch levels on individual MRCC basis, each MRCC has an independent staff compliment and recruits to ensure vacancies are ﬁlled as soon as practically possible. 2.6 Present MRCC Pairings Aberdeen—Forth Humber—Yarmouth London—(unable to pair with Thames) Thames—(unable to assume complete control from MRCC Dover due to the implications for the Channel Navigation Information System, CNIS) Dover—(unable to depend on Thames & London for complete support due to the implications for CNIS Solent—Portland Brixham—Falmouth Milford—Swansea Holyhead—Liverpool Belfast—Clyde Stornoway—(unable to pair with Shetland) Shetland—(unable to pair with Stornoway)

3. Proposed SAR Co-Ordination Structure 3.1 A minimum of 14 stations plus London would be required to maintain the safety and integrity of the whole of the UK SAR region, (10,500 miles of coastline and 1¼ million square miles of sea area). 3.2 The selection of the 14 stations could be assessed by a criteria of Strategic positioning, Workload, Stafﬁng levels and number of actual SAR Incidents and be appointed by an arbitrary panel. SAR Incident cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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statistics being incidents where people are either rescued or assisted rather than Incidents initiated for exercise or passing information to a coordinating MRCC. 3.3 The future MRCC structure would have a rolling Daisy Chain Communication Configuration whereby a station that suffers an outage would be supported by either one or both of its flanking stations. This would maintain the integrity and safety of the 10,500 miles of UK Coastline and surrounding Sea Areas. 3.4 By having so many stations with interoperability it would be more resistant to terrorist attack than having two main centres, which could be targeted and immediately result in disaster around the coast of the United Kingdom. 3.5 Each MRCC will operate individually 24/7, 365 days of the year with approximately 24 staff per station, but supported by both immediate flanking stations. Staffing at each station would be done on a risk assessed basis particular to that station. 3.6 Solent–Portland (Combine both stations and utilise the Billy Deacon Building at the Training Centre Grounds), perhaps renamed as Highcliffe Coastguard? The building is currently used to train HM Coastguard Operation Room Officers and has been used as a live emergency coastguard station in the past. 3.7 Stornoway–Shetland—Both MRCCs should remain because of their inability to pair and their isolated locations. London—Independent due to inability to fully pair. Dover—(CNIS and SAR coordination duties) Falmouth—(GMDSS duties to be shared with other stations for contingency planning and training purposes)

4. Current Staffing 4.1 Each MRCC operates a four watch, watch-keeping regime of 2 x 12 hour days, 24 hours rest period followed by 2 x 12 hour night watches. The staffing levels at each site vary, nationally there is 450 Operations Room staff. 4.2 In terms of financial budget and number of permanent staff, HMCG MRCC Operation Room Officers are the smallest group of any emergency service in the United Kingdom. 4.3 Each MRCC Operations Room employee is examined and assessed to maintain unique skills, which are utilized on a daily basis either during SAR Incidents or on station training. 4.4 The Watch Manager (WM) of each watch should be qualified to be The SAR Mission Coordinator (SMC) during SAR Incidents. 4.5 The SMC is responsible for maintaining coordination of an incident from the initial alert (either by marine band radio, mobile & land line phones, Digital Selective Calling (DSC) or emergency beacons) to the termination of a SAR mission. 4.6 The small number of people on each Operations Room Watch at present is manageable by The SMC. 4.7 The introduction of additional duties including Vessel Traffic Monitoring (VTM), Marine Management, Maritime Security, Border Control and Customs & Excise for MRCC Operations Room Staff would qualify them for improved remuneration reward to bring pay in alignment with other 24/7 emergency services. 4.8 The Coastguard Rescue Service (CRS) is managed on a daily basis through a network of 64 Sector Managers (SM’s), servicing the needs of the approximate 3,500 Volunteers. 4.9 The Management of both MRCCs and Sectors in an operational partnership is normally provided by 1 Coastal Safety Manager (CSM) and 2 x Rescue Co-ordination Centre Managers (RCCM’s) who also service the Duty Area Officer (DAO) role by one in three duties.

5. Proposed Staffing 5.1 At present there are three regions, there would be scope for staff reduction by moving from a regional business model to a more cost effective National Coastguard, so there is consistency across the UK in procedures and practice. Regional Directors and Coastal Safety Managers roles would then become obsolete; however, two new roles would be introduced to support the Rescue Coordination Centre Manager (RCCM), Watch Manager (WM) and Sector Manager (SM). 5.2 The Introduction of the Coastal Support Officer (CSO) and the Senior Watch Manager (SWM) would create resilient support for operational frontline officers, both on the coast and within the MRCC Operations Room. 5.3 The Coastal Support Officer (CSO) will be a full time supportive role, supporting Sector Managers in their duties and filling the SMs role during their absence providing continuity for volunteers and supporting RCCM’s by attending liaison meetings with other emergency services and authorities or incident scenes as required. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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5.4 The Coastal Support Officers (CSO) and Rescue Coordination Centre Managers (RCCM) would inherit more responsibility on Coastal Volunteer working practices and also attend multi emergency service meetings improving working procedures, practices and relationships. 5.5 The Rescue Coordination Centre Manager (RCCM) role would be supported by a single Senior Watch Manager (SWM) who would be selected from the four watch managers within each MRCC. 5.6 The Senior Watch Manager (SWM) would be the point of contact for the duty Watch Manager (WM) in the RCCM’s absence either for the routine running of the station or during protracted incidents or Major Incidents. The selected WM would perform the role of WM when on watch and not required for specialist duties but will become the SWM when required for operational needs. 5.7 The selected Senior Watch Manager (SWM) should be the most experienced WM of the four and rewarded as necessary for the time working in this role. The SWM would support the WM by passing advice, contacting other SAR, Pollution, Media support or actually attending the MRCC or flanking MRCC to assist the watch. 5.8 The introduction of this post would mean there would be support for Watch Managers from experienced staff from within the Operations Room environment, relieving other external Officers of such duties. 5.9 The Watch Manager (WM) will continue to take on the role as the Search & Rescue Mission Coordinator (SMC) during incidents, supported by the senior managers. 5.10 RCCMs & SWMs from each MRCC would be part of an area duty roster for support for Operations Room Staff during incidents, similar to present Duty Area Officer (DAO) duties, but the duty rota would be shared between six staff (3 x RCCMs plus 3 x SWMs). 5.11 If a flanking MRCC Officer is duty and a Watch Manager from one of the three linked MRCCs’ requires assistance, the Duty Officer attends his or her local MRCC to assist, give support or liaise as appropriate. 5.12 No change to current uniform, operations room layouts or design of buildings, vehicles etc. would be more cost effective than the proposed changes?

6. Coast Rescue Teams 6.1 The Coastguard Rescue Service (CRS) will remain as a volunteer service, managed on a daily basis by Sector Managers (SM) & coordinated by the SAR Mission Coordinator (SMC). 6.2 Modernisation for the CRS could come in the form of Mobile Data Terminals (fixed) units fitted to each Coastguard Rescue Vehicle (CRV) or Android EPads (portable) units utilised while the CRS team members are on foot, this would improve interaction between Operations Room & SAR units during incidents. 6.3 This is modernisation & low budget financing for resilience on the coast, the equipment is available and will improve communication between Coordinator and the Search Unit (text, email, casualty description, listed hazards etc.) and improve transiting time for the SAR unit. Other emergency services are utilising similar equipment at this time.

7. Training 7.1 The MSAR courses should only be available for Coastal Staff to attend through the Autumn & Winter Months to maintain resilience on the coast with each MRCC maintaining a full compliment of Operation Room Staff per Watch. 7.2 A Team of Trainers can work from a designated station or at the Training Centre, then cascade new methods, skills etc. to Coastguard Ofﬁcers when they return to their designated stations. 7.3 The Training Team could organise station visits/assessments to maintain the standard of skills. 7.4 Computer Based Training should be available for Coastal Staff throughout the year, as well as Online teaching videos and computer based animations.

8. IT and Equipment IT Support 8.1 Any working Operations Room Coastguard would agree one of the areas that requires improvement would be IT Support. 8.2 Each MRCC should have an IT Support Ofﬁcer (ITSO) to cope with day to day problems & faults. The ITSO would be a member of the watch with a suitable IT knowledge and literacy to carry out tasks on station. 8.3 The MRCC ITSO will then be supported by a specialised IT Team based at HQ. This should improve the integrity and resilience of the UK Operations Rooms. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Operations Room Equipment 8.4 Each operator would have a four screen configuration, each screen will have a particular purpose: Tabbed Mapping screen: for Electronic sea charts (updated weekly), Google mapping for quality and for street view, Saris, OS Mapping, AIS. Communications Screen: VHF/MF/DSC, Tetra. Administration (Incident) Screen: Localised databases, Web Access, Email, Logging, General Admin, and Microsoft Windows based. Assets (Resource) Screen: One touch management of Lifeboats, Helicopters, Coastguard Rescue Teams, Fire, Ambulance and Police shortcuts. These screens can also be split screens. 8.5 One touch launching, Colour coded assets types on bingo card, Reduced Mnemonics, Wireless Headsets, Speech to text capabilities, Drag and Drop narratives, Tabbed bingo type card for flanking stations assets. 8.6 Summary templates 8.7 Coastguard Rescue Vehicle (CRV) would be fitted Mobile Data Terminals (MDT) to receive details of incidents also has built in tracking. Smart Phones or E Pads/I Pads for the Station Officer to replace their out of date GPS, giving them email and picture capabilities because not all stations have FAX/Online services.

9. Partnership Working 9.1 HM Coastguard has always recognised the importance of partnership working with other authorities, be that during emergency response with colleagues in the other blue light services or working with Local Authorities and other bodies to ensure safety signage etc. 9.2 HM Coastguard to work with or/in partnership with other agencies eg: HM Customs, Border agency, Police. 9.3 Building share with other agencies to reduce costs.

10. Income and Savings 10.1 It may be possible, if negotiated favorably to keep the Emergency Towing Vessels (ETVs) so that at least the service paid for itself. 10.2 Income and savings can be made by the lease or rent of surplus building or ofﬁce space gained by the rationalisation and centralisation of regions and middle/upper management structures. 10.3 Using this plan will greatly reduce relocation costs, keep skilled staff thereby not incur training and recruitment costs and no compulsory redundancies. 10.4 The greatest effort should be driven into exploiting ways the agency can create to gain income and explore the potential the agency has with all its expertise to bring this to fruition. April 2011

Written evidence from Operations Room Staff at MRCC Clyde (MCA 81) 1. This is a submission to the Transport Select Committee in response to the request for information into the proposals for H.M. Coastguard, the Maritime Incident Response Group and emergency towing vessels. All statements and ﬁgures are the result of work carried out by the staff and the sources of this evidence are available on request. 2. This response is submitted on behalf of the Operations Room staff at MRCC Clyde by Calum Murray, Watch Manager, MRCC Clyde, Eldon Street, Greenock, PA16 7QY. 3. Chapter 1 states that our seas are becoming more congested and, while this may be true, it is not with the large ships which the document would have you believe but with smaller vessels which are not required to carry all the electronics on which the proposals are based. The number of vessels of 300 Gross Registered Tons and over fell from 55,000 in 2008 to 50,000 in 2010. 4. That ships are getting larger is not entirely true—container ships are increasing in size but tankers are not as large now as they have been in the past. The present size of the largest container ships is less than half the size of the largest tankers. Nevertheless, such vessels are not those that generate the majority of work for Coastguards. 5. The coast is getting busier. This is true, not with large ships but small craft operating to ﬁsh farms, wind farms and pleasure craft. Fishing vessels are, perhaps, fewer in number as a result of quotas and subsequent decommissioning. Those remaining are operating with smaller crews to save costs, which increased the risk of incident. These vessels are not all required to carry the equipment on which the proposals are based. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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6. Weather conditions are becoming more extreme. No evidence was found for this. The majority of our customers do not go to sea in bad weather. They get a local forecast from their local Coastguard. In fact less than 0.5% of incidents in the last five years have been attributed to adverse weather—figures extracted from Management Information System (MIS) 7. Chapter 2 attempts to give the impression our systems are 40 years old. This is blatantly untrue. It talks of limited resilience—where has the present pairing system failed? At present, if we have a complete failure to an aerial, we can send Coast Rescue Officers (CROs) to the aerial site to monitor our distress channel manually. This is also what will happen in the new system. Where is the improvement in this? 8. The new proposals purport to enable staff to up their professional standards and skills which will follow from dealing with more incidents. If that is true, why is the busiest station in Scotland (and incidentally the 3rd busiest in the UK, in terms of SAR hours) scheduled for closure, when the staff there is already dealing with a higher work-load than all the other Scottish stations? The plan is to close the busiest, with its wealth of experience and knowledge, and retain one of the quietest. Where is the logic or operational judgement in that? 9. In fact, Clyde MRCC is the busiest in Scotland by number of incidents and by the time involved in dealing with incidents—almost 1,000 hours per year more at Clyde than at Aberdeen. 10. The staff at Greenock carried out an analysis of incidents for 2010 which gave some surprising figures. For number of incidents per station, Clyde is 5th in the UK, for hours in prosecuting Search and Rescue, Clyde is 3rd in the UK, 2nd behind Falmouth for Distress Calls and 1st for Urgency Calls. (See graphs). 11. Chapter 3 talks about a nationally networked system. This only applies to aerial sites, since the majority of other equipment has been networked for years. 12. If we lose one of the proposed MOCs, only those aerials deemed as critical will be transferred to the second MOC. Is it progress that the in-fill aerials (most of which have been installed to cover blank spots in VHF coverage, in response to particular maritime tragedies) will not be transferred? 13. Adding additional line managers into Operations’ Room will never increase the responsibilities of those below—just another layer of unnecessary management. 14. Chapter 4 talks about the proposed new structure in which it is stated that the only place to have the Northern MOC is Aberdeen. This is short-sightedness beyond belief. Any Scottish MOC should be located in the central belt, alongside the proposed new single Police and Fire service headquarters, where most of the population lives and where the greatest catchment area for recruitment exists. This area provides the greatest variety and availability of affordable housing. One must speculate that, despite the reason given for the choice of Aberdeen being mainly due to some kind of complications with regard to the lease of their premises at Blaikie’s Quay, there is a great deal of suspicion that a much more believable reason is that the Regional Director and his staff wish to stay where they are. 15. Sub-Centres operating daylight hours will result in incidents being handed over from one station to a MOC. It is perfectly possible that at the busiest times of the year, there might be several day stations handing over incidents to the MOC simultaneously. We only have to look at the ongoing Fatal Accident Inquiry into the fishing vessel Aquilla to see the short comings of handing over co-ordination of incidents between stations. 16. Basing the choice of sub-centres “because they house MCA facilities such as Marine Offices or Radio masts” is astonishing as Stornoway has neither a Marine Office nor do they house a radio mast. Shetland do have Marine Office but no occupying surveyors, Clyde MRCC has both. 17. It also states that “Sub-centres would also sensibly be located in areas of good communications, with a reasonably large population and with good job markets to facilitate future recruitment” so why would the Clyde coast, which has all these requirements, be ignored in favour of stations at either Stornoway or Shetland. 18. Manning levels in Operations’ Rooms, we are led to believe are to be set at that which will be able to deal with the anticipated number of incidents. Therefore, every year our watch levels should increase in line with the continuous increase in incidents we have to deal with. The watch levels at Clyde, which were set in 2,000, have in fact been reduced since then. 19. Management seem to forget that, when we are not co-ordinating incidents, broadcasts to shipping, receipt of transit reports and other routine calls, dealing with faults and the numerous other functions that fall on an Operations Room. We also carry out training as part of our job description. It is generally the case that the only time staff can carry out self study, in-watch exercises and incident debriefs is on night shift. 20. The present rigid shift pattern is only so because of a reluctance on the part of management to be proactive and industrious in attempting to make the system more versatile. There are numerous ways in which watch-keepers might be utilised while maintaining adequate manning in Operations’ Rooms. 21. Chapter 5 deals with the strengthening of the Coastguard Rescue Service which, in broad terms, is welcomed by all. The proposed increase from 64 to 78 Sector Managers is to be welcomed, but the prospect of putting a further layer of management in place to manage them is nonsense. Sector Managers are more than capable of working to the Coastal Safety Managers, so the other 18 posts between Sector Managers and CSMs which are proposed are completely surplus to requirements and will be financially poor value for money. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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22. At present the Coastal Safety Manager has responsibility for Sector Managers and the Operations’ Room but, in the future, they would only be Line Managers for the Sector Managers. That being the case, why do an additional 14 Sector Managers need another 18 managers? 23. Chapter 6 deals with improving efficiency and value for money. However, how does that square with the fact that Aberdeen MRCC costs more to run than all of the other four Scottish stations put together? 24. The figures the MCA have presented in the Consultation Document are so over- simplistic that it is difficult to understand where they came from. For example, where are the costings for the redundancy payments of approximately 200 staff over the four years that this reorganization is programmed to take. From the evidence of straw polls taken around the coast, very few coastguards will be prepared to move to one or other of the most expensive parts of the country for housing and cost of living. These are the people who have suffered an imposed pay settlement for the last four years—well below current inflation in each of these years and subsequently increasingly less able to accumulate any savings. What sort of world does the senior management of the MCA inhabit? 25. On 1 April 2011, Navy Buildings, which houses MRCC Clyde, was released from the stewardship of Faslane Naval Base and handed over to DIO (Defense Infrastructure Organization). Has the MCA made any enquiries into what the future intentions of DIO for Navy Buildings are? The answer to this is most important, since it appears that the future of Navy Buildings was given as one of the main factors that Clyde MRCC would to cease to exist as part of the reorganization. 26. We wish to question the suitability of the members of the team who have made these proposals. As the exact identity of the team has not been disclosed it is somewhat a matter of speculation as to its members. However this is a small service and we have made an educated guess as to the make-up of its members. Of the team of six, not one of them has any contemporary experience of working in an Operations Room. Two have only ever worked at Stornoway MRCC, a comparatively quiet station and a third has only ever worked at Swansea MRCC. It appears that there were others co-opted under a great veil of secrecy in the very last few weeks before the publication of the Document. Why was there no opportunity for a representative from each station to be included? Our new Chief Executive, despite having little opportunity or knowledge to influence these proposals has honourably claimed ownership of this Document. Unfortunately for him, there is a great credibility gap. As he goes round the country speaking to the staff at each CG station, assuring all that most of those whose opinion he has sought agree with him that there must be station closures, one can imagine that each and every one who might agree in principle will be firmly of the opinion that it might be any station other than their own. Would turkeys vote for Christmas?—Probably not! 27. Finally it is worth drawing attention to the weight the MCA has put on the opinions of the Transport Select Committee in the past. In 1999 when the closure of Pentland, Oban, Tyne Tees, Liverpool and the co- location of Solent and Portland was under discussion, it was noted that the recommendations of the Committee were ignored. To quote: “The Coastguard is an extremely effective, and very cheap, service of which we should all be proud. We do not accept that now, when the number of incidents dealt with by the Coastguard is rising steeply, when the average real cost of responding to each incident has fallen so sharply, and when our record compares so favourably with other countries around the world, is the time to close Coastguard maritime rescue co-ordination sub-centres. We note that the closure programme would only save £500,000 and to stop it will be inexpensive. Therefore, we recommend that all 21 maritime rescue co-ordination centres and sub-centres be retained, and that the new communications technology, which is so necessary, is installed in all of them.” cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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% of UK incidents handled by each station from lowest to highest

12.00%

10.55% 10.52%

10.00%

8.09% 8.00% 7.31%

6.41% 6.16% 6.03% 6.00% 5.49% 5.55%

4.60% 4.37% 4.44% 3.97% 3.72% 4.00% 3.58%

2.94% 2.55%

1.92% 2.00% 1.81%

0.00% SHET STY FOR BEL MILF DOV HYHD LON YARM ABZ LVPL THAM PORT BXM CLY HUM SWAN FAL SOL

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Written evidence from Greg Albrighton (MCA 85) The Senior Management of HM Coastguard sets great store in changes to the Coast Rescue Service (CRS) making the closure of Rescue Centres workable. The Chief Coastguard wrote in February 2011: “These issues are gradually stretching the size of the Coastguard Rescue Service (CRS) operating envelope, with a potential for increasing the need to operate inland as well as on the coast. The existing operating model for the CRS needs to be strengthened to give our Teams the appropriate leadership and support for the anticipated future operating environment. The proposed future Coastguard structure with additional full time officers and Team Leaders will enhance the leadership and support for Coastguard Rescue Teams in terms of on scene command and control at more complicated incidents and make significant improvements to training delivery, supervision and general support.” The CRS is not set up to take a greater co-ordination role in its current state. The basic communications systems, training and supervision has changed little over the last 30 years and the 14 “additional full-time officers”, spread thinly across the whole of the UK will make little, if any difference to the status quo. The following paragraph from MCA HQ to mitigate the loss of MRCCs is at best how we would like things to be and at worst disingenuous. Lay-persons will be impressed but those in the know will not recognise this description of our infrastructure. HM Coastguard has suffered decades of under-funding and has pretty much been held together by the hard work and goodwill of its officers on the coast. “the 3,500 strong Coastguard Rescue Service operates using over 300 modern 4WD vehicles fitted with comprehensive communications and GPS navigation equipment. They are trained and equipped for search and a variety of technical rescue operations, operate from modern buildings and are alerted by modern paging systems.”

Buildings Some Coastguard Rescue Teams operate from “modern” buildings sadly this is not the case for all teams. The NE area is probably typical of the service as a whole. Of ﬁve teams, two operate from decent buildings, two have aging and unsuitable “lock-up” units on industrial estates. One team make do with a domestic garage with no toilet or heating—The team and the vehicle cannot be on station at the same time and vital equipment checking in the winter months is difﬁcult.

Modern Vehicles Yes. Some of the Coastguard Response Vehicles (CRV) are chronologically modern. However, for the 220 cliff rescue teams they are the wrong type of vehicle. The weight of the rescue equipment often means that only three people can be transported. At best only half of the typical rope rescue team can go to an incident in a marked CRV. Everyone else has to go in their private car. Private saloon cars are unsuitable for much of the coastal terrain on which we operate. This means that team members responding to an emergency cannot get to the scene quickly—or the 4X4 CRV has to return to get them. There are still many aged vehicles on the coast—the one I use is nearly 11 years old and has 100,000 miles on the clock.

“Modern” Paging Systems The CRS rely on “Tone Pagers” to be alerted of an incident. This system is 1970s technology and is indiscriminate, the user has no indication of the seriousness, location or attendance requirements. Paging two teams means that the co-ordinating operations room (MOC/MRCC) then have to answer up to 22 phone calls from the CRS asking for more information and to conﬁrm attendance. A few teams do have a “Modern” paging system (BT Connect) but this was not rolled out nationwide because it was too costly.

“Comprehensive” Communications The majority of CRS rescue stations have only a phone to receive or transmit information regarding emergencies. They have no fax, no internet access or data reception facility. Once the team leaves the station to attend the emergency they rely solely on VHF radio. Whilst VHF radio is good for passing short tactical messages it is not appropriate for longer messages. Other emergency services have no access to VHF marine band radio. The vast majority of Coastguard teams do not have a mobile phone to pass information or to receive or transmit detailed or sensitive information. In no way can communications on the coast for the CRS be described as “comprehensive” cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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GPS Navigation Equipment Rescue teams on the coast have an old, entry level hand-held GPS receiver. (Currently available on Ebay for £20) This has one useful function—to mark a grid reference or latitude and longitude position. It has no map function, post codes cannot be used nor can it store named locations. It is not a modern SatNav type piece of equipment and is largely useless. Where SatNav is required—to find addresses of first informants or response to inland flooding for example, we rely on volunteer rescue officers bringing and using their own SatNav equipment. I have purchased one for my Coastguard vehicle. In technology terms, the CRS is decades behind the other emergency services, however, the consultation document implies that we will operate more like them.

Additional Full-time Officers on the Coast The risk analysis mitigation of MRCC closures says Future structure enhances the number of sector managers available for training and supervision. Provides a an additional level of supervisory management and provides on call 24/7 operational presence The proposal states that full-time professional officers on the coast will be increased from 64 to 105. This is just “smoke and mirrors”, the number of additional officers actually working with the CRS will be 14. The 105 will then be made up by additional managers and moving the current Salvage and Pollution Branch into the CRS. The true number of people operationally effective will be 78. The 64 SMs in post at the moment struggle to train the 50 Coast Rescue Officers (CROs) in, on average, 5.6 teams as it is. The extra 14 will give each CSO an average of five teams. These officers work alone and have complete responsibility, not only for training but for: Recruitment, pay, discipline, welfare (All HR functions required for 50 paid volunteers.); Liaison with many organisations—Police, Fire, Ambulance, RNLI, Harbours, LA emergency planning, lifeguards, beach managers, Coastwatch, Marinas, Yacht clubs; and many others. Public relations, media liaison, education and incident prevention. On average six buildings (maintenance, statutory inspections etc), six vehicles and all the related rescue equipment much of which require statutory checks under H&S law. To remain qualified in certificated rescue skills and to teach—Rope Rescue, Water Rescue, First Aid, Land Search Management, H&S management, Time Expired Pyrotechnics and Ordnance and 4x4 driving. Basic rescue skills (Communications, safety, casualty evacuation, maritime knowledge plus another dozen basic competencies). When the SM is not available (Annual leave, sickness, training etc) there is no back-up at all. Phones go unanswered, mail is unopened (paper and email), parcels go uncollected, CRS training does not happen and supervision of volunteers ceases. When I explain to colleagues in other emergency services how Coastguard provision on the coast is given they are amazed at the lack of business continuity, the breadth of required knowledge, the teaching commitment, the amount of rescuers managed (especially for a basic annual salary of circa £22–25k) 14 additional officers and some new managers to supervise them will make little difference to the operational effectiveness of the CRS. Training delivery for the majority will not change—I cannot see where the “significant improvements” will come from. What is required is for each SM (CSO) to have an assistant to share the massive training commitment and to provide business community throughout the year. Giving each SM an assistant will give business and operational continuity, double the effective training and liaison and significantly enhance the general well-being of the CRS in all critical areas. The future plan is for SMs (CSO) to be on call 24/7 on a roster basis. Whilst this is a good idea in theory it is very unlikely to make much difference in practice. The proposed teams of SMs giving on-call cover will be four—six strong. This means that the on-call full-time officer could be up to six hours or up to 200 miles away from the incident. Whilst driving to the incident the officer will be out of touch with operations. The majority of incidents last no more than two hours—even the serious ones and the critical on-scene decisions will be made in the first hour. In the vast majority of incidents this system will add little to the effectiveness of operations. If each SM had an assistant these teams could be smaller and cover shorter distances giving the duty officer a chance of getting on scene within a time where he/she could do some good. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Summary If presented with a blank sheet of paper, one would not design a CRS that looks anything like we propose to end up with—post modernisation. We would not have SMs working in isolation, responsible for absolutely everything from buying toilet rolls to sitting on regional resilience fora to training a long list of life-saving technical skills to maintaining links with the dozens of partners. Supervision, training, local contact, assistance and advice would not come to a grinding halt every time the full-time officer (SM) in the area took annual leave, got trained or went sick. There is no business continuity in the present or proposed organisation. One would want a structure where officers could join at an entry level and gain experience, skills and promotion as a rescue practitioner—now and post modernisation the entry level is SM (CSO) and there is no scope for promotion within the Coast Rescue Service. Officers are promoted out of front-line rescue and all skills and experience is lost. We would not rely on our volunteers having an internet connection at home to receive important operational information quickly. Similarly, we would not need to rely on them having a private mobile phone to be able to talk to them at the rescue scene. Each rescue station would have a basic electronic means of receiving/sending detailed operational information (data transfer terminal or internet connection). We have a once in generations chance to start with a blank sheet of paper and the great opportunity will be lost if the proposal goes ahead in its current form. March 2011

Written evidence from Lynne Fry (MCA 88) Operational Issues — The proposals outlined in the consultation document take no account of the current local knowledge requirements of Coastguard operations room staff. It is being promulgated at the public meetings during the consultation process, that this level of expertise is no longer necessary as all the information required to process an incident can be acquired from a database or via local volunteers at the end of a telephone line. It is even suggested that a first informant in an emergency be linked via telephone to a rescue officer in order to determine their exact position prior to resources being assigned to an incident. This could and would lead to a delay in effecting a rescue and cause significant distress to the caller, especially if they are in a dangerous situation ie in a liferaft, or in the water, using a mobile phone. It is not sufficient to use the current EISEC details in coastal areas as they have proved to be somewhat inefficient at present, and it is not known if this situation will be improved in time for the new MOC’s. — On the subject of making more use of the local resources, a recent incident at Humber was reported to us by a very irate member of the public who had been trying, without success, to contact the local coastguards in Hull for 3 days before finally contacting the 24 hour operations room at Bridlington. (The Coastguard rescue officers are not to blame as they are volunteers and not expected to be available 24/7 to deal with enquiries). Although in this case the enquiry was not an emergency, the person would be even more frustrated if he/she was confronted with a call centre type menu when contacting a MOC. So it seems, that instead of providing a better more “resilient” service, the operations room staff will be dealing with increasing numbers of irate customers, the reputation of call centres being what it is. — The new system seems to be very much reliant on staff being willing to relocate in order to make the MOCs effective and take their local knowledge/expertise with them. From the way it is outlined in the proposals, this prospect does not look very attractive to many people and in most cases it will involve moving from a relatively inexpensive part of the country to a much more expensive location. What are the reasons for these location choices? This may well incur a considerable drop in living standards unless the remuneration package is extremely lucrative, which again is unlikely in the current economic climate. So far no indication of how much this is likely to be, or even what changes are expected to the current shift patterns have been given. Not a very encouraging scenario considering the upheaval that will be faced by those that agree to relocate. — The reliance on DSC (digital selective calling) as a primary means of alerting in distress situations at sea is a flawed concept unless the casualty is a merchant vessel familiar with the use of this equipment. Small pleasure vessels and fishing boats do not generally use DSC (in my experience as a Coastguard) and, unless legislation is changed with regard to this then the present situation will continue to be the case. These vessels generally use either mobile phones or VHF radio in order to summon help. Therefore, with the proposed new system unless they dial 999 their call will probably be placed in a queue, as is the case in most call centres, where, by the time the call gets answered the battery of the cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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phone will probably be ﬂat or the vessel may well have sunk. DSC may also generate a large number of hoax calls from small vessels where the button is pressed in error, and the crew may, or may not, be familiar with the regulations/procedures regarding false alerts as per IMO guidelines. If, as it is being promoted DSC is the main method of communication then the follow up broadcast on CH16 or 2182Khz may not be done because the casualty will assume that once the DSC has been acknowledged, help is on the way. If this happens, communication with the casualty vessel will be lost and, in the absence of a properly formatted distress message, the only information available to the coastguard is the very limited version from the DSC. It is important to note here that DSC was only brought in as a replacement for the Auto alarm on merchant vessels when they no longer carried Radio Ofﬁcers. This was purely as a means of alerting so that someone could listen and be ready to log the details of a full follow up distress message on the radio. However, on most merchant ships, a CH16 watch is still kept on the bridge where the DSC is just another piece of equipment, with an audible alarm, alongside many others for different functions on board the vessel which need to be monitored. eg. engine room alarms (UMS) on loud speakers. Also whilst on this subject can I draw your attention to an incident that recently occurrred at MRCC Humber where a DSC undesignated distress call was received with no position information and generated a large search. The vessel in question had not registered the DSC equipment so the only information available was very much out of date and invalid. I attach a press release put out by the MCA on this incident and feel that this is an issue which needs very careful consideration before implementing a system which is heavily reliant on DSC especially in the case of small boat users which make up the bulk of the Coastguard sea rescue work. — The ability of a single operator in a MOC to monitor 15 receivers on CH16 (average number of aerials at a current MRCC) can be very stressful, and without the DF facility currently available, it will be easy to miss calls or select the wrong aerial for a response. With the other functions requiring attention at busy times it may not be possible to monitor the radio effectively and this could possibly mean that a faint or brief call for help may be overlooked. This is something that should be considered especially during periods of high barometric pressure which has a bad effect on radio reception and causes high noise levels on all VHF channels. Propagation issues for radio reception also mean a more vigilant watch needs to be kept particularly on longer range frequencies during the hours of darkness.

MCA Issues — Despite meetings with management to discuss the proposals and attendance by Coastguard personnel at public meetings (CG personnel were instructed by the MCA that they were only allowed to attend public meetings in civilian clothes and ask questions as members of the public not as staff members) the MCA management consistently refuse to acknowledge our concerns about their plans. The proposals also seem to be subject to modification as the consultation period progresses with the introduction, now, of the Disaster Recovery Centre. This is not mentioned in the original consultation document only in the Risk assessment publication which appeared after the Select Committee meeting on 8 March. Its location is, apparently a closely guarded “secret” as is its function but the general feeling is that it will be situated at Dover. — A question was raised at our local public meeting on 21 February as to whether these proposals had been discussed with the unions prior to the announcement in December. We were assured that this had taken place but, to our knowledge this was done only with select members of the PCS executive committee who were not allowed to report back to the rest of the committee let alone their members, or the meetings would be discontinued. This does not seem to be the correct way to conduct discussions where union representatives are attending meetings on behalf of their members who are being kept in the dark. — A further question regarding a trial of the proposed system was posed at the same meeting and it was stated that a table top exercise had been conducted with a correct timeline and that it had been successful. After further talks with the union reps we now find that this was not the case and that some of the data was seriously flawed only covering the stations in England. It did not prove that the system would work quite the opposite in fact and it was all done with pieces of paper and not as it would occur in reality with the incurrent noise of phone/radio traffic and ops room communications. This was backed up by the efforts made when the operations room staff went on strike during 2009–10. The system was only able to operate effectively because of non-union staff and those not taking part in the strike manning up some of the stations around the coast. — The initial proposals for the MOC’s were also reliant on very large investments in new technology, which under the current financial restrictions will not take place, instead the MCA are relying on the current system with an upgrade. A current system which at best is not totally resilient and causes problems during very busy periods with ICT issues. Should a similar situation occur within the MOCs once the stress becomes unbearable for the staff there where would the resilience then be? — It is very difficult to ascertain from the MCA management what sort of work and hours will be involved in manning up a day station such as Humber, or does this mean that the day stations will just be in existence until the MOCs are established and then they will be gradually phased out as was the case of the Coast Radio Stations operated by British Telecom up to 2000. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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— Finally, on a personal note, I would like to take issue with Mr Penning MP whom I wrote an email to regarding his constant references to Operations room staff as Call takers or people who simply answer telephones. This is not the case but may well be in the future the way things are beginning to look. However, instead of answering my email, he forwarded it to the MCA (my employer) for a response, which I feel was highly irregular and somewhat unexpected behaviour from a Government Minister. I received a standard response from the MCA consultation team quoting the same rhetoric that we have been listening to since the announcement last December.

Excerpt taken from Bridlington Free Press newspaper on 24 February 2011 (Front Page) FURIOUS coastguards and local residents voiced their anger over plans to cut the emergency service in Bridlington. More than 100 people attended a lively public consultation at Bridlington Spa on Monday evening, where current and former coastguards, rescue workers and members of the public fired questions at Maritime and Coastguard Agency (MCA) representatives over the plans. But the MCA struggled to explain the logistics of cost-cutting proposals which would see the Humber Control Centre in Limekiln Lane move to daytime-only coverage. Now one local coastguard officer said the plans should be “taken back to the drawing board”. The modernisation would see Bridlington’s station, along with 17 others like it around the UK, replaced with two larger 24-hour bases, called Maritime Operations Centres (MOCs) in Aberdeen and on the South Coast. Bridlington would then become one of six “sub-centres” around the UK that would only open during the day—which will see 20 people lose their jobs in the town. Hundreds of people have already signed a petition in the town against the plans. Paul Chapman, a coastguard watch officer in Bridlington and union representative for the Public and Communication Services Union, believes the plans value cutting costs over improving the service and have not been fully thought through—presenting a threat to safety. “It was clear from the consultation that there was absolutely no support for the proposals, but I don’t believe that any concerns the staff or public raise are being taken into account. ‘They need to start again,’ said Mr Chapman, who also raised concerns about the lack of input from staff and unions before the MCA published their plans. The main worry for everyone is safety. The MCA representatives had no statistics available to show that the two centres would be able to deal with all of the calls they might receive, and revealed there will be a greater dependence on technology, which is obviously prone to failure. They are pressing ahead without the statistics to show that the switch from 18 centres to two will be feasible, or whether one operations room could cover the whole of the UK.” During the meeting, Coastguard safety manager Mike Bill and MCA regional director Tom Elder were continually asked for reassurances about how vital knowledge of local terrain will be transferred to two larger centres. Mr Elder referred to the closure of a coastguard station on the Tyne in the 1990s as an example of how local knowledge can be transferred. He insisted place names and local landmarks can be inputted onto databases and used alongside mobile communication technology in the event of an emergency call, although he conceded that there was a possibility that mistakes could be made during any transition. Mr Elder also repeatedly argued that having all existing communications aerials around the country linked to both national centres, rather than to individual stations like Bridlington, will improve “resilience in the system”. However, Mr Chapman thinks that this is a “buzzword” to support the MCA presentation. One employee at Limekiln Lane challenged Mr Elder, claiming the station has had a mobile phone that has not worked for 18 months due to a lack of network coverage. They questioned how the MCA would be able to implement a large-scale overhaul of its system if it could not solve such a minor problem. Lesley Salisbury, founder of East Coast Seal Rescue, emphasised the importance of the relationship between the public and the coastguard, and fears it could be lost if changes go ahead. “I think the Bridlington team are invaluable. I may have to go on a rescue at any time of the day or night, in dangerous conditions, and I always ring the coastguard first,” said Lesley. “I’m not confident a new centre many miles away will understand the terrain on this part of the coast. It will certainly affect the safety of everyone who relies on the coastguard.” cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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A spokesman for the MCA said: “High ranking members of unions were approached with the principles of the plans, and throughout the consultation process we will listen to any concerns or suggestions.” “Local knowledge is important but will still be maintained through RNLI and other rescue crews, but the use of modern technology is just as important.”

Currently, all 18 stations need to be fully staffed at all times to deal with emergency calls, as all stations are not linked nationally.

However, the MCA say that under the new plans, workloads could be distributed more evenly from busier areas.

Public consultation on the plans will run until March 24.

Press Notice No: 80–11 Saturday, March 26, 2011 Posted 19:40 GMT

HUMBER COASTGUARD URGENTLY SEEKING BOAT OWNER

Humber Coastguard are asking for the owner of a 6.6 metre rigid inﬂatable MMSI number 235053194 to get in contact after an emergency VHF DSC alert sparked a fruitless search this afternoon.

At 3.11pm Humber Coastguard received a VHF DSC radio distress alert from a 6.6 metre rigid inﬂatable MMSI 23053194 number somewhere within the range of the Coastguards Cullercoats VHF aerial but with no position or further information as to the nature of the emergency. A search commenced across a large area, involving four lifeboats, two Coastguard Rescue Teams and the rescue helicopter R128 from RAF Leconﬁeld with nothing found.

Humber Coastguard has been hampered in identifying basic essential information for search and rescue such as the current owner and vessel name because the MMSI database entry for this vessel has not been updated by subsequent owners of the craft. Coastguards have spoken with several previous owners without yet ﬁnding the current owner and therefore cannot determine if there are people at risk on this vessel right now or where the vessel is.

The original details for the vessel describe it as a 6.6 metre rigid hulled inﬂatable with a white hull and red tubes. Two previous names include Sidewinder and Pepsi.

Humber Coastguard Watch Manager Graham Dawson explains, The DSC VHF radio distress alert allows a boat to raise the alarm at the touch of a button on the radio unit, but in order for rescue services to get help quickly to the right place it should include a position and be followed by voice communications, eg a Mayday call. For the system to work well it requires the MMSI database to be updated each time the vessel changes name and or owner. Failing to do this means valuable time and resources are wasted attempting to ﬁnd more information to resolve an incident.

Notes to Editors

1. MMSI (Maritime mobile service identity) a unique number assigned to vessels or hand held radios for Digital selective calling, this is a radio alerting system which should be followed by voice communications on the appropriate radio frequency.

2. Digital Selective Calling (DSC) is a paging system that is used to automate distress alerts sent over terrestrial (ie: non-satellite) VHF, MF and HF marine radio systems.

3. The MCA is a partner in the Sea Vision UK campaign to raise awareness and understanding of the sea and maritime activities. Sea Vision promotes the importance and economic value of the sector and works to highlight the exciting range of activities and career opportunities available to young people within the UK growing maritime sector. www.seavisionuk.org .

4. Stay safe—before heading out on the water get trained, check weather and tides, wear a lifejacket, avoid alcohol and keep in touch.

5. Follow us on Twitter. Find us at MCA_media . March 2011 cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from a Serving Operational Coastguard Ofﬁcer (MCA 91) Expect the unexpected “When anyone asks me how I can best describe my experience of nearly 40 years at sea, I merely say uneventful. Of course there have been winter gales and storms and fog and the like, but in all my experience, I have never been in an accident of any sort worth speaking about. I have seen but one vessel in distress in all my years at sea………. I never saw a wreck and have never been wrecked, nor was I ever in any predicament that threatened to end in disaster of any sort.” From a presentation by E.J. Smith, 1907 On 14 April 1912, the RMS Titanic sank with the loss of 1,500 lives…….One of which was its Master, Captain E.J. Smith.

Foreword The proposal that was put forward by the Maritime and Coastguard Agency (MCA) in December 2010 makes the case that Operations Staff are not seen as frontline personnel and essential to the efficiency of the Emergency Rescue Service of H.M. Coastguard. However, in recent weeks no less than the Prime Minister, Mr David Cameron and the Minister for Shipping, Mr Mike Penning have been quoted in the National Media and in the House of Commons as stating that “Operations Room Staff are frontline.” Clearly there is a breakdown in communications somewhere that requires to and should be addressed. The proposal displays a clear lack of understanding, both by the authors of the Consultation Document and those that they advise, of exactly what the officers who staff the Maritime Rescue Co-ordination Centres (MRCC’s) around the coast actually do. This is certainly due to the fact that those in Senior positions within the MCA have no current Operational experience, have engendered a situation where there is a clear lack of engagement with staff, a dearth of visits by Senior Managers to MRCC’s and no clear sense of direction or leadership. The MCA and H.M. Coastguard in particular, has been in a constant state of flux for the past ten years and subject to review after review. What is needed now is not yet more upheaval and disruption but a clear period of stability with determined, forward thinking and credible leadership, something that is and has been sadly lacking. It is felt that there are too many people, in positions of great responsibility that have their own agendas and are so busy pulling in different directions to suit their own needs that they have lost sight of what this great service stands for and why we are here. Thankfully, the Operational Staff have not lost their focus and it is they who are keeping the service together and recognise the need to drive the organisation forward, not the current crop of Senior Managers who are paid vast sums to do just that. The current consultation proposal, it is felt, is being used to further personal agendas, reduce staff, under the banner of modernisation, but does not address the real efficiencies that need to be made in the MCA. The fact that H.M. Coastguard only costs every tax payer in the United Kingdom £1.33 per annum to run is surely excellent value for money in anybody’s book and Search and Rescue on the cheap. There are other areas where costs could be reduced at no detriment to the front end Operational Delivery and they should be seriously considered. The Emergency Services are “reactionary” in their function and this will not change. H.M. Coastguard, being the fourth “Emergency Service” is no different in this respect. There will be times when officers are sat in the Operations Room awaiting developments, but this does not mean that they are idle. Their own professionalism and drive to be the best will not allow it. There is a lot that goes on behind the scenes and it is this that Senior Managers either do not wish to acknowledge or have no knowledge of because they do not fully understand the business themselves.

1. Introduction 1.1 As everyone in the United Kingdom is aware, this is a period of austerity and having to find economies. All organisations have to look inwards and consider ways of delivering the same business for less money. The Department for Transport in this respect is no different and is also having to find economies. The officers of H.M. Coastguard are fully aware that the organisation must evolve as the Consultation Document authors themselves stated, “This is making our coastline far busier than ever before. We are building much larger ships that are less manoeuvrable and drilling rigs and increasing numbers of wind farms pepper the seas around the UK. As a result our seas are becoming much more congested. Weather conditions are also becoming more extreme, with significant weather events becoming more frequent and severe, making work at sea more perilous and increasing the risk of coastal flooding.” The proposed evolution however must not dilute or lower the standards we currently work to nor increase the risk to the Mariner and General Public. It is felt by Coastguard Operations Room Officers that the current proposals would lower standards and put the safety of not only the mariner but the general public who use the coast for leisure at risk. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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1.2 The proposed new MOC’s, to be based in Aberdeen and the Southampton/Portsmouth area would lead to an unhealthy, stressful and unmanageable working environment. Staffing them initially would rely on the current operational staff being willing to uproot themselves and their families and move. This is clearly not a viable option for the vast majority of staff and would in itself incur high costs in relocation and other expenses. Should this occur, we are then faced with the situation of officers having to be recruited, trained and then gaining operational experience, all at more cost to the taxpayer. The ambient noise level within the proposed MOC would rise depending on how busy the “District Pods” became. The fact that so many radio aerials would have to be monitored by a small number of people would lead to “Distress Calls” being missed, especially as the intention is to have these radios monitored via loudspeaker, rather than via coastguard officers themselves as at present. The noise from the radio loudspeakers would also add to the cacophony of sound that would already be prevalent. 1.3 The vast area of coastline, half of the United Kingdom for each MOC, that officers would require to have knowledge of would tax the most proficient of Coastguard Officer. No matter how good your gazetteer/ database or Google earth is, lives will surely be put at risk and ultimately lost if this concept is allowed to come to fruition. The Fire Service, and more recently West Yorkshire Police, have both investigated, utilised and rejected the “Centralised Control Room” concept and found it wanting. In fact in the case of the Police, public opinion drove them to revert back to the local control room model which surely tells us something. What “secret” technology do the MCA possess which makes them think that they can do what everyone else has failed to do. We should learn from the mistakes of others and not drive ourselves down the chosen path just because we “cannot be seen to be wrong!” Technology is a tool and we must not let it become our master, as over dependence on it can lead to all sorts of problems such as hacking and even worse failure at critical moments. A recently published government report highlighted just this fact, 1.4 H.M. Coastguard is not a Mickey Mouse organisation, nor is it a part time Emergency Service. We are ready to respond 24/7 365 days a year in the same way that our colleagues and partners in the other Emergency Services are. This should not change and the idea of day time only stations is quite frankly laughable. H.M. Coastguard has a long and proud tradition, and was in fact the first emergency service ever created. The Operational staff fully recognise this fact and constantly strive to give their best when called upon. It is worthy of note that although the MCA is quoted as a Category 1 responder under the Civil Contingencies Act, it is the uniformed part of the service in H.M. Coastguard that fulfils that obligation and partner organisations turn to. 1.5 Having only two main centres is not resilient and indeed makes it easier for Terrorists or a disease such as Pandemic Flu to disrupt the service. The failure of one MOC would lead to large areas of sea and coastline unable to be monitored which renders them unsafe. This is clearly an unacceptable and easily mitigated risk. It is recognised by Operational Officers that keeping the United Kingdom in manageable areas would promote safety and ensure a secure environment. This is obviously recognised by Senior MCA Managers because they have been quoted as saying “The stations that we currently have are where they are because they are in the most strategic locations!” Why do we feel the need to change? It can only be cost driven and for no other reason! 1.6 Front line Operational Coastguard Officers are not averse to change as long as it is for the betterment of the service. It is believed that the current proposals are not only flawed but are being driven wholly on a cost basis and are aimed directly at H.M. Coastguard, just as they were the last time the service was reviewed and stations were closed. There is recognition that savings could be made across the whole of the business, with the majority being made in headquarters and across the Regions. It is fully recognised that there is scope for H.M. Coastguard to modernise and improve the service to our partners and customers but not at the expense of safety. As stated earlier, £1.33 per tax payer per annum is not an onerous price to pay for an up to date and fully committed Emergency Service. 1.7 H.M. Coastguard should be expanding their business, not seeking to shrink it. We are exponents of Incident Co-ordination, recognised amongst our partners and the rest of the world, and should utilise our skills to their fullest. For too long we have lacked Senior Managers who are forward looking and visionary. The time has now come when partners are having to save money and cut back on the services they provide. The Department for Transport, of which the MCA is an executive agency, is currently responsible for two thirds of the Search and Rescue delivery within the United Kingdom. It is therefore perfectly feasible that H.M. Coastguard picks up the last third and is responsible for all SAR within the UKSRR. Mountain Rescue Teams (MRT’s) have openly stated that they would be happy to be co-ordinated by H.M. Coastguard. The Police forces responsible for MRT’s would have one thing less to worry about and could concentrate on their core business. Inland SAR providers would work better with H.M. Coastguard because we are recognised as being the experts in our field and extremely proficient. The advent of Personal Locator Beacons (PLB’s) will bring an added dimension to SAR. H.M. Coastguard is fully aware of satellite alerting technology and how to handle it. There is virtually no difference in handling an incident involving an Emergency Position Indicating Radio Beacon (EPIRB) alert from a vessel at sea than there would be handling an incident involving a PLB. The current thinking is to pass the prosecution of incidents involving PLB’s to the Police, who for all their expertise in other matters, are not exponents of utilising the information the PLB’s will impart. This is surely one way that we could expand our core business and bring Search and Rescue under one umbrella, that of H.M. Coastguard. This is the sort of forward thinking that is needed at the Senior Management level, not looking at ways to save a few pounds and in the process endangering the lives of both mariners and coastal users alike. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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1.8 H.M. Coastguard has a long tradition and proud history and we are the envy of the world when it comes to Search and Rescue. For too long our Senior Managers have been inward looking and lacking vision and it has to stop. We should be out there promoting ourselves and utilising the excellent training that we have all undertaken. It has equipped us to become exponents at Search and Rescue and that is what we are. It is time we had Senior Managers who have drive, vision and the same ethos as the Operational Staff. If we do not achieve that then H.M. Coastguard is in danger of being driven into the ground and this service, of which we are all proud to serve, will be destroyed.

2. Current Structure 2.1 The MCA currently provides the United Kingdom Civil Maritime Search and Rescue response through a network of 19 Maritime Rescue Co-ordination Centres (MRCC’s). The 19th centre is MRCC London which consists of one officer in the Port of London Authority building at Greenwich. These are strategically located around the coast and operated by fully trained and professional officers of H.M. Coastguard. 2.2 Currently, Operational partnerships are able to “Pair” fully with the exception of MRCC’s Stornoway and Shetland. There are further restrictions in that MRCC Thames cannot fully takeover from MRCC Dover (CNIS), and MRCC London (which is one officer) cannot fully takeover from MRCC Thames. The ability to pair ensures that during quieter periods, on watch training can be effected without endangering the integrity of the area. Pairing also facilitates mutual support and provides resilience. There has never been an occasion when both stations in the pair have suffered major outages at the same time. The technology that supports this flexibility (ICCS/Vision) is proven, reliable and robust. 2.3 The MCA is currently in the process of a Radio Equipment Refresh (RER) rollout to all 19 MRCC’s in the current set up. The programme is scheduled to complete in the second quarter of 2012. The refresh upgrades the Integrated Coastguard Communications System (ICCS) from Version 12 to Version 19. The upshot of this is that MRCC’s will have the ability to connect to any five other stations within the network, albeit one at a time, inevitably this will give increased resilience and make it harder for terrorists to attack. 2.4 MRCC’s currently operate independently and watch levels are assessed utilising manning levels set by headquarters. This does not take account of the needs of individual MRCC’s requirements and is not fit for purpose. Staffing levels should be set independently, depending on requirements, and not on a one size fits all basis. It is worthy of note that the staffing level in MRCC Aberdeen has been steadily increasing over the past year, ostensibly to take account of the increased work that the Common European Reporting System (CERS) brought. However, one cannot but draw parallels with the staffing required for a MOC and wonder if the ground was being prepared early.

3. Proposed SAR Co-ordination Structure 3.1 A minimum of 14 stations, including London, would be required to maintain the safety and integrity of the whole of the United Kingdom Search and Rescue Region (UKSRR). This equates to approximately 19,500 miles of coastline and 1.75 million square miles of sea area. As stated by Senior MCA Management, “the stations are where they are because they are in the best strategic positions”, however the merger of Solent and Portland has long been the subject of debate within the service and it is only a matter of time before it happens. The station selection should be based on Strategic Positioning, Current and future workload, Staffing Levels and number of actual SAR Incidents. The statistics concerning SAR Incidents should reflect where persons are either assisted or rescued rather than incidents that have been created for exercise purposes, passing information to a co-ordinating MRCC or when an Oil/Gas Platform conducts a routine muster drill every week. The team who were involved with the consultation document that is now in the public arena should have absolutely nothing to do with the determination of the future set up. 3.2 The current ICCS equipment is being upgraded to Version 19 (V19). When the software patch is applied to the system in May, all upgraded stations will have the facility to connect to up to five other stations anywhere in the United Kingdom. This will give greater interoperability, better resilience, higher resistance to terrorist attack and maintain the integrity and safety of the UK coastal area and seas. 3.3 Each of the 14 MRCC’s will operate individually, as they do at present, on a 24/7, 365 days a year basis with approximately 24 Operations Room staff per station. The staffing level for each station should be decided on a Risk Assessment basis which is particular to that station and not a generic National Assessment. The added resilience of being able to connect to up to five other MRCC’s anywhere in the country will enable stations who are busy to have, not only their partner station but any station in the country dial in and help out. This will have the added benefit of officers increasing their skill set, handling incidents that they would not ordinarily handle in their day to day work, and give them access to Rescue Resources that they would not normally task. 3.4 Combining Solent and Portland Coastguards and utilising office space in MCA Headquarters, in Southampton would negate an expensive outlay on a new build at Lee on Solent. The money could be saved and spent elsewhere to enhance the service with spare land at Lee on Solent being sold to raise more capital which could again be invested in the service. The maintenance costs could also be absorbed into the HQ budget, saving even more. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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3.5 Stornoway—Shetland. Both MRCC’s should remain as there are problems with them pairing due to their isolated locations. London—An independent station (with one ofﬁcer on watch) which is unable to fully pair with anyone else. Dover—Unique in that it is the base for CNIS services. Falmouth—The U.K. hub for Global Maritime and Distress Safety System (GMDSS) Alerts, however duties could be shared to allow other stations access for contingency planning and training aspects.

4. Current Staffing 4.1 Each MRCC currently operates a four watch system, which consists of 2 x 12 hour day watches, 2 x 12 hour night watches and four days off. The cycle is then repeated. The staffing levels at each site vary, the levels being set by Headquarters, with MRCC Aberdeen having the largest number of staff. Nationally there are currently 450 Operations Room Staff. In terms of budget and finance, H.M. Coastguard MRCC staff are the smallest group of any Emergency Service within the United Kingdom. 4.2 Every Operations Room Officer is examined and assessed to ensure that their skills, which are utilised on a daily basis, are being maintained. This is carried out through either on station training or actual SAR Incident working. The Watch Manager (WM) of each watch is additionally trained to the Search and Rescue Mission Co-ordinator (SMC) qualification. The SMC is a legal requirement and they are responsible for maintaining co-ordination of an incident from its inception through to the final conclusion. 4.3 The introduction of additional duties, such as Vessel Traffic Monitoring (VTM), Marine Management, Maritime Security, Border Control along with Customs and Excise duties would qualify staff for regrading and subsequent improved remuneration which would in turn settle the ongoing and protracted Industrial Action and not breach the Pay Guidelines set out by the Treasury. 4.4 The Coastguard Rescue Service (CRS), is the volunteer branch of H.M. Coastguard and numbers some 3,500 personnel. They are managed, on a day to day basis by 64 Sector Managers (SM’s). The management of both the MRCC’s and the Sectors in the current Operational Partnerships is provided by 1 x Coastal Safety Manager (CSM) and 2 x Rescue Co-ordination Centre Managers (RCCM’s). These officers also service the Duty Area Officer (DAO) Roster on a one in three basis.

5. Proposed Staffing 5.1 Currently there are three Regions whose only purpose is seen as placing a dog leg in the system and where “Spin” is applied to all and any requests. We should move from a Regional Business Model to a National Model, after all we are a U.K. service. The roles of the Regional Director, Regional Business Manager and Regional Business Unit would become obsolete. It is proposed that the role of Coastal Safety Manager should remain as some, but not all of the CSM’s have a wealth of operational experience and knowledge that should not be arbitrarily discarded. Two new roles should be introduced to support the RCCM, WM and SM. The introduction of the Coastal Support Officer (CSO) and Senior Watch Manager (SWM) would create resilient support for Operational front line officers, both on the coast and within the MRCC. The current structure within the MRCC works perfectly well, is fit for purpose and does not require to be changed. 5.2 The CSO will be a full time supportive role, supporting Sector Managers in their duties and filling in for them whilst they are absent. They would provide continuity for volunteers, and support the RCCM through attendance at Local Resilience Forums (LRF’s) and liaising on the ground with other Emergency Service Partners and Local Authorities. The CSO and RCCM would inherit more responsibility regarding Coastal Volunteer working practices and attend multi agency meetings to improve working practices, procedures and relationships with partners. 5.3 The Senior Watch Manager (SWM) would be selected from within the current complement of each MRCC. They would be the point of contact for the Duty Watch Manager in the RCCM’s absence. The SWM selected should be the most experienced of the four WM’s and rewarded as necessary for any and all time spent working in this role.

6. Coast Rescue Teams 6.1 The Coastguard Rescue Service (CRS) should remain as a volunteer service, managed on a daily basis by the Sector Manager and supported by the CSO. There is no requirement whatsoever for yet another layer of management above the SM as proposed in the current Consultation Document. SM’s have been asking for years for support in respect of administration and other duties so that they can devote the majority of their time to training the CRS. This proposed structure will give them that freedom and ensure that our volunteers are more motivated and highly trained to perform the functions that are asked of them. 6.2 Modernisation of the CRS is a recognised requirement and could easily be instigated and provided for. Technology currently on the market and freely available, such as Mobile Data Terminals ﬁtted in the Coastal Response Vehicles or portable E-Pads when the teams are on foot, would greatly enhance the interaction between Operations Room staff and the CRS during incident working. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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6.3 This is modernisation at low cost which will add resilience on the coast. The equipment is readily available and will improve communications between the Co-ordinator and the responder. Other Emergency Service partners are utilising similar equipment at this time with no detriment to service delivery.

7. Training 7.1 The entry level of Coastguard Training is at MSAR(F) and this takes approximately one year to complete. At the end of the year the officer takes examinations and is then established in their role of Coastguard Watch Assistant (CWA). If we use the example of the Merchant Navy or the Police, then officers could be trained to fulfil the function of the grade above theirs. This would give us a bank of qualified officers who would be able to step in when the need arises and mitigate or even reduce the risk associated with placing unqualified staff in positions of responsibility that they are not properly trained for nor tested in. 7.2 Training courses for Operational Staff should not take place during the busy summer months. This has been an ongoing problem for a long period of time and seriously depletes the watch bill in MRCC’s when leave and sickness is also taken into account. 7.3 A team of training staff could operate from a designated MRCC or from the current Training Centre in Highcliffe. The staff could organise to visit stations and monitor or assess skills and standards or even cascade new methods of working. Computer based training in the form of E-Learning could also be made available to officers throughout the year. This would alleviate the high financial drain on travel and subsistence expenses and shrink the carbon footprint of the agency considerably.

8. Information Technology and Equipment 8.1 The bane of every Operational Coastguard Officers life is I.T. support, or more importantly the lack of it after 16:45 each weekday and virtual non-existence on a weekend. There is a duty I.T. roster, however it is dependent on the duty person having access to the Internet and being able to connect to headquarters. It is proposed that each MRCC has an I.T. Support Officer to cope with day to day problems and faults. This function could be fulfilled by a regular member of the watch who has the requisite knowledge, ability and literacy to carry out tasks on station. They will still have the backup of the I.T. specialists in headquarters but the establishment of the on station person should aid greatly in improving reliability and resilience. 8.2 The RER has enhanced the performance of the Operations Room equipment and given us greater resilience than we had before. Version 19 of the Integrated Coastguard Communications System (ICCS) now enables any MRCC in the country to connect to up to five others of their choice, albeit one at a time. This has greatly enhanced reliability and resilience, mitigated and virtually eliminated the risk of terrorist attack or hacking and ensured that Operations Room Officers will now have access to incidents that they would normally deal with.

9. Partnership Working 9.1 H.M. Coastguard Operational staff have always recognised the importance of partnership working and engaging with colleagues from the other Blue Light services. Relationships, which have been built up over a long period of time by MRCC staff with other agencies such as Police, Ambulance, Mountain Rescue, Fire and others ensures that when the chips are down and a multi-agency response is required we can all work together to achieve the common goal. 9.2 As previously stated, H.M. Coastguard should be looking to expand its core business and work with other regulatory bodies concerned with the Maritime sector. More and more, Operations Room Staff are being asked for assistance by partners when they are looking for a particular small vessel of interest or even to ascertain whether a certain ferry is carrying a certain trailer or person. The United Kingdom is an island nation and with such a vast coastline, with many isolated landing sites, there is the potential for terrorists to come and go as they please. We should be looking to engage more fully with our colleagues in the Border Agency, Special Branch and Counter Terrorist Units as it is readily recognised in those communities that the biggest threat to the security of this country is the Maritime Sector. MRCC Liverpool is heavily involved in this aspect of work and is widely respected throughout the North Wales and Northwest Area as a vital source of intelligence. This is yet another example of forward thinking and having a clearly deﬁned direction. It may be that we can even building share with other agencies and reduce costs all round.

10. Income and Savings 10.1 By far the biggest drain on the budget of the MCA is the Planned Maintenance aspect. The money that is spent on this just beggars belief and certainly does not represent value to the taxpayer. When it costs approximately £450 to have a ﬂuorescent light tube changed in a building in Kirkcudbright, with the contractor travelling from Manchester, then serious questions need to be asked. The idea of spending that amount of money on a £6 light ﬁtting that could have been dealt with locally is insane and needs to be stopped immediately. Maintenance budgets should be delegated to the relevant RCCM for the MRCC and SM for the Sector Bases. It was the case in the past, before centralised negotiated contracts, and should be returned to in the fastest possible time. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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10.2 The Offshore Renewable Energy Sector is exploding and as such is cutting down on the amount of sea room that is available for shipping. This in turn leads to higher concentrations of vessels all trying to sail in the same part of the sea. The Eastern Irish Sea Basin has a particularly high density of wind farms, with more programmed to be built and current operations being extended. The companies have offered to pay for the construction of a VTS Radar and its installation in MRCC Liverpool, however the current MCA Senior Managers saw ﬁt to decline this offer. In view of the current Consultation Document it is plain to see why. This decision should be reversed immediately and the VTS installed in MRCC Liverpool. It is among the busiest MRCC’s in the country with a high density of shipping and an ever burgeoning offshore renewables sector. In the agencies own words, the seas are getting busier and the potential for disaster is increasing exponentially.

10.3 The abolition of the Regional Structure, coupled with the removal of the Director of Maritime Services post would save money and remove a lot of obstructions in the chain of command. The MCA is top heavy with management and support staff and is crying out for rationalisation and downsizing. The last thing that we need is another layer of management and therefore the idea of placing a manager above the Sector Manager should be discarded out of hand! We are a small organisation and appear on our parents’ balance sheet as “Miscellaneous!” The MCA handed back £8 million to the DfT because they wanted to get used to not having the money! That to an Operational Ofﬁcer, who it is readily acknowledged is poorly paid, seems ridiculous and looks like someone trying to make a name for themselves. The money could have been used to purchase much needed new vehicles for the Sector Managers, some of whom are driving around in “W” registration cars with over 100,000 miles on the clock! Repairs cannot be done to other vehicles or buildings because there is no money in the kitty. What sort of message are we sending out to our partners and the tax payer when we can’t even afford to ﬁx dents in vehicles?

11. Conclusions and Summary

H.M. Coastguard is an internationally recognised brand and one that the Maritime Sector is fully conversant with. When called upon to support our partners, they know exactly what we do and how we do it. The service does not need to be decimated just to save a few pounds. Instead, our Senior Managers should be going to their masters and asking for more money. The lack of drive, vision and forward thinking in the upper echelons of MCA Management (with the exception of the current Chief Executive) just beggars belief. We should be driving ourselves forward and taking on SAR Co-ordination Nationally. After all, it is what we are trained for and what we are extremely skilled exponents of. — The current consultation process should be stopped and discarded. It is perceived by the vast majority of Operational staff as unsafe and unworkable. — The current set up should be reduced to 14 stations working on a 24/7, 365 days a year basis. — The authors of the current consultation document should not be allowed to have an input to any new proposal. Operational staff should be fully engaged in any change process. — H.M. Coastguard should additionally assume co-ordination for Mountain Rescue, Inland Flooding, Inland Waterways and Personal Locator Beacon Alerts. This would ensure a consistent approach to SAR throughout the UKSRR. — The Regional structure should be disbanded immediately along with the post of the Director of Maritime Services. Headquarters staff should be rationalised commensurate with the size of the organisation. — Sector Managers should be supported by an ofﬁcer below them to aid in administration and freeing the SM to concentrate on training. There is absolutely no requirement whatsoever for yet another layer of management. — H.M. Coastguard should be a forward looking and visionary service. We should be fully engaging with partners and stakeholders to ensure, that the very best service is delivered to those that require it by those who are exponents of it. April 2011

Written evidence from Country Standard (MCA 92)

On behalf of 5,000 supporters and members of Country Standard we would like to register our opposition to the closure and cuts in the Coastguard service which we believe would jeopardise lives. April 2011 cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from the British Ports Association (BPA) (MCA 93) Summary of main conclusions: — We believe that the Coastguard needs reform and change and support the programme outlined by the MCA. — A signiﬁcant minority of BPA members is nevertheless concerned about the impacts of the changes, particularly in more outlying areas. — We are critical of the handling of policy on ETVs and MIRG and the lack of consultation and risk assessment. We are grateful for the opportunity to make our views known to the Committee on these issues. The BPA represents 84 port authorities located throughout the UK and this response is written from a UK perspective. These views can only be made on the basis of our judgment as ports; other parts of the maritime sector may have different views, but this response is about our estimation of any direct impact on ports and port operations

Modernizing the Coastguard 1. The majority view within the BPA is that modernization of the Coastguard is a needed reform. We agree with the MCA’s analysis of the way in which technical changes and improvements in the way in which staff are trained and developed can be integrated into the way the Coastguard operates. We support the proposal to set up two maritime centres and believe that this can provide an appropriate and effective approach to Search and Rescue response abilities. At the same time, we have no views on the choice of sites for sub-centres and believe this is a matter of judgement for the MCA. 2. Furthermore, we believe that the new roles and responsibilities for Coastguard officers as set out in the proposals represent a potentially helpful change. We support the intention to produce better trained officers with more fulfilling careers and improved career prospects. We also agree with the principle, as set out in the consultation, that the focus should be on front line operations. On the assumption that the number of personnel on the front line will increase, it is however vital that their skills, and especially their local knowledge, are fit for purpose. The possible threat to the store of local knowledge, an asset of current arrangements, has created some concern. 3. Nevertheless, we have two caveats. The first is that in making changes, there is no expectation that ports will in any way take on Coastguard duties, or be expected to fill any gaps that might result from the unintended consequences of the changes. It is crucial that the changes are self-contained within the MCA and will require no additional action from other organizations. One of the aims of our response to the MCA consultation will be to have a confirmation that this is the case. 4. The second caveat is that there is a significant minority of BPA members who have expressed strong concerns about the impact of the proposals on safety at sea, on local communities and on the environment. This is particularly the case for more outlying areas of the UK. They were also concerned about the fragility of communications systems in the more outlying areas, and increasing examples of broadband, mobile and BT mainline failures which could jeopardize the MCA’s intended programme. Assuming the changes go ahead, and bearing these issues in mind, it might be preferable if they are carried out in stages to ensure that new arrangements are working satisfactorily and that the transition is as smooth as possible.

Emergency Towing Vessels (ETVs) 5. Irrespective of our views on the merits of the government’s policy towards ETVs, we were disappointed with the way in which this issue has been handled, with an announcement made without any prior notice or consultation. A non-negotiable decision appears to have been taken, driven by the needs of the spending review. We have not had any evidence from the MCA that the removal of ETVs does not constitute a safety risk and we are seeking assurances from the MCA that this is the case. 6. Consultation amongst our members suggests that the removal of ETVs does not pose any particular threat to ports, and the chief interest in the change will come from the shipping sector. As with the Coastguard proposals, it will be completely unacceptable for ports to be expected in any way to ﬁll gaps which might have been left by the ETVs decision. Of course ports would wish to play their part if an emergency arose based on their own assessment of the risks to their personnel and tugs. But there must be no obligation on ports to act and again we would be interested to see whether the MCA has assured itself before the decision was taken that this is the case. In spite of our concerns about the process, we do acknowledge the efforts made by the MCA subsequent to the announcement to seek views from the industry. Another meeting in Glasgow is due to take place later this month.

Marine Incidents Response Group (MIRG) 7. Our reaction here is very similar to our reaction to the way in which the ETVs issue has been handled. We know of no ofﬁcial consultation from the MCA on the future of MIRG, nor are we aware of any unofﬁcial cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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contact seeking views on its future or the consequences of change. The only information we have is contained in the DfT’s transport spending review of 20 October 2010, that MIRG would be reviewed and a consultation would follow with detailed proposals.

8. Nevertheless, we believe that this issue is substantially one for shipowners to address. The MIRG team provide fire fighting advice and expertise to assist a ship’s crew in dealing with a fire at sea. As we understand it, this would extend to when a vessel is on a passage to a berth and within port limits. The local fire brigade will respond when a vessel is alongside, but are not in normal circumstances able or willilng to deal with a fire at sea. So there is a lack of clarity about, for example, which service would be responsible for a ship at anchor in a port area. We would expect a consultation to expose these issues, assuming such a consultation takes place. All in all, we believe it is unsatisfactory for a service to be identified as being part of a round of cuts, but then subsequently left in limbo until a consultation is launched and decisions taken. April 2011

Written evidence from MRCC Belfast Watchkeeping Staff (MCA 97)

1. Northern Ireland

1.1 The MCA Proposal has seen widespread condemnation across the whole of Northern Ireland, this has brought all political parties together to lobby for the retention of a full time Coastguard coordinating presence within the province. An online social networking group has gained 11000 persons joining a cause to see the retention of Northern Ireland’s only Coastguard Rescue Coordination Centre.

1.2 According to the list of consultees the MCA failed to consult with the Northern Ireland Assembly, Police Service of Northern Ireland, Northern Ireland Ambulance Service or the Northern Ireland Fire and Rescue Service. These are emergency service partners and the withdrawal of the Coastguard from Northern Ireland would have a major impact on their operations.

1.3 The plans do not take account of the unique geography, culture, social and government structures and legislation in Northern Ireland (NI) which, taken with the large coastline and bodies of inland waterways, would make it extremely difﬁcult to manage effective coastguard operations without a full time MRCC in NI.

1.4 The Royal Yachting Association (RYA) in their response to the consultation also states “we would add that given the unique situation in Northern Ireland, careful consideration should be given to the merits of retaining a physical presence there to ensure that optimum coordination of current and future cross-border agreements and services are maintained on an all-island basis.”

2. Staff Numbers v Incident Numbers

2.1 From Freedom of Information Act reply published on the MCA website: “The Coastguard Modernisation proposals provides for 48 watchkeepers at periods of peak demand. This will be flexed from a pool of 238 watchkeepers (excluding London). The analysis reveals that 43 watchkeepers are required to cope with peak demand. This is based upon a typical SAR incident concurrency on the busiest day recorded, projected forward to 2015 at expected growth rates. It identifies an averaged growth of 3% per annum for SAR. Counter pollution activity is shown to be steady over time. The growth in shipping is averaged at 3% over the previous decade. Data sets for SAR concurrency are based on 2006. This was a busy year, influenced by an extended period of fine weather, and data capture was not corrupted by industrial action. Counter pollution data is taken from NAO data. Traffic monitoring data is derived from current data derived from AIS and CERS. As the effort required to conduct different incident varies an over estimation of the number of watchkeepers required has been factored in. Additionally, the analysis notes that not all work is time critical, can be prioritised and be undertaken concurrently with other tasks. This efficiency smoothes the huge peaks and troughs in loading experienced currently by watchkeepers.”

2.2 We believe this number of required watchkeepers is incorrect. Coastguard Watch Managers are required to hold a Search & Rescue Mission Coordinator (SMC) qualification. The MCA trains staff in the qualification of SMC. During these scenarios at least four persons are required to conduct the operations satisfactorily. Some incidents, we agree, could be managed with single operators but the vast majority of incidents require a team of between three and five operators to complete a successful mission.

2.3 With the introduction of Vessel Trafﬁc Monitoring in addition to Maritime Safety Advice, routine enquiries and many more demands on operator’s time, we believe a number approximately double of the MCA expectations would be required to successfully manage incident numbers during the highest incident demand. Future growth also needs to be taken into account. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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3. Staff Relocation & Retention 3.1 With the proposed positioning of the Maritime Operations Centres (MOC) and with very limited numbers in the sub-centres, staff will have very little opportunity to remain within the service. This will inevitably lead to very capable and experienced staff leaving the service for other employment. 3.2 Watchkeepers have already begun to leave the service, which will probably result in dangerous manning levels at some stations. This could lead to overloading in the short-term, with staff being overwhelmed and unable to cope with demand. Ultimately this could lead to loss of life, which would most definitely not be the fault of the remaining staff and would cause undue stress on an already unsettled workforce. 3.3 As the locations of the proposed MOCs are in two of the most expensive parts of the United Kingdom, staff will find locating to these areas difficult. Informal inquiries have indicated that very few staff will be prepared to move to these areas, ultimately resulting in extremely inexperienced operators managing a UK wide Search and Rescue infrastructure.

4. Technology 4.1 Much has been stated about future technology assisting in the coordination of incidents. Systems such as Google Earth have been mentioned to replace local knowledge. Google Earth is not compatible with Government systems as the software is updated too frequently. Every update would need to be tested prior to being implemented as with other systems. In the past ofﬁcers have asked for such a service to be provided in the Operations Rooms only to be told that it is not possible. 4.2 Current web browsing systems are out of date, with Operations Rooms using Internet Explorer 6, again the reason being that newer operating systems are being tested before being implemented. If the MCA cannot update a web browser they will never be capable of running a frequently updated GIS system.

5. Grades 5.1 It has been recognised for a long period that staff within HM Coastguard are the lowest paid emergency service operators in the United Kingdom. The CWA grade is the equivalent of a civil service AA grade. These ofﬁcers have to complete intensive training and qualify with examinations, answer difﬁcult and sometimes distressing emergency calls and operate sophisticated communications and incident management systems, yet they are often paid at the minimum wage. 5.2 The MCA is intending to implement different grades within the proposed modernisation program which will ultimately make the CWA grade redundant. 5.3 We suggest the Transport Select Committee requests the following information: (A) How many AA grades are based at MCA HQ Spring Place? (B) How many AA (CWA) grades are based at MRCCs around the UK? (C) How many EO grades are employed at MCA HQ and, of those, how many manage three or more staff? (D) How many EO grades are employed at MRCCs and, of those, how many manage three or more staff? 5.4 We believe the answers will indicate that the MCA is and has for many years been discriminating against Coastguard watchkeepers around the United Kingdom, whilst ensuring that MCA HQ staff are adequately remunerated.

6. Alternative Proposal 6.1 The staff at Belfast believe that, even if ﬁnancial constraints are unavoidable, the MCA proposal for the modernisation of the Coastguard is unworkable for many reasons. We (and others) have created an alternative proposal which, we believe, more adequately addresses issues such as safety of life, regional representation and expertise and the roll-out and completion of the modernisation program. This alternative proposal allows for maritime rescue coordination to remain on a 24/7 basis in all the devolved administrations, making it more politically acceptable. 6.2 Whilst it would be regrettable for stations to close, there are issues regarding some station’s tenancy which require immediate attention to ensure that those areas of the coast are adequately covered for search and rescue.

Executive Summary of the Proposal It has been created by highly motivated front line staff that wish to ensure the safety of life, the environment and the reputation of the Coastguard in the United Kingdom. This proposal suggests: One 24 hour National Maritime Operations Centre—Southampton; 5 x 24 hour Maritime Rescue Coordination Centres; cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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MRCC Scotland; MRCC Wales; MRCC Northern Ireland; MRCC North England; MRCC South England; 4 x 24 hour Maritime Rescue Sub Centres; MRSC North Scotland; MRSC West Scotland; MRSC North England; MRSC South England; and London Coastguard operating as today. (MRSC London) A National Network tested in parallel to the existing which, when fully implemented, will deliver a truly ﬂexible system offering full resilience and mutual support. A copy of the proposal is attached for your attention.13 April 2011

Written evidence from Mike Lacey (MCA 98) I am writing in respect of: 1. The Government’s declared intention to terminate the UK Emergency Towing Vessel, (ETV), agreement in September. 2. The proposed cuts in HM Coastguard stations around the UK. I hope that my comments below will assist you in your deliberations. I set out below details of my career and background which is why I consider I am able to comment on these matters. I am a UK Master Mariner, and from 1959 I served at sea for 10 years with a British cargo liner company, then from 1969 to 1981 I worked in London as a Marine Consultant to maritime lawyers dealing with shipping incidents, (collisions, salvage, total losses, etc). From 1978 to 1981 I was the Assistant Legal Adviser to the International Salvage Union, (ISU), the Association for the world’s marine salvage industry. During this period I was the ISU’s representative in the industry discussions leading to the Lloyd’s Form 1980 Oil Tanker “Safety Net” Clause, and I also participated extensively in the deliberations which led to the 1989 Salvage Convention. From 1981 to 1992 I was Managing Director of United Towing Ltd., which company was then the UK’s leading ocean towage and marine salvage company. I was also the UK Adviser to NATO on Salvage Services in Wartime. From 1992 to 2005 I again worked in London in maritime law, speciﬁcally dealing with marine salvage. From 1984 to 1992 I was an Executive Committee member and later the ﬁrst Vice President of the ISU, and from 1992 to 2005 I acted as Special Adviser to ISU. In 2005 I was appointed Secretary General of the ISU. During all of this time I have been closely involved in matters and all developments relating to Salvage, Lloyd’s Form, the Special Compensation P&I Club, (SCOPIC), Clause, as well as the on-going industry discussions concerning Environmental Salvage. I have also closely followed the changes which have taken place in the international ocean towage and salvage industries since 1981. I must emphasise that the contents of this letter are strictly my own views, and cannot be attributed to the ISU.

THE EMERGENCY TOWING VESSEL Background 1. It was the South Africans who ﬁrst instigated the concept of Emergency Towing Vessels, (ETVs). With the closure of the Suez Canal in 1967 and the increasing size of oil tankers, they realised that their coastline was at serious risk of pollution damage. The South Africans were driven to this conclusion as they were dependent upon Dutch, German and British salvage companies, (Smit, Bugsier and United Towing), keeping a salvage tug or tugs on station in South African waters. If the tugs sailed away, South Africa had nothing. 13 Proposal made available in the Parliamentary Archives. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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2. As a consequence in the early 70’s they drew up plans for two “super-tugs”. These tugs were delivered in about 1975 and placed under the control and management of Safmarine. They were the “JOHN ROSS”, now “SMIT AMANDLA” and the “WOLRAAD WOLTEMADE”, which was recently scrapped after 35 years service. 3. Since that time at least one of these tugs has maintained station on the South African coast, and they have been involved in some incredible salvage operations in respect of damaged VLCCs and ULCCs, thereby safeguarding the South African coastline. “SMIT AMANDLA” is, at the time of writing, at Tristan da Cunha, in the South Atlantic, where a large laden bulk carrier ran aground last month. 4. Following the “AMOCO CADIZ” incident off Brittany in March 1978 the French government arranged for two new Swedish “super-tugs” to be placed on station at Brest and Le Havre. The tugs were operated by French salvors Les Abeilles. 5. Recently Les Abeilles have taken delivery of two state of the art high powered salvage tugs which are based at Le Havre and Brest, and they now operate five ETVs for the French Government. The ones at Le Havre and Brest, plus one in the southern Bay of Biscay, and two on the Mediterranean coast. 6. During the 1990’s and later, more coastal states realised that they were exposed to the threat of environmental damage in the event of a shipping incident. The Dutch placed a large powerful salvage tug on station, and whilst the original tug recently suffered a serious fire, it has been replaced. The Germans have two such tugs, one in the North Sea and one in the Baltic. One of these tugs is another very powerful new building “super-tug”. 7. The Norwegians have about six ETVs, commercial and Coastguard units, covering the Norwegian coastline. 8. The Spanish have a large number of ETVs covering their Atlantic and Mediterranean coastlines and the Canary Islands. 9. The Australians have a dedicated ETV based in Queensland to protect the Great Barrier Reef National Park. In addition in each major Australian port there is a nominated powerful harbour tug, to act as first response in a marine incident. 10. The Japanese do not have ETVs, but do have station keeping salvage tugs funded through the Japanese marine insurance industry, as well as through their commercial operations. 11. The Chinese have a vast fleet of tugs and helicopters dedicated to safety of shipping and protection of the environment.

The UK ETVs 1. Following the “BRAER” incident the Government of the day placed ETVs on station on the UK Coast. Initially there were two, and later this was increased to four. 2. After the “SEA EMPRESS” incident the Government implemented a number of recommendations made by the late Lord Donaldson. Among the recommendations was an improved Command and Control system through the appointment of the Secretary of State’s Representative, or SOSREP. From my personal knowledge I know that this system is the envy of the maritime world, and is supported 100% by the maritime salvage industry. It is a system that works. Many other maritime nations would like to implement such a system, but are restrained from doing so. 3. The system is backed up by the SOSREP having at his disposal the four ETVs. 4. Whilst the UK is a small nation, it has a lengthy coastline, some 7,720 miles, excluding islands and indentations. By comparison Norway has a similar coastline of 1,650 miles; France is 2,142 miles, Spain 3,100 miles and South Africa 1,749 miles. 5. UK waters see a high density of shipping trafﬁc, bound either for the UK, or for northern Europe or the Baltic states. This shipping includes the largest oil tankers and bulk carriers, the largest container vessels, very large cruise liners, as well as LNG and LPG tankers. All of these vessels represent a threat to the environment in the event that they encounter a problem, and it is in this respect that the role of the ETV is so vital. 6. The whole purpose of stationing ETVs around the UK coast is to provide the best possible protection for the UK coastline from environmental damage following a shipping casualty. They allow the SOSREP to exercise his powers of intervention at the earliest possible opportunity. 7. The Minister, Michael Penning MP, has stated that it is not the role of the UK Government to provide salvage services to ships in trouble. This is a distortion of the role of the UK ETVs. The primary role of any vessel when there is a casualty at sea is safety of life, but for the ETVs the next most important role is safeguarding the UK coastline from environmental damage. 8. The use of an ETV may give rise to a salvage situation, but in the majority of cases the salvage element has been taken over by a salvage company, bringing in their own equipment and taking over from the ETV. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Indeed so far as I am aware, the ETV Contractor is not permitted to utilise an ETV for salvage purposes. He is obliged to provide a substitute tug in order to release the ETV back to its primary role. 9. A further point which I understand has been made by the Minister is that there have not been very many incidents where the presence of the ETV was crucial. To dispense with ETVs on this basis is on a par with saying that as my house has never caught fire I will not bother in future to insure against fire. 10. Without the ETVs the UK will be dependent upon; (a) Harbour Tugs: These are of modest power and range compared to the ETVs. In addition many are usually only manned by four crew, sometimes less, very few of whom will be experienced in offshore salvage situations. The crewing level is insufficient for them to place personnel on board a casualty for making fast the tug, as is often necessary in shipping incidents. (b) Offshore Support Vessels: There are many of these operating in the North Sea, some of considerable power. However they are not always freely available due to their commercial commitments, and they are far removed from the more exposed Western Approaches, Channel and Dover Strait. In addition they operate with limited crew numbers, who will rarely have the experience of dealing with disabled vessels, perhaps close to the shore in rough weather. (c) The private salvage industry: These days there are very few salvors operating ocean-going high powered salvage tugs. There are two Greek salvage companies that do maintain tugs on salvage station, but at present the nearest of these to the UK are at Gibraltar and the Azores. Other salvage/ towage companies do on occasions station a tug in the Falmouth area, but this is usually when the tug is between towing jobs. There can be no guarantee that any such suitable tugs will be available. It will depend upon market forces. (d) The fact remains that whilst the UK East coast probably has sufficient resources to deal with any maritime incident, the South coast and Western Approaches will be dependent upon assistance from the French ETVs, or the occasional salvage tug in the Falmouth area. The West coast will be at the mercy of the safety record of shipping and the wind and tide. The Northern coast will be similarly exposed.

Costs 1. I believe the annual cost of the ETVs is about £ 10.6 million. This is very cost effective protection, particularly given the reduction in size of the Royal Navy. In addition the current ETVs are very suitable for use as training vessels, patrol vessels, etc so the costs could be deferred by making use of the units on other tasks. 2. No doubt the costs could be further reduced by inviting the Scottish Government to cover the costs of the two ETVs based in Scotland. 3. In recent times the total costs of tanker incidents in or near UK waters has been: AMOCO CADIZ US$ 282,000,000 BRAER US$ 83,000,000 SEA EMPRESS US$ 60,000,000 ERIKA € 129,699,000 to date 4. The International Tanker Owners’ Pollution Federation, (ITOPF), has calculated that the costs of cleaning up oil spills, excluding the “EXXON VALDEZ” in USA, average £ 3,000 per tonne. So the annual cost of the ETVs roughly equates to the costs of dealing with an oil spill of about 3,500 tonnes. Well below the fuel capacity of a large cruise liner or container ship. 5. It is also worth remembering that the Spanish government put forward claims of over€ 968 million for clean-up expenses following the “PRESTIGE” incident off the north west coast of Spain. 6. The presence of an ETV does not mean that it can prevent every incident developing into a catastrophe, but it does give a genuine capability to respond quickly and effectively, with skilled mariners, and the right type of equipment.

Conclusions I believe that the proposal to terminate the ETV Agreement has been seen as a quick way to save money within the Department of Transport, but without thinking through the potential consequences of such action. It is 17 years today since Lord Donaldson’s Report on Safer Ships, Cleaner Seas was published. Much has changed since then. The threat to the coastline is as present today as it was then, and it is not just from errant oil tankers, but also from the potentially far more damaging cocktails of chemicals and dangerous cargoes carried on container ships, or from the huge bunker capacities of new cruise liners, container ships and bulk carriers. I strongly recommend that the Committee use its powers to call upon the Government to reverse this foolhardy decision. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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HM Coastguard The primary role of the Coastguard is safety. On the coast they are there alongside the Police, the Fire Brigade, the Ambulance Service and the RNLI. They are a 999 call away. I understand that the decision to close down so many Coastguard stations is now under review. Hopefully the Government will recognise that this was another short-sighted proposal. In this electronic age the Coastguard could probably be run from a building in the middle of Poland, but what must surely be taken into consideration is the need to be able to rely upon local knowledge. Such knowledge does not come out of a book or a computer, it is gained the hard way, by being there through all weathers and in all sorts of situations. It is impossible to believe that anyone can expect a Coastguard system to operate with only two 24 hour stations, about 500 miles apart, and with only ﬁve sub-stations operating during daylight hours only. What is so special about daylight hours? Is there some presumption that everyone is tucked up in bed once it gets dark? These proposals are complete madness and must be rejected. Savings have to be made in the current economic climate, but not this way. There have to be ways of cutting back through the excessive expenditure of some Government departments without strangling vital safety operations. I hope my comments are of some assistance, and will be pleased to respond to any questions you may have. April 2011

Written evidence from Louise Pooley (MCA 99) I am writing, with very many concerns over the proposals put forward by the MCA for the modernisation of the coastguard service. I’m very sure I speak for many others with the concerns I have. 1. The MCA consultation document has flaws, which concerns me that the MCA haven’t done their homework, so to speak, before its publication. The proposals state that the service was last reviewed 40 years ago, this information isn’t correct. During the 1990’s the coastguard service underwent a major review, the focus for change review in 1998 which was at the time the most detailed, and thorough review for decades, into the structure, workloads and running of the service. There is an ongoing programme of continuous, technical improvements, to upgrade its technology and communication systems, with upgrades being rolled out even now, which has continued since then. 2. I’m aware that most coastguard officers are happy that change, is part of the natural process of such work, however The complete closure of stations situated in vital locations, such as Milford Haven, Holyhead and Shetland is a very Worrying idea. The MCA keep saying, both in the document, and in the public meetings, that there is a requirement for National resilience, which will provide cover if a pair of stations go down, not that both of the stations has ever had this problem, and when one has gone down the other has coped with it, as was in the case of Falmouth when it was hit by lightening, calls and all obligations were diverted to its paired station at Brixham, it worked and it was resilient. The benefit of this being the paired station has the local knowledge to be able to provide more than adequate cover. A major concern over changing this arrangement, to just Swansea during the day and two MOCs at night, firstly, Swansea albeit in Wales, would have a substantial amount of coastline it would have to cover, and would need a significant amount of training to be able to know that coastline inside out. Also the coverage by the MOC’s at night, would mean a lack of the all important very local knowledge. Details such as the tiny unmapped bays and caves, that are often known locally by “pet” names. 3. Coastguard officers are examined every two years in their local knowledge, and each station makes it their business to have a very thorough knowledge of their area. Milford Haven tests is officers on a yearly basis, this is on the direction of local area management and I would guess they obviously feel the need to do so, with the station being situated on a very rugged coastline, and being in the UK’s only coastal national park, which attracts thousands of visitors each year. 4. The MCA have said that the local knowledge will be provided by the RNLI and volunteers in the coastguard rescue service, this is true to some degree, and they have a very good knowledge of their area. Unfortunately they are not the first point of contact when a 999 call comes in, that is the MRCC’s job to know where the incident is, and to have the knowledge to know which is the best lifeboat etc to send to deal with it, and also to know exactly the area they are required in, they then co-ordinate with the MRCC to assist in the rescue and recovery of a casualty. At the MCA meetings they have been asked many times about the issue of very local knowledge with the response that they’ll have the technology and training, I believe that the training they will get is not enough, the local knowledge used now is only gained by experience of working and living in that area of the country. In the initial 999 calls, a decision is made in seconds, where to send the help and the technology is just a tool to assist in the location, and to confirm as required, local knowledge is the primary method, and this will be lost if MRCC’s are closed, leading to endangered lives and slower response times and ultimately more deaths. Seconds save lives. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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5. I am also concerned that the volunteer coastguards and RNLI haven’t been consulted on whether they are happy with the proposals, with some staff feeling they are not able to speak out for fear of being victimised. I know a couple of volunteer coastguards and they are not happy to go out on shouts without the back up from the local team. They work closely together they understand each other, knowing how they work and have the trust that is only gained from having actually met someone. The MCA proposals say they are going to rely more heavily on volunteer teams, and sadly some of those volunteers have said they will not continue to volunteer if they haven’t got the local team behind them. There is also the availability of the volunteers, a lot of them have other jobs so won’t to be free to cover the extra demands placed on them. 6. There is a very real concern over very similar sounding names, some of which a caller may or may not be able to spell, and also the “pet” names for places used by fisherman and the like, names which the local MRCC would know, but you won’t find it on a map, but the locals will use these names in an emergency situation. The MCA have said that there will be technology with phonetic spellings, but try putting a welsh place name into google translate and getting it to tell you what it says, it comes out nothing like how it’s pronounced at all. The coastguards in the MRCC’s also have the depth of local knowledge that is required if a call comes in with just a geographical description of where the incident is and they are able to locate them, this isn’t something an officers in Southampton would know unless they had spent many years holidaying in the area or had lived there. 7. The lack of risk assessments the MCA didn’t do before releasing the consultation documents is reckless. On visiting Milford Haven Coastguard centre on the 15th anniversary of the Sea Empress disaster, Sir Alan Massey was asked if a risk assessment had been done on the presence of LNG in Milford Haven, Sir Alan Massey replied “what LNG?” and unfortunately this was tried to be ignored at the public meeting, suggesting he meant something else, when it was very obvious from those there exactly what he meant. He didn’t seem to know that one of the busiest ports in the UK, which has been having LNG tankers since 2009, even had such a thing let alone carried out a risk assessment on what effect the closure of Milford Haven Coastguard station could have on the area. There is also an increase in the amount of, not only of shipping and leisure users, but also of visits from cruise ships, something Milford Haven Port Authority is keen to expand, it is an enormous boost to the local economy, last year there was six and so far this year there are 10 booked in bringing in excess of 5,000+ passengers, that’s a lot of lives to be playing with. So with things being put in place to boost the economy, why put the very ones who are improving it, in an environment that isn’t as safe. 8. Milford Haven coastguard station covers from the river Towy in Carmarthen to near Froig at which point Holyhead take over, they then cover round to the River Dee, so between these two very important stations they cover part of south Wales, and right up the coast round the top of the north Wales coast, that’s a lot of coast and it also has a very popular coast path, which is extremely narrow in places and very near to cliff edges. 9. Many individuals who use the waters round the coast in clubs, and on their own will check in with the coast guard when they leave, and give an estimated time to be due back this is also a safety thing. It isn’t going to be very practical to call Swansea or Southampton from elsewhere in wales to check in, apart from the fact that there will be significant extra calls to these stations, I doubt that if someone did check in that it would be remembered what time they are due back, as the officers are far more likely to be occupied with other things, people would feel deterred from contacting them and maybe would not bother, when they always had before, it increases the risk of an accident and no-one knowing till too late. Sheryll Murray MP’s husband was due back at 7pm he wasn’t back so a search was sent out for him, tragically they found his boat with him on it, the boat was recovered. This could’ve been hours longer if he hadn’t said what time he was due back. Our condolences are with Sheryll. A lot of sea users check in with the coastguard, and it also gives a sense of security that someone is watching out for them, that just wouldn’t be there if these stations closed. There is no way a call centre in Southampton or indeed Aberdeen—if Southampton failed—could reasonably say they know who has called in, who is out, what time there expected back and whether or not they have returned. The local knowledge of where they are headed is given to the coastguards which is reciprocated by the local knowledge each MRCC has. The local MRCC also often know the routes that certain clubs make regularly take. When out the regular users update the coastguard with the conditions they see while they are out, so even if forecast have not predicted fog for instance in the Irish Sea, the coastguard can be made aware of it, and it does happen. It is a well known fact by the locals that Pembrokeshire can almost be said to have its own climate, and especially around St David’s Head it is very hard to predict the weather. In just 2008 a water spout formed off Caldey Island, I had the pleasure of seeing it form luckily no one was caught in it, and it didn’t last long, however there is no way anyone could’ve said that was going to happen from a normal grey showery day. Very often the weather in North Pembrokeshire can be completely different to that in the South. This I have experienced many times. 10. It is stated in the proposals to greatly cut the number of staff, this in itself concerns me, not only for the reduction in the number of jobs, but also for the safety aspect of it. Sometimes the staffing levels can seem too high for what is needed, but if there was a situation where the higher staff levels are needed they would be there, ready to get the job done as quickly and safely as possible. They MCA say that if an incident which is bigger than the average rescue needed dealing with, then other officers from the MOC would assist, but as each area would have its own team in a MOC the others wouldn’t have enough knowledge of the area to be efficient enough. Say the country was hit by strong winds which is a very regular thing, and seems to be increasing with the more extreme, and variable weather we are having, (which the MCA has acknowledged this in the consultation), chances are there are going to be very rough sea conditions, throughout the UK, so cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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in a time when extra help from others in the MOC might be needed, it will not be there simply because they will be dealing with their own area. 11. Milford Haven waterway forms part of the 138,069.45 ha Pembrokeshire marine area of special conservation, this needs protecting. In the last ﬁve years Milford had co-ordinated more than 3,500 emergency call outs, and taken part in nearly 4,500 operations, and these ﬁgures are only going to increase with the use of the Milford Haven waterway, and welsh coast, by commercial and leisure users. Figures from the consultation document say in 2007 there was 18,614 incidents, which had risen to 20,544, by the time the document was published in 2010. 12. More and more inexperienced people are using our seas, so to make them safer we need to upgrade if need be, and link up some more stations, after all the country is half linked up already, to keep the vital coastguard stations where they are, placed strategically round the UK for a reason, and not to downgrade to two MOC’s at night when, if an incident occurs it would be so much harder to co-ordinate for obvious reasons, and to keep Milford Haven open as a vital station which looks after one of the busiest, deepest natural waterways in Europe. I would urge you, to seriously reconsider the proposals by the MCA, and protect our country, by protecting our seas and coasts, and those who use them. April 2011

Written evidence from Ivan Fabian (MCA 100) I am a serving Coastguard in Stornoway who is still under training. This puts me in a position that enables me to see the side of being a coastguard that many see as second nature or instinctive. In particular, an area that I have found the most challenging as I became familiar with the job is knowing the name and also the spelling of the locations that a caller may refer to. Without the backing of the other coastguards who listen and support the call collection process I would not have been much use in the operations room for much of my first year. Those around me who are used to the spelling, accents and local infrastructure have long forgotten the difficulty in doing this part of the job. It is an area that the MCA management have described as “unquantifiable”. This may be the case for management and in particular the Chief Coastguard who has not worked in an Operations room for many years, or indeed a seasoned Coastguard who does not realise when they are using local knowledge to influence a decision. No attempt to understand this and make it “quantifiable” has been made. Much, but not all, of my evidence that I list below illustrates this. (1) The Chief Coastguard has described the Local knowledge of the Coastguards as an “unquantifiable parochialism”. I’m not quite sure what he means, however it would be good to understand what has been done to quantify how much time local knowledge can save in the early stages of an incident. Early stages being before a RNLI or CRT volunteer is called. In industry, a professional business analysts would be used to analyse past incidents. They would do this by talking to the coastguards involved in those incidents and looking at the details of those incidents and they would be able to help the Chief Coastguard to quantify and put a measure on the time that is lost or gained in the early stages of an incident before the Sector managers or Volunteers in the Coastal Rescue Teams are called. (2) The systems and software that we have in the stations and the new version of it that we use in the training centre when on training is unreliable at identifying the best SAR resource to call even when the incident location is well understood. The software does an as the crow flies measurement to determine which is the nearest resource to the incident. The software does not understand that the Coastal Rescue Team’s mode of transport is by foot or in a road going vehicle and that stretches of mountain and water are not passable by the team. There are an infinite number of locations where the rescue team suggested by the software would not be the best to respond to an incident. Good local knowledge on the part of the person collecting information on the initial call will mean that the correct Coastal Rescue Team or RNLI lifeboat will be called first time. (3) The Chief Executive Sir Alan Massey has agreed that the proposal put forward by the MCA may, in his words, add a “handful of minutes” to the length of time before a SAR response can be instigated. How many is a handful? As with any emergency service a quick and appropriate response is necessary to save lives. In at least one incident that I have been part of a fishing vessel was had sunk without any visible signs within 10 minutes of the distress call being received. Incidents involving the sea and coastline happen very quickly and when things go wrong they go spectacularly wrong. Sir Alan has also said that the proposal will not put lives at any more risk than the current way the coastguard operates. That simply does not make reasonable sense. To say that delaying a SAR response by a few minutes will not affect those who need Coastguard help does not follow logic or reasoned thought. (4) The MCA have stated that improved questioning techniques can be used to more accurately gain precise location information on the position of a casualty. If better call collection techniques exist the MCA have not shared them with us. In fact it is irresponsible for the Chief Coastguard not to share these improved techniques with us if indeed they exist. If we knew what this technique was we may be able to judge if it would be better than a local coastguard who knows the area taking the initial call or a remote SAR coordinator who does not understand the accent, pronunciation and has no cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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knowledge of the geographic location. By way of an example, this is just one of many, in the Stornoway district there are four places called Pabbay. Due to local knowledge, I can determine which Pabbay a caller is referring to by asking if it is the one by Loch Roag, Sound of Harris, South Barra or the Inner Sound near Kyle of Lochalsh. Someone from a remote site without that local knowledge would not know to ask this. (5) The MCA proposal suggests that in order to gain local knowledge necessary to call out and task an appropriate unit, the Coastguard who receives a call should call the RNLI or a Sector manager who will have the local knowledge necessary to determine which SAR unit to call. The issue with this is it will add time to the process increasing the time before a unit will be tasked. Think of the scenario where a caller tells the Coastguard that they are on Pabbay. The Coastguard does not know to ask the caller which Pabbay. So the coastguard calls the Sector Manager who then asks which Pabbay because he knows that there are four Pabbays in the district. The Coastguard then has to try and re-establish contact with the informant which may be by radio or telephone. It is easy to see that if the Coastguard did know which Pabbay the informant was talking about he could have tasked the appropriate unit without wasting this time. In some situations where comms are an issue due to the positioning of aerials it is difficult to establish comms, so there may never be a second chance to get this information confirmed. (6) The MCA proposal shows an increased dependence on software to overcome the loss of local knowledge that the current regional Coastguard configuration has. The software that the MCA are referring to is not yet able to provide that level of functionality to the degree required to find many places that a caller is referring to. This means that local knowledge is essential to rapidly identify where an incident occurred and then making sure that the correct SAR resource is called. The main system that we use when searching for a location such as Pabbay does not find it at all. Searching Google Earth for Pabbay reveals only one when I know that there are four in vastly different geographic regions within the Stornoway District.( (7) The MCA senior management state that Google Earth can be used to get local knowledge. There are several issues with this. Google Earth takes time to search, it does not have both Gaelic and English names for places and there are many locations that Google will not find. I suspect that Google would be more reliable in areas better charted or mapped like the South Coast of England. It certainly is not very good identifying locations around the Western Isles. It would be wrong for any Emergency service to rely on a free system which also relies on internet connections with no Service Level Agreement with the providers of the software or the networks. (8) As with any computer system it is necessary to use correct spellings in order to get the system in use to return to you the correct response. Place names, particularly in the Stornoway district, stem predominantly from Gaelic and Norse mean that without some considerable knowledge it is unlikely that a guess at spelling will produce the correct place name. Loosing the knowledge of the district through the MOC system that the MCA proposes will cause considerable delays in response. Delays in this industry result in death and disaster. (9) The MCA have described improvements in the technology as being one of the reasons that centralising and creating a MOC in Aberdeen and a MOC on the South Coast will work. If questioned, the MCA acknowledge that this is simply a minor upgrade in software version and it is not a revolution of new technology. That same software is used in the training centre in Highcliffe so many of us have had the opportunity to use it. The improvements in the upgraded version are barely identifiable. So the MCA have a mistaken belief that this new software will overcome problems that it will clearly not overcome. (10) Aberdeen costs £280,311 a year for rent, rates, utilities and estate management. Compare that to the cost of the other stations in Scotland. Stornoway £55,150, Shetland £53,036, Clyde £112,441, and Forth £44,622. So summing that up we see that the latter 4 stations cost a total of £265,249 per year. These figures are published on the MCA web site. So for a saving of £15,082 the Aberdeen station could close and we could retain four regional stations. I am not suggesting that Aberdeen should close, the point being that there is no sense in the business case of this part of the MCA’s proposal. The MCA has stated that it is due to the oil industry that Aberdeen should remain open as the main station. An emergency on an oil rig does not require Aberdeen staff to deal with it. All the oil rigs are in known locations and the flight paths of the serving helicopters are well known. This is precisely the type of incident that could be coordinated from a call centre. (11) Staffing up the MOC in Aberdeen (and similarly the MOC in the South) to the levels described in the MCAs proposal will rely on a significant number of staff moving from their current station to this new centre. For many in the Coastguard the primary earner in the family is not the Coastguard but the partner. The cost of living in Aberdeen is considerably higher than in all the other locations. It is very unlikely that enough experienced coastguards will move to make up the numbers necessary to fully staff the MOCs. As a result a significant recruitment and training program will need to be carried out. It takes nearly a year to train a Watch Officer and then many years to hone those skills and gain knowledge. One of the biggest assets the service has is the number of long serving coastguards. If the MCA continue with the proposal the Coastguard will loose not just the 48 percent of staff that the cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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proposal identifies but considerably more than that because not enough people will relocate to the MOCs for the reasons that I identify. (12) The MCA refers to improved tracking systems to locate vessels when in distress. The system known as AIS (Automatic Identification System) is in use in the stations however the MCA do not acknowledge the following: 1. The system is unreliable and large vessels appear and disappear at random. There are particular areas that are worse than others. The MCA proposal does not identify this issue or describe how it will overcome it. 2. Many vessels particularly recreational craft and smaller fishing vessels do not carry the apparatus that allows us to monitor and track their position. 3. Walkers who may fall or become crag bound on the coastal cliffs do not carry the equipment. (13) The MCA proposal shows a few stations that will only operate during the day. If the MOC system that the MCA proposes is going to be successful then keeping these day stations will be wasting a large amount of money in rent, rates and facilities management. It is suggested that the sub centres purpose is to ensure enough staff are available to cope with increased work loads during daylight hours. Coping with the need for more staff is easier to do with a shift or an on call system operated in one place than in this remote way. Due to the fact it does not make sense to get additional staff to support the MOC in a remote location, it is possible and highly likely that the real reason that the MCA have these sub centres is due to their own lack of confidence in the plan that they propose. Another possible explanation for the sub stations may be a political one whereby the MCA did not feel that they could get away with closing all but two stations without public outcry. April 2011

Written evidence from Simon Hart MP (MCA 101) I am grateful for the opportunity to submit a brief paper outlining the importance of the Milford Haven Coastguard to the coastal community of West Wales. To do so I will summarise comments I made in the recent debate in Westminster Hall. One of the reasons that there is such interest in this issue locally is that our community is proud of the Pembrokeshire Coast National Park and of the people who look after it. Moreover it is proud of the industries that surround Milford Haven, and the coastguard that has looked after it with skill and dedication for such a long time. The Coastguard is part of the fabric and architecture of our area. I would also like to draw the committee’s attention to events of 15 February 1996, when the Sea Empress went aground off St Ann’s head, spilling 72,000 tonnes of oil into the Milford Haven damaging 200 km of our coastline, as well as causing lasting effects to our tourism sector. The consequences of that disaster are still being felt 15 years later. Given our pride in the Haven there is a feeling of nervousness caused in part by threats to the helicopter search and rescue service, (and made worse by the fact that the universal tug service has been withdrawn). It is these concerns that are the contextual background to the local community’s uprising in defence of the Milford Haven Coastguard station. This uprising has included a recent rally in Milford Haven attracting 17 political speakers, the town band and included the Mayor putting the case for the Milford Haven coastguard. A campaign has been run with great reasonableness by the Western Telegraph and the Milford Mercury, and a petition by the “Save Milford Haven Coastguard” has gathered many signatures. Many of the arguments are common to other areas of the UK but with the additional issue of the Welsh language and a healthy local scepticism of technology reliability, risk assessments and back-up measures. Memories are still sore about the time the 999 service was centralised in Wales—if someone rang 999 and asked for an ambulance to come to Newport, Pembrokeshire, it was not unusual for it to go to Newport, Gwent, 140 miles away. These things are not forgotten in a hurry. We argue that history is relevant, especially in Milford Haven. There is confusion about whether the proposal is the MCA’s, the Government’s or, indeed, the last Government’s. The Minister’s recent visit to the Milford Haven area allayed some fears and reassured residents that the consultation is a genuine one. Our community recognises the need for reform, changing technology as well as accepting the signiﬁcant ﬁnancial restraints under which the country currently operates. Nevertheless we hope that the Committee and the Government will recognise that there is an obligation to balance those issues with the hopes, expectations and fears of the community. April 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from Hampshire Fire and Rescue Service (MCA 102) Introduction 1. Hampshire Fire and Rescue Service is a current member of the Maritime Incident Response Group for provision of an “at sea” fire fighting capability around the UK coastline. This is based on Hampshire’s previous declared “at sea” response prior to MIRG, and the necessity to provide a ship firefighting capability in the busy harbours and ports of Hampshire, especially Portsmouth and Southampton which fall within the boundaries of the Hampshire Fire and Rescue Authority. 2. Hampshire has a large maritime industry and has high numbers of both ferry passengers and cruise liner passengers throughout the year and throughout all of our area of coastline, however we have no statutory duty to respond to such calls in coastal waters. 3. It is our considered view that a properly funded and resourced provision for fire fighting at sea by professional fire fighting specialists is an essential risk control measure for the maritime industry, and that to remove it will present an additional risk to the many members of the public (both UK and foreign nationals) who are on board vessels in the Hampshire coastal area every year. 4. For that reason, Hampshire Fire and Rescue Service would ask the Transport Select Committee to consider that national arrangements supported by appropriate national funding are an essential element of national resilience and that no reduction or cessation of funding by the Maritime and Coastguard Agency should be sanctioned without any alternative arrangements being in place.

Case for the Maritime Incident Response Group 5. In 2010, the Maritime Coastguard Agency commissioned consultants BMT Isis Ltd to conduct an independent “Review of Requirements in Relation to Assisting with Incidents Involving Fire, Chemical Hazards and Industrial Accidents at Sea” . Hampshire Fire and Rescue Service participated in this review and welcomed its recommendations that the MIRG arrangements were effective and with some development of the operational model could deliver improved cost efficiency. 6. The report is underpinned by an assessment of risk around the whole of the UK coastline and proposes a reasonable worst case scenario that would involve “a passenger vessel fire that potentially needs to be controlled for up to two days, has the potential to cause loss of life and cannot be contained by the ship’s finite resources”. 7. This report reinforces and re-affirms the business case for the original introduction of the MIRG arrangements. HFRS can see no evidence that the risk assessment has changed and can therefore see no cause to do away with what is regarded as an effective delivery model to meet that risk. 8. The International Maritime Organisation have also recognised the potential need for external support. 9. The IMO’s Maritime Safety Committee (MSC) published a Circular in 2006, “Guidelines on the provision of external support as an aid to incident containment for SAR authorities and others concerned” (MSC.1/ Circ.1183). The Circular lists, “fire-fighting personnel and equipment” as its prime example of such support: 10. “Teams of shore-based fire-fighters, suitably trained and equipped for incidents at sea, may be brought to the ship in distress by helicopter and/or by surface craft, to advise and assist the ship’s crew in tackling and/ or containing fires, smoke, and/or chemical hazards arising from spilled, leaking or burning materials. Fire and/or salvage teams may also be able to bring additional equipment to the ship to assist in dealing with such hazards.” 11. The Marine Accident Investigation Branch (MAIB) has also published a report considering fires that had the potential to cause multiple fatalities within UK territorial waters. 12. The report identifies that the overall frequency of these potential incidents is approximately two per year for the whole of the UK and that ‘this approach identifies that a response capability is required for all of the UK coastline’. 13. Hampshire waters and the Solent have a very high number of vessel movements and in particular the rapidly developing Cruise Liner industry operating out of Southampton represents both a high life risk and a high economic risk if it were to be affected by a serious fire on board a vessel. 14. The plans for green energy sites at sea include a number around the Hampshire coast and the associated numbers of people that will be located within these areas represent a significant future risk that will not be dealt with adequately without a multi-agency approach.

Conclusion 15. Hampshire Fire and Rescue Service consider it is reasonably foreseeable that signiﬁcant incidents will inevitably occur around the UK coast based on the high volume of vessel movement. Should an incident occur, it is clear that there is potential for it to be severe. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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16. This is confirmed in the independent assessment of risk conducted by BMT Isis as part of their MCA commissioned review, which states that there is a “Very High Risk” of a “Significant” incident involving a passenger vessel at sea within the territorial waters of the UK. “The risk assessment has confirmedthat a response is needed around most of the UK, to attend and contain vessel fires with the purpose of preventing loss of life.” 17. Whilst there is no statutory duty on either the MCA or individual Fire and Rescue Authorities to provide a response to fires at sea, the current financial support provided by the MCA and equally matched by the FRS, ensures an integrated, national strategy for dealing with incidents at sea, with common policies and equipment giving the benefits of full interoperability. 18. The independent review commissioned by the MCA itself concludes that MIRG provides a cost effective and timely emergency response to Incidents Involving Fire, Chemical Hazards and Industrial Accidents at Sea. 19. A revised MIRG operating model has been proposed within the BMT Isis report that will maintain the current effective response whilst yielding cost efficiencies, and it is the view of HFRS that this is the optimum solution. 20. Without the provision of the necessary funding to maintain the role of the MIRG Hampshire Fire and Rescue Service will not be able to continue supporting the current arrangements. 21. Should MIRG be scrapped there will be no provision for an at sea firefighting response around the UK coast, at a time when the likelihood of an incident is potentially increasing. It is the view of both Hampshire Fire and Rescue Authority and Hampshire Fire and Rescue Service that this would be wholly inappropriate and unacceptable, and would inevitably lead to greater risk to the marine industry and the sea-going public. April 2011

Written evidence from Shetland MRCC (MCA 104) Summary of Main Points — The proposals as presented in the MCA consultation document are fundamentally flawed and should be withdrawn immediately. — Coastguard officers are not against change or modernisation per se, recognise that some tasks could be done better and that some re-organisation may be necessary, without it requiring the wholescale dismemberment of HM Coastguard as it currently exists. — Any planning for the future of HM Coastguard should include SIGNIFICANT input from operational coastguard officers from around the UK coastline, to make use of their obvious, current expertise. — Any emergency service, by its very nature, MUST operate 24 hours per day. Any move to the proposed “daytime only” status around the dangerous coastline of the UK and its islands would be foolhardy and, in our view, dangerous. — Local knowledge is clearly considered vital by coastguards, the public and the maritime industry alike and any re-organisation that would dilute that in any way would be wrong and again potentially dangerous. — A substantial proportion of what HM Coastguard currently does works well. The suggestion that it is some sort of out-of-date monolith is misleading. — The current configuration delivers what HM Government seeks vis-à-vis its “localism” agenda, ie locally based coastguard stations staffed by locally based officers delivering services to the local maritime communities that they serve.

Details of those Involved in this Submission This document has been compiled by a number of serving coastguard officers based at Shetland Maritime Rescue Co-ordination Centre (MRCC), who between them have 85 years coastguard experience as well as substantial experience in either maritime or emergency services occupations. Name Role Experience (HMCG) Neville Davis Rescue Co-ordination Centre Manager 17 years (+ 16 years experience as a commissioned officer in the Royal Navy) Bob Skinley Watch Officer 5.5 years (+ 2 years Grampian Police, 5 years RAF Police, 3 years Special Constable, Northern Constabulary) Alex Dodge Watch Officer 10 years (+Qualified RYA Day Skipper, Volunteer Sail Training Ship crew, regular sea angler) Martin Sykes Watch Officer 14 years (+1 year experience Coastguard Ops Room Auxiliary) Brian Anderson Watch Officer 1.5 years cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Name Role Experience (HMCG) (+17 years deep sea and 30 years inshore ﬁshing experience, Class 2 Fishing Vessel skipper) John Webster Sector Manager 36 years (6 years as Sector Manager, 30 years as Station Ofﬁcer/CRO, 2.5 years Merchant Navy, 17 years Special Constable with Northern Constabulary)

Evidence Submission Coastguards not Opposed to Change/Modernisation 1. We would like to make it clear at the outset that as Coastguards, we are not opposed to change or modernisation per se. In any occupation there is always a need to strive to do better. Indeed, we recognise that there are some areas where HM Coastguard could improve both in terms of the way it does things and how it is structured/organised, but we do not believe at all, that the only way to achieve this is through the virtual decimation of HM Coastguard as it currently stands as has been outlined in the MCA consultation document.

Current MCA Proposals are Flawed 2. We firmly believe that the proposals as outlined in the MCA consultation document are fundamentally flawed in a number of ways. We believe it is a document riddled with over-simplifications, hasty generalisations, inaccuracies and is a deliberate attempt to paint HM Coastguard as some outdated, outmoded monolith in need of dramatic and sweeping reform, something we do not believe stands up to any level of basic scrutiny. In particular we feel that the document is flawed in the following ways: — The document has been compiled with little or no input from operational coastguards with current and ongoing operations room experience. — It attempts to play down the significance of local knowledge in the operations room setting and yet this is regarding as having crucial importance by coastguards, the public, the maritime industry and previous Select Committee enquiries in 2000 and 2005 into both HM Coastguard and the Fire and Rescue Service. — It paints HM Coastguard as being 40 years out of date when this is patently not the case. HM Coastguard has gone through several periods of re-organisation/modernisation and is a constantly evolving and modernising organisation. — The proposals are backed up by very little in the way of evidence and where evidence is presented it is flimsy at best or potentially misleading. For example, statistics are used to indicate peaks of activity during the summer months and daylight hours. These data are subject to the heavy influence of the large numbers of short-lived incidents along the south coast of England during the summer season, that do not occur in such numbers, for example, around the coast of Scotland, where there is very little in the way of peak activity either seasonally or diurnally. The case is then made for having “daytime only” sub-centres (MRSC) based on these flawed data and misleading use of statistics. — To propose that a national emergency service should operate, in part, during daylight hours only is risible. Emergencies, by their very nature can happen at any time of day or season of the year and to leave large chunks of our dangerous coastline unprotected, except by some distant operations centre during the winter months and the hours of darkness is a frankly ridiculous suggestion and, in our view as professional coastguards a highly dangerous one. — The proposals are presented as “the only show in town.” At no point is there any suggestion that there may be other, workable, viable alternatives to what is proposed or that such alternatives have been seriously considered. How is it possible to make an infirmed judgement on the best way forward for HM Coastguard when only one “take it or leave it” solution is presented?. — The location of the proposed MOC’s (Maritime Operations Centres) in two of the more expensive parts of the UK, the number of staff required to man them, and the reluctance of many current staff to relocate to these centres, gives grave cause for concern that the MCA can actually staff these centres fully from existing, qualified, experienced staff. This would then require the recruitment of a large number of unqualified, inexperienced staff which would have a consequent and potentially disastrous impact on safety. Is that a risk we should be taking when safety of life is at stake?. — It has transpired that the proposals as outlined have not been adequately risk assessed nor have they been rigorously tested to see if they actually work, nor did there appear to be any intention of doing so prior to their implementation. This is frankly a staggeringly cavalier attitude toward safety of life at sea from an organisation whose job it is to ensure exactly that. 3. It is our opinion, therefore, in the light of all the foregoing, that these proposals are fundamentally flawed and should be immediately withdrawn. As previously stated, we are not opposed to change or modernisation necessarily and would welcome the opportunity to FULLY participate in any future discussions on the future cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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of HM Coastguard. Management must acknowledge that we, the operational professional coastguards, have a degree of expertise in these matters that cannot and should not be ignored.

Operational Coastguards must be Involved in any Future Discussions on the Future of the Service. 4. Clearly, if any plans are to be made to reorganise, restructure and modernise the Coastguard service, then those whose job it is to actually prosecute Search And Rescue (SAR) on a day-to-day basis, ie the professional coastguards who man the current 19 Maritime Rescue Co-ordination Centres (MRCCs) around the coast of the UK, should be consulted and involved. Furthermore, surely it makes sense for coastguards to be involved and feel they have a stake in what is proposed? Surely it would make sense to carry the workforce with you in any proposals for the future rather than presenting them with a “take it or leave it” dictat from management? Had that been done in the ﬁrst instance, perhaps we would have arrived at a set of proposals that had the support of the majority of professional coastguards which would have had a much smoother path to implementation than the current ones. 5. The complete lack of any meaningful or serious consultation with operational coastguards is a serious ﬂaw in the proposals. It means they have not been informed to any great degree by those who actually do the job. The current consultation document is a testament to an MCA management who, rather than respecting the professional skill, judgement and integrity of its employees, rather seems to regard them with little short of contempt.

HM Coastguard must Remain a 24 Hour Service 6. The proposal that some coastguard stations would have a “daytime only” status is a patently ridiculous notion and should be abandoned. No other professional emergency service operates on a part-time basis and neither should HM Coastguard. All operations rooms for other emergency services, be that the Police, Ambulance or Fire Service, operate around the clock and there is no valid reason why this should not continue to be the case with HM Coastguard. 7. The rationale for a move to “daytime only” status for some stations is, as has already been pointed out, based on a flawed use of statistics which are heavily influenced by the volume of incidents along the south coast of England during the peak holiday period. This “peak” of activity is not so defined, if it exists at all, in places such as Shetland, Stornoway etc. or indeed around the coast of Scotland as a whole. 8. By its very nature an emergency can happen at any time day or night, at any time of the year. Again, using Shetland as an example, NO month of the year is gale free. We can be subject to severe weather conditions at ANY time of year. Furthermore, the nature of the incidents we deal with tend to be quite prolonged, often lasting many hours to even days, therefore it is vital that 24 hour status is maintained for ALL coastguard stations.

Local Knowledge 9. The consultation document attempts to totally underplay the value of local knowledge in the operations room setting, suggesting that this knowledge can instead be obtained from other sources such as our Coastguard Rescue Teams, RNLI crews etc. Whilst it is true these sources do have a great deal of local knowledge, which is of benefit when conducting a search for example, they do not have it all, nor are they the initial point of contact for an emergency call. When the 999 telephone rings it is the operations room staff that take the call and need to elicit the crucial initial information from the caller in the critical first minutes of an incident. Having locally based officers well versed in local conditions who can elicit information quickly is vital. Any need to consult a third party for local knowledge will, by necessity, be more time consuming. It adds an extra dog-leg in the crucial information gathering process. Any time lost during this critical early phase is inherently dangerous and could, in our opinion, lead to lives being lost due to delays in the determination of the incident location and the tasking of the correct resources. 10. In their investigation into the now abandoned FiReControl project in 2005, the Communities & Local Government Select Committee highlighted the importance of local knowledge in the operations room setting. In particular, the evidence of the Fire Brigades Union (FBU) was particularly telling, regarding the explosion and fire at the Buncefield Oil Depot. The FBU pointed out that the first informant in that incident was not at the incident location, thus rendering any information derived electronically via EISEC (the system which provides caller and location information for the emergency services) utterly useless (something that occurs frequently in our experience), and the caller could not identify where the explosion had taken place, merely that they had heard a large explosion. It was only through careful questioning by the control room operator using their extensive local knowledge, that the location of this major incident was pinpointed accurately, in short order, allowing the rapid deployment of resources to the correct place. (source: Fourth Report of session 2005–06 House of Commons Communities & Local Government Select Committee enquiry into the FiReControl Project). 11. It is abundantly clear, from all that has been said during the course of this consultation process, that coastguards, politicans, stakeholders and the public alike, all regard the retention of local knowledge in the local MRCC as being vital to maritime safety, we agree. There is no doubt that, despite assurances from the cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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MCA management to the contrary, in any migration to a centralised system, as proposed in the consultation document, this essential local knowledge will be at best dangerously diluted, if not completely lost, with a consequent risk to the safety of the maritime user.

HM Coastguard is not out of date and in need of Drastic, Urgent Modernisation.

12. The consultation document has made much of the current, allegedly parlous state of HM Coastguard, as currently conﬁgured. It has sought to imply that the organisation is substantially out of date and in need of a drastic solution to bring it kicking and screaming into the 21st century! This is patently not the case.

13. HM Coastguard has gone through a number of organisational changes, most recently as a result of changes initiated in 1998 which saw the closure of three coastguard stations at Oban, Tyne Tees and Pentland (Orkney). Furthermore, HM Coastguard is constantly evolving and changing its working practices to make use of the latest technology as it comes on-stream. Over the past 15 years we have seen the introduction of a new Incident Management system (Vision), new communications system (ICCS), a computerised Search Planning system (SARIS—which is constantly being updated), the Automatic Identiﬁcation System (AIS)—which tracks, in near real-time, all ships over 300 Gross Register Tonnes, an enhanced version of AIS—GHAIS (which tracks single hulled tankers and banned ships) and there are currently ongoing programmes to replace all the computer terminals in operations rooms around the coast, to install an upgraded version of Vision and to refurbish, replace and modernise the MF (medium frequency) Radio network. It is therefore clear from all of the above that any suggestion that HM Coastguard is some out-of-date monolith which has sat unchanged for 40 years is patently false and is in fact a device which has been used to try and justify radical change, which may actually be unnecessary.

14. A great deal of what HM Coastguard does at present and the way in which that is achieved actually works very well. For example, the consultation document has suggested that the current “pairing” arrangement, whereby neighbouring stations are interlinked so that one can take over the others area of operations ‘in extremis’ is not resilient and in particular, if both of the stations in a pair were to fail, this would leave a substantial gap in our coverage. In the ﬁrst case, it is quite clear that the current pairing arrangement does work. As an example of this, a few years ago a ﬁre at MRCC Swansea made the building unusable until repairs were carried out. Operations were transferred to its “pair” MRCC Milford Haven. This caused no disruption to services and enabled that stretch of coast to be effectively covered for a number of days whilst repairs were carried out. The system works. In the second case, the situation of both stations in a pair being inoperative at the same time is frankly a fantasy that has NEVER happened and indeed engineers at BT cannot conceive of this EVER happening. That said, we agree that work could be done to enhance resilience by improving existing communications links, likely at much less cost than what is currently proposed.

Current Coastguard Conﬁguration is the Epitome of “LOCALISM.”

15. The current Government has placed great emphasis on “localism” ie local services delivered locally and locally accountable. The current configuration of HM Coastguard sits very well with this agenda. The diverse network of 19 MRCCs around the coast of the UK deliver exactly that, local coastguard stations, staffed by locally based officers, having essential local knowledge, delivering local maritime services to local communities, whilst at the same time being part of a wider, national organisation. HM Coastguard, as it is currently configured, delivers the best of both worlds!

Recommendations

16. We request that Honourable Members of the Transport Select Committee consider recommending the following: — The current consultation document is thoroughly ﬂawed and widely unpopular. It should be immediately withdrawn and the process brought to a halt. — Any plans for the future of HM Coastguard MUST involve SIGNIFICANT input from currently operational coastguards from a diverse spread of coastguard stations. — Any proposals for the future of HM Coastguard must ﬁrst be thoroughly and rigorously risk assessed and tested to ensure they work BEFORE they are put out for consultation. — Plans for anything other than a 24 hour Coastguard service are absurd and should not be contemplated. — Any future consultation process should present a range of options so that stakeholders can make a properly informed judgement. The process should also be subject to independent scrutiny. April 2011 cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from Anthony Byrde (MCA 107)

I am a volunteer Casualty Rescue Ofﬁcer (CRO) in Kimmeridge Coastguard and I have attended the consultation evening at Wyke Regis. I have been a member for over 20 years. I am also a boat owner and am a self-employed yacht surveyor.

I have some points which I ask the Committee to consider. 1. If the Ops Rooms are to be reduced from their present number to two central control rooms, how will they cope with CROs calling-in several times a day to tell Control who is on-call in their team? It is not possible to make a weekly roster because CROs working times change. Many of us are self- employed, and have to take work as and when it comes. Our team must have two or three changes daily, and sometimes more. 2. By how much will the lack of local knowledge affect reaction times and central direction of operations, and is that increased time an acceptable pay-off against the saving in cost? (I understand that there have to be trade-offs, but I think they should be recognised and considered). 3. Will the central control rooms have to devolve more control to the Rescue Teams on the coast during incidents (eg of supporting services such as ﬁre and ambulance), and if so will we get the necessary training and equipment? 4. It is stated that resilience cannot be created in the present system because it is too costly to connect all the aerial sites so that other MRSCs etc can take over an area if a control room goes out. Has that been costed and is that outcome in fact realistic? 5. I understand that some Areas have relatively few incidents compared (say) to Portland or Southampton, but how do those incidents compare in time taken up at the Ops Rooms? The workload may not be entirely measurable only by the number of incidents. April 2011

Written evidence from Mairi Murray (MCA 108)

As a serving coastguard ofﬁcer of 12 years I am seriously concerned about the MCA proposals.

The situation as a whole has been dealt with appallingly from the start. The employees have been waiting for these announcements for some time, this has been unsettling and unfair but when they ﬁnally “dropped the bomb” on Dec 16th 2010 no one could believe the devastation they were proposing to our Search and Rescue service.

The proposal is flawed throughout but below I have chosen to highlight my three major areas of serious concern: Firstly the blasé nature in which they dismiss local knowledge. Why do we have to bother sitting a local knowledge exam every two years if it’s of that little importance? We could just search for everything on Google earth! Which as I’m sure has been previously highlighted does not work when you are dealing with coastlines and sea lochs with no postcodes. Secondly as a parent of a son who goes fishing I want complete assurance should he require assistance while on a fishing trip he receives the fastest possible response time. I do not want him to have to be questioned further by an operator in a MOC because they do not know where Loch Brebhat, near Brue is, in between being constantly cut off because of the unreliable mobile phone signal. I want operators on duty to know the area and to be able to start a rescue, I don’t want them to have to waste minutes finding out who is on call for that sector, then further minutes phoning them up passing on the information, spelling place names out, and all this just to establish the area, a rescue hasn’t even started yet. The service would be going backwards not modernising, we try to eliminate doglegs these days not establish them. Who’s going to take responsibility when all these minutes cost lives, how are you going to explain these minutes to grieving families, because should these plans go ahead it won’t be one family it will be many that will be affected by this mindless disregard for our safety? Thirdly how can a safe transition take place between stations closing and a MOC being set up when a large percentage of the MOC staff are going to be new recruits under training? The details relating to the station closure plan are unworkable; the MOC is going to be full of inexperienced operators. Statistics show only 10% of staff will transfer if a station closes.

I trust the Transport Select Committee will investigate these and many other areas fully. April 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from Martin Collins (MCA 109) 1.0 Introduction 1.1 I am a serving Coastguard Watch Manager with a total of 24 years involvement in Maritime Search and Rescue. I was a volunteer lifeboat crew on an independent inshore lifeboat in the Solent for ﬁve years, during which time I was also an Auxiliary Coastguard at Solent Coastguard. In 1992 I obtained a fulltime Watch Ofﬁcer position at MRCC Clyde until I gained promotion in 1999 to Watch Manager at MRCC Stornoway. 1.2 Since I started with the Coastguard I have seen various changes in the service, such as the introduction of computers and the advancement of technology to assist in locating persons and vessels requiring assistance, some of which I have helped to develop. I feel that my input to this inquiry may be valid and helpful. 1.3 Below I intend to put forward my personal interpretations and observations about the subjects that the Transport Committee are looking into. The views expressed are my own and are not those of any other individual, group or organisation.

2.0 Overview 2.1 The year of 2010 saw ﬁve major announcements that separately may seem sound in their reasoning but, collectively, could vastly reduce the UK’s ability to respond to major maritime incidents within the UK Search and Rescue Region. These announcements are as follows: — Cancellation of the Nimrod Project. — Failure to renew the Emergency Towing Vessel (ETV) contract from September 2011. — Cancellation of the Maritime Incident Response Group (MIRG). — Cancellation of the SAR-H Project for the replacement of Search and Rescue Helicopters. — Maritime and Coastguard Agency (MCA) consultation to reduce the number of Maritime Rescue Co-ordination Centres and Coastguard staff by half and leaving only two 24 hour stations for the whole of the UK.

3.0 Nimrod 3.1 The Nimrod Maritime Recognisance Aircraft provided a vital platform to conduct long range search and rescue missions both in the North Sea and into the North Atlantic. Its speed, range and endurance made it ideal as a first response to long range distress situations. It was fitted with radar capable of searching the sea surface, it had advanced communications equipment that enabled the crew to act as On Scene Commander for directing surface and airborne search units. The duty Search and Rescue aircraft was also fitted with liferafts, food and water that could be dropped to people in the water that would allow them to survive until ships or helicopters could rescue them. 3.2 The Nimrod also provided safety cover for SAR helicopters during long range taskings, such as medical evacuations. They could located the vessel before the helicopter was near the scene so there was no time wasted by the helicopter and then escort the helicopter back to land, providing communications throughout.

4.0 Emergency Towing Vessels (ETV) 4.1 The ETV’s are the UK’s insurance policy against major pollution resulting from a vessel grounding. The history of their inception is well documented so I will not go into this. The ETV stationed in the Minch, off Northwest Scotland, is the only ocean-going tug of its size in this area. There are no large ports and no oil or gas installations that require support from this type of vessel so there is no opportunity or reason for commercial companies to locate a similar vessel in this area. Currently the nearest vessel of this type and size is around 18 hours steaming time away, a vessel would be aground and leaking before it reached the area. 4.2 The Minch sees around 2.5 million tonnes of shipping per month passing through the area, everything from coasters and mobile rigs to chemical, oil and gas tankers. The ETV based in the Minch carries out passive escorts of vessels over 50,000 gross tonnes or laden with more than 10,000 tonnes of dangerous cargo. In 2010 the Minch ETV undertook 115 “taskings”, three of which were non-escort duties and included HMS Astute (aground), the coaster Red Duchess (engine failure) and Yeoman Bontrup (major ﬁre). 4.3 With an estimated £120 million to clean up after the Sea Empress grounded off Milford Haven and reports of the Gulf of Mexico oil spill costs reaching $33 million a day, then surly the few million a year for the four ETVs make economic sense, even if they stop just one major spill? 4.4 One answer to raising extra ﬁnance to pay for the ETVs could be a renegotiation of the contract so that the salvage payment percentage for the MCA is greater than at present. Also some means of charging laden tankers that require an ETV escort through the likes of the Minch would bring in some capital, although this cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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should not be too higher charge as to discourage vessels from travelling through these areas in bad weather and endangering the vessel, cargo and environment.

5.0 Maritime Incident Response Group (MIRG) 5.1 MIRG Teams are specially trained and equipped Fire Fighters who can be airlifted to the scene of a fire using a Search and Rescue helicopter. They can provide vital extra time to evacuate passengers from a cruise ship or ferry and can be used in remote areas of the country as a front line response to fires on islands and remote peninsulas. 5.2 The majority of the outlay on these teams has already been paid for in terms of purchase of equipment and training. The teams are all qualified with the only regular outlay being refresher training and equipment replacement. As a result I feel that any saving from the withdrawal of this service is minimal. 5.3 An alteration to the callout procedure for these teams may see them used more then at present. Currently I feel that the procedure is time consuming and detracts from the overall aim of the process. This involves contacting the MCA Fire Liaison Officer, Counter Pollution and Salvage Officer and Duty Area Officer, briefing each on the incident and then holding a conference call to discuss the MIRG tasking with the Watch Manager. This all takes time and removes the Watch Manager from the rest of the incident while this is taking place. A streamlining of the process would be advantageous.

6.0 SAR-H Project 6.1 The SAR-H project was to provide the UK with Search and Rescue helicopter cover for the next 25 years. This included using modern aircraft with up to date equipment and having the same aircraft type at all the bases around the UK, meaning that crews and aircraft were easily interchangeable. 6.2 The reason for the cancellation of this project is not in question but the effects of it could leave gaps in the SAR helicopter coverage. As I understand it, the contract with CHC Helicopters who currently run the MCA contract for the four Coastguard helicopter bases around the UK will ﬁnish next year. The aircraft based at Stornoway and Shetland look likely to go to the Irish Republic where CHC will be supplying the Irish Coastguard Helicopters and there is nothing currently in place to provide an alternative. 6.3 The RAF and Royal Navy SAR helicopters are an aging ﬂeet of Sea Kings which, although good at their job and provide an excellent service, must require more maintenance and have higher running costs than a more modern aircraft. These aircraft will have to take up the slack if a replacement for the four Coastguard bases can’t be found in time, putting more pressure on the units who run and maintain them. 6.4 As this project is such a large undertaking I have no immediate resolution but its demise further compounds the cumulative effects on Search and Rescue effectiveness.

7.0 H.M. Coastguard 7.1 Originally I was planning to comment about various aspects of the MCA’s consultation document but I felt that this would end up being a list of criticisms so I have chosen a different approach. I want to look at how I feel we can improve the Coastguard service of today so that we have a Coastguard service worthy of its name in future. 7.2 There is already a planned roll-out of upgraded I.T. equipment to replace the ageing servers and PCs currently in use at the MRCCs around the UK. This will hopefully solve most of the long term issues that we have experienced in recent years. Software upgrades will give the most benefit and hopefully improved broadband speeds will accompany these upgrades. The use of electronic charts, easier map search facilities and logical information and contact databases would improve speed and efficiency. 7.3 The Automatic Identification System (AIS) is a very good tool and a receiver placed on every remote aerial site would be of great benefit in monitoring shipping around the UK. Currently in the Northwest of Scotland there are blank areas that could be filled with little outlay. To offset this expenditure there could be an opportunity to allow shipping companies, ports and harbours to have access to the MCA AIS data via a subscription service. There are already a number of websites that supply this data from receivers run by private individuals but these do not have the coverage or reliability that the MCA can offer, making a subscription service a viable proposition. Add to this the sharing of AIS data with other Government Agencies for the tracking of vessels for the likes of law enforcement and customs and the benefit of the equipment increases. 7.4 Savings can always be made by the rationalisation of the number of MRCCs around the UK but this has to be done to maintain or improve the level of service that the MCA currently supplies and cannot compromise its integrity. I see little advantage to moving to a two-tier Coastguard with day stations. This would create more problems than it would solve and take the Coastguard back 10 to 15 years when there were MRCCs and MRSCs. This brought about a “them and us” type mentality within the service with the MRCCs thinking they were better than the MRSCs. With every station being equal, the working relationship between the stations improved dramatically and I would like to keep it that way. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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8.0 Future H.M. Coastguard Concept

8.1 I feel that it is beyond my pay scale to suggest which of my friends and colleagues should have their MRCC closed but I will outline a concept.

8.2 This concept is more of a slimming down of H.M Coastguard with the same, if not better, savings as the consultation document. It makes use of the current estates to their full potential and maintains a 24 hour coastal presence in all areas.

8.3 The concept has a total of 12 MRCC’s that are operational for 24 hours a day and operating in pairs, much as they do now. The buildings would still have to be heated and most electrical systems would have to be maintained, whether occupied or not. So why not make them work?

The staffing required for these 12 stations would see watch levels of between five and seven members of staff, day or night, which will allow a reduction to four or five for leave and training. This would make a total staffing level of around 280 operational Coastguards. The staff numbers would be assigned to each station by looking at the average number and length of incidents over the last five years and would include other activities that various areas deal with, such as traffic reporting areas and oil and gas installation exercises.

8.4 Retaining the 12 MRCC’s will vastly reduce the initial cost of relocating staff, will make staff retention more likely and will give a more varied source of recruitment in the future.

Added to this, local knowledge will be retained and the larger areas of responsibility for each MRCC will increase the workload and avoid the “skills fade” referred too in the consultation document. With correct planning these MRCC’s will use the current MCA estates and thus reduce expenditure on property leasing.

8.5 As the plan to use duel kilostreams (wired links from a remote aerial site to the MRCC) has been budgeted for under the MCA’s current plan then I would utilise this facility for the resilience of the overall system. One kilostream would go to the local station and one to its paired station. This will allow one station to take total control of two areas if the need arose. There would also be the ability for a third (another ﬂank) station to be able to gain remote access to the aerial sites of another for added resilience and to relieve pressure if required. This should also see a reduction in cost when establishing the infrastructure as there will be shorter distances for the kilostream runs, when compared to the MCA’s plan.

8.6 The current Regional Business Units based at Aberdeen, Swansea and Yarmouth could be centrally located at the MCA HQ in Southampton. I see that there is little to be gained from maintaining these units on the coast and this would save an estimated £1 million per annum. Each MRCC would have one manager to oversee local stafﬁng, estate management and civil contingency liaison with partner agencies. There would also be one Administration Assistant per MRCC.

8.7 There is scope for H.M. Coastguard to increase its area of responsibility and expand its expertise in Search and Rescue to inland areas. Currently the Police are responsible for all inland SAR but with more pressure being put on the Police to save money and reduce numbers, there is no reason why the Coastguard can’t take on the inland SAR co-ordination roll. That is what we’re trained to do. Using the current mountain, fell, lowland and cave rescue teams, backed up with specialist SAR ofﬁcers, and our knowledge of SAR helicopter operations, this would allow the Police to devote more resources to their primary rolls.

9.0 Summary

9.1 The accumulation of cancelled projects and future planed reductions within H.M. Coastguard would have an effect on the UK’s ability to react to a major maritime incident. 1. Loss of Nimrod, the only long range SAR aircraft that the UK had. 2. Loss of the four ETVs with no commercial replacements likely in some areas. 3. Withdrawal of MIRG for ship and remote area fire fighting. 4. No current future for the UK SAR helicopter fleet. 5. A 50% reduction in the number of Coastguards and MRCCs.

9.2 The UK and H.M. Coastguard are regarded as world leaders in Search and Rescue with other countries using us as an example of best practice. If we want this to be the case in ﬁve years time then we have to think carefully about how we take this forward. We can become a world renowned organisation or a laughing stock, the choice is ours. April 2011 cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from Strathclyde Fire and Rescue (MCA 110) Background The Maritime Incident Response Group (MIRG) was implemented in April 2006, three years after commencement of a project which started the partnership between Maritime Coastguard Agency (MCA)/Fire & Rescue Service (FRS)/Ministry of Defence (MOD). This Group is made up of 15 Fire Authorities who agreed to participate in this strategy. The delivery of the project, the first of its kind in the world is held up as an example of best practice. In 2010, the MCA commissioned an independent review of its requirements to assist with incidents involving fire, chemical hazards and industrial accidents at sea. This review was undertaken by BMT Isis Ltd and reported in October 2010. The review identified 30 conclusions and 28 recommendations. Significantly the report identifies that: — “The risk assessment has confirmed that a response is needed around most of the UK, to attend and contain vessel fires with the purpose of preventing loss of life”. — That “Eliminating the provision is not considered an option” in the context of the identified risk. — A commercial replacement of the MIRG would be expensive and that “the existing form of provision (MIRG) has inherent cost advantages because all the basic training and non-MIRG firefighter training time is funded elsewhere”.

Options Available The following options have been included as possible responses to the Department for Transport’s ongoing consultation:

Option 1—Maintain UK Arrangements The recent MCA review findings of the current MIRG provision have been assessed with a view to realigning to the identified risk. It is considered that UK MIRG resilience arrangements could continue to be maintained within a revised number of Fire & Rescue Services with a reduction in the cadre of specialist firefighters necessary in each. The annual MCA funding requirement for this UK provision would be in the order of £340k, a significant reduction on the previous figure of £600k. This includes personnel costs incurred in managing and coordinating the strategy. (Fire Liaison Manager)

Option 2—Provide Specific Scotland Based Approach Scotland has over 790 offshore islands with 94 inhabited islands. These islands are served by ferries on a daily basis with an approximate total of 145,000 sailings per year. It should be recognised that a Scotland only approach would result in an overall reduction in MIRG team members’ availability as a direct result of the reduction in capacity from the current Fire & Rescue Services nationally to potentially two in Scotland when Lothian Borders have withdrawn from the National agreement on 14 May 2011. Fires on board ships are labour intensive and whilst the MIRG general strategy is to contain a fire until the vessel can be brought alongside it may still require a large number of firefighters and resources over an extended period of time to achieve this. Under the current and proposed UK arrangements, teams can be transported to incidents from all over the UK. This support is vital in terms of firefighter safety. In addition, it is recognised that individual Fire & Rescue Services currently absorb a significant cost to participate in the current national strategy such as additional availability allowances, transport and infrastructure in order to maintain their teams. Management provision (FLM) would also have to be made as in Option 1 above.

Option 3—Remove Funding and Support Without the provision of the necessary funding and support to maintain the role of the MIRG, national contingency arrangements would fall into decline and become vulnerable to exactly the same issues which ﬁrst initiated the formation of the “Sea of Change” project. In areas where individual FRSs decide that they will continue to maintain a provision, it will not provide an integrated response including training, equipment and procedures as currently inherent in the UK MIRG strategy. I trust the above provides you with an overview of the current and ongoing situation however please feel free to contact me should you require any further information. April 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from Irene MacRitchie (MCA 114) 1. Local Knowledge Local knowledge is not about something that can be written down and put onto a database. It comes from a lifetime of living in the area and gaining experience from different activities/people/organisations that may have nothing to do with the Maritime community, which the agency will lose because you will not be able to recruit people from the Highlands and Islands to go and work in Aberdeen or Southampton. The agency have not taken into account the various different dialects and languages around the coast, and how these various different spellings of place names could cause confusion to those who are not used to them. On the West Coast of Scotland we are more than aware of the slight difference and spellings of a Place called Tarbert, but would someone from another district be able to distinguish between Tarbert & Tarbet? Let alone that there are eight places on the West Coast of Scotland which vary from Tarbert’s to Tarbet’s. The service is currently very robust, staff have a great deal of local knowledge of their operational area. This makes tasking of the correct unit, in as quick a time as possible, to the right location while understanding the nature of the area that the unit is being asked to operate in. The Agency’s proposal only see the operator having to add minutes to the incident, while they try and locate the area (which they might be unfamiliar with) the person is in—when every minute matters to the person in distress.

2. Day Stations Proposing to have certain stations around the coast open during daylight hours has several ﬂaws. In theory this sounds good, however in practice it would not be able to work due to the following reasons: 1. The Agency are proposing to only have 10 staff in total operating out of the day stations: — You would only have a limited number of staff available; — If they have had to work an extra four hours and are required to be at work the following day also (it could contravene the Working time directive); 2. The Agency have suggested that staff could stay longer if they are dealing with an incident—but they haven’t taken into account those people with childcare issues, that would then be forced to ﬁnd someone to assist them. 3. There is a huge difference between Daylight in the Summer in Shetland and Daylight in Falmouth (the same can be said for the winter!)

3. MOC’s The agency have yet to convince anyone, whether they are staff or members of the public, that Mocks are a good idea. Firstly, the location of the MOC North is questionable—Yes the Agency is tied into a contract for the next eight years, but this building is only rented, at the end of it’s current contract, who is to say that the owners won’t demand a higher rent—by which point MOC North will have had so much money put into it to accommodate the extra staff that they agency would probably have to agree to what ever sum of money the owners came up with. MOC North is located in one of the most expensive cities in the UK to live. Most staff at other stations would not be able to relocate to Aberdeen purely due to the cost of housing. With this in mind I believe very few staff would take up the opportunity to relocate to the new MOC no matter how much the new proposed pay scale was. Therefore the Agency would lose skilled, experienced, time served staff and would then have to fill many vacancies, with staff with less or no search and rescue experience, in a city with low unemployment rates (due to the offshore oil and gas industry’s heavy presence in the city.) At the public meeting in Aberdeen, one of the management team stated “One of the reasons I feel for the importance of us being based here in Aberdeen is the industry (sic. Oil). You know, we have spent many many years working together to do everything we can to ensure that life is just that little bit later (assuming this was meant to be safer rather than later) offshore, and if not that we’re working together to ensure that we do whatever we can to bring everything to a successful conclusion. And that will continue.” So if one of the reasons to keep the station in Aberdeen is about keeping the oil industry safer, should the same courtesy not be given to the fishing, fish farming, leisure, cargo transportation etc industry? Also, going to a MOC system will add pressure on staff, which could lead to a rise in already high sickness levels experienced around the coast, due to the stress. Coastguard Officers deal with often harrowing incidents, if they were required to deal with numerous incidents while being the only station available overnight, spanning the entire coast, In my opinion, I believe that the physical and psychological effects on staff would have a huge impact on the people at that station.

4. Enhanced use of Technology The Highlands and Islands already have signiﬁcant problems when it comes to technology, mobile phone signals are patchy at best, AIS reception again is patchy and depending where you are in the district VHF coverage has “Black Spots” in many Sea Lochs and coastal areas. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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The MCA have said that Coastguard Ofﬁcers can use “Google” to help locate a place—yet this relies on the operator knowing how to spell the place in the ﬁrst instance eg Valtos on the West Coast of Lewis, is actual spelt Bhaltos. Many users of our Coastline are the small boat operators, day sailors or kayakers—many of these users only have a handheld VHF to rely on and not AIS.

5. ETV’s Emergency Towing Vessels were put to the “Four corners of Britain” under the advice of the Lord Donaldson Report in 1994, in that time we have seen this invaluable resource come to the fore and prevent many possible disasters. The Minch, Fair Isle Channel, Dover Straits and Southwest Approaches were all deemed to “Marine Environmental High-risk areas” that would require the Coastguard Agency to consider it urgently to provide salvage tugs. I can not see what has changed since the report was published some 17 years ago, so why does the government now not think that they are required. The USA & BP have seen only to well how much a pollution clean up can cost, surely the ETV’s are a small price to pay for some peace of mind?

6. Questions to be Asked and Answered — Public meetings—The MCA did not have those who produced the actual consultation document at any of the public meetings—Why? — Public Meetings—Coastguard ofﬁcers were referred to at a number of meetings as “remote SAR co-ordinators”—When did the change of job description happen and why were the staff not informed? This term can not be found in any of the Coastguard manuals or in the Terms and conditions of their employment. Or was this an attempt by management to make Coastguard Ofﬁcers seem distant and not as an important part of the Search and Rescue service. — Public Meetings—The MCA stated that they believe they have shown a robust case for modernisation and that they stand behind this document, Yet the Shipping Minister has been telling staff that the plan which the MCA has put forward will not be the plan that goes ahead. If this is the case, where does that leave those in the MCA management who believe that they have come up with the best plan?

7. Miscellaneous During this consultation period several misnomers have appeared in the press from those who should know better. Some have referred to Coastguard Ofﬁcers as purely call handlers, others have said that we are not front line services. Yet our remit is: “The Modern Role of HM Coastguard was clearly deﬁned by the Secretary of State for Transport in the House of Commons in March 1992 when he announced that under the authority given to him by the Coastguard Act 1925 it had been agreed that Her Majesty’s Coastguard is responsible for the initiation and co-ordination of civil maritime search and rescue within the UK Search and Rescue Region. This includes the mobilisation, organisations and tasking of adequate resources to respond to persons either in distress at sea, or to a person at risk of injury or death on the cliffs or shoreline of the United Kingdom”. We are also responsible for provision of maritime safety information, medical link calls from ships to hospitals and mutual assistance to other Category 1 responders as part of the Civil Contingencies Act. In the Highlands and Islands, this sees us frequently deploying our resources to land-based search and rescue incidents and assisting the medical authorities in transfer of patients from remote communities to hospital facilities. April 2011

Written evidence from TOTAL E&P UK (MCA 115) Please find TOTAL E&P UK’s response to the Coastguard consultation attached hereto, but I would also like to summarise our position below. TOTAL has worked in the UK since the mid 1950s and is one of the largest oil and gas producers in the country and indeed the world. We have a large workforce based in Aberdeen and working offshore throughout the UKCS, including both East and West of the Shetland Islands. We have taken the decision to develop two gas fields to the West of Shetland. These are extremely remote from infrastructure so we are constructing a subsea system with pipelines to bring the gas to a new-build gas terminal on Shetland. The fields will be producing for many years, and further work to bring additional accumulations on stream will continue for two or three decades. This is a new and growing business and cannot have been included in historic assessments of incidents. We are most anxious that this vital offshore activity is fully understood and factored into the modernisation discussions. Modernisation and embracing new technologies and methods is a daily process in our highly technological industry, and improvements to the MCA communications and operating systems should be welcomed to improve the service. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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However, we believe that the Shetland Coastguard base provides more than its vital role in co-ordination; it is an essential part of an integrated emergency response organisation for the East and West Shetland basins where many hundreds of people work and travel daily. This base represents an essential element of emergency response involving the police, the Gilbert Bain hospital, volunteers, the Jigsaw helicopter system and vast local knowledge. We strongly support maintaining Aberdeen and Shetland Coastguard stations and can appreciate the need for the Stornaway base, but are not in a position to comment in any detail. Our primary concern is the safety and welfare of the many people involved in drilling the wells, laying pipelines, managing occasional well interventions and providing all the ancillary supply and maintenance marine and aviation support. We would urge you to consider the expanding offshore oil and gas industry and ensure that lives are not put at risk in a drive to reduce costs.

Part2—Questions about the Proposals Question 1 (Chapter 1)—We have set out the changes that would affect the way the Coastguard needs to operate. Are there any other changes and pressures that should be taken into account in our plans for a modernised Coastguard service? Please provide supporting evidence for your comments As a high technology industry, we fully appreciate the need to upgrade systems and structures and welcome any improvements to the communication network of the Coastguard Service. — Points we wish to emphasise relate to the greatly increased level of offshore and near shore activity taking place for the oil and gas sector off the Shetland Islands both in the East Shetland basin (the Northern North Sea) and the West of Shetland/Atlantic Margin. This is a change from the past and needs to be seriously considered when modelling the future need for cover since current statistics will not take this work into account. TOTAL E&P UK anticipates this will continue for at least 25 years and include drilling, pipe laying, shore-line crossings, helicopter services and marine support vessels. — It must also be noted that these operations are 24 hours, seven days/week and not related to tourist peaks such as can be anticipated for resort areas. Fortunately, and as MCA statistics show, there are relatively few major incidents around the Shetland Islands, either to the East or West but if any incident did occur the local services could be required at any time day or night and potentially for an extended period. — Also, in many parts of the North Sea, access to emergency support can also come from other installations and even from Norway. The West of Shetland area does not have the beneﬁt of the same level of additional emergency support facilities and is heavily reliant, in the case of a serious incident on the existing emergency services of the Coastguards, Emergency Towing Vehicles (EMT) and in the past, Nimrod air surveillance support. — Search and Rescue Helicopter, Emergency and MIRG facilities could be vital emergency support to the offshore industry, particularly East and West of Shetland where increased shipping and offshore activity, including hydrocarbon production will occur for several decades. We would strongly oppose any reduction in this vital emergency response capability based on or around the Shetland Islands.

Question 2 (Chapter 2)—We have explained the current Coastguard structure and the potential weakness in that structure in the face of increasing demand. Are there other strengths or weaknesses in the current arrangements that we should be taking into account? Please provide supporting reasons for your comments A fully connected national system of Marine Rescue Coordination Centres, using current technologies, leading to greater resilience is a sensible objective which we fully support. We accept that some reduction in site numbers may be possible due to improved communication facilities between Centres and more sophisticated electronic mapping and locator facilities. Staffing of centres with seasonal or diurnal peaks could be managed by managing staff numbers or possibly by annualising hours worked and offering greater relocation opportunities, for experience and skills enhancement. Points we would wish to emphasis are: — The location of an Oil and Gas Offshore Liaison Officer in Aberdeen is extremely important and should not be considered for change. The role ensures excellent coordination and planning both for real incidents and in exercises across industry and government agencies — Oil and gas activities are taking place all year and day and night so that the proposed daylight hours only for the Shetland Centre could potentially cause significant disruption and hinder communications with the strategically important Gilbert Bain Hospital, airbases and local landing sites on Shetland. A 24 hour MCA operational base in Shetland is considered essential for the offshore oil and gas industry presence in the East and West Shetland basins on a 24/7 basis for many decades to come. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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— Fortunately, major offshore incidents are rare but have serious implications and would require staff for potentially extended periods. The potential for staff to be needed at all hours and possibly for several days cannot be ignored in the consultation. — There are concerns about communications reliability on Shetland and the inability of achieving fast repairs during bad weather. The Lerwick base is able to continue operations due to its own antenna and local mobile communications thus ensuring operational availability even when links to the mainland are down. This is a vital safety net for the offshore industry. — The experience of local staff and their extensive local knowledge is even more critical in the event of communications failures to the mainland.

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

The proposal to have MOCs with improved communications, more advanced electronic locator information and enhanced systems are not unreasonable if the new MOCs are fully capable of delivering the required service. However, the proposals speak of peak demand which, in the oil and gas industry is very different from daytime users or tourist trafﬁc. The oil and gas industry operates 24 hours per day seven days per week and loss of full service could be critical in the rare event of a major incident. — Major incidents are, fortunately, rare but the ability to utilise local Search and Rescue facilities, hospital and potentially ETVs at any time of day and night could not be provided if the Shetland base were to be operated on daylight hours basis only. — The large amount of activity in the East Shetland Basin and West of Shetland often uses Shetland for helicopter travel, particularly when weather is inclement. The MCA base is therefore fully familiar with user’s operational processes and the potential emergency needs of the industry. — In the event of a near shore incident the local knowledge of the Shetland based staff is considered highly signiﬁcant, particularly with the very large number of islands, local names and pronunciation, extensive shoreline, local tide and currents knowledge. — In the event of a long term incident the prospect of the Shetland base either not being manned or down manning at the end of daylight hours would be, in reality totally impractical and potentially extremely dangerous. The comments of the Chairman of the MAC to the Select Committee on 8 February gave no comfort that out of hours service extension was a serious option. — We would be concerned if the “strong linkages” with Coastguard Rescue Service and Volunteer organisations, no matter how well trained, effectively passed responsibility to local voluntary groups to carry out the vital co-ordination of local services.

Question 4 (Chapter 4)—Our proposals for Maritime Operations Centres and sub-centres locates these around the UK coastline and makes use of the MCA current estate. What is your opinion on the proposals for the location of these Centres and sub-centres? Please provide supporting reasons for your comments

For the reasons previously stated, delivery of a safe working environment for the large oil and gas workforce in the far North of Scotland, the need for 24 hours facility and the extensive local knowledge strongly suggests that at least one further 24 hour base is required on Shetland and, possibly, also Stornaway: — The Aberdeen base remains essential since the Oil and Gas Liaison Ofﬁcer Role has worked well and provides an important point of contact for an offshore industry that is very largely Aberdeen-based. — There is insufﬁcient evidence to convince us that a Shetland base could provide the same level of service, with no risk to offshore workers, on a part time, daylight hours only basis. — There are comments about so called ‘sub-centres’ being in good communications with MOCs by radio links and we refer to our comments in response to Question 2 that makes the resilience of the current Shetland base all the more compelling. — We strongly support retention of the Shetland base, not as a daylight hours sub-centre but as a full time operations centre providing a highly valued and potentially critical element in any incident relating to 24 hour operations of the oil and gas industry both East and West of Shetland. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Question 5 (Chapter 4)—In your view, are the new roles and responsibilities for Coastguard officers at different levels in the proposed structure appropriate to the tasks that need to be delivered? Please provide supporting reasons for your comments The staffing levels required at stations are not something that can be argued coherently by TEPUK due to the lack of detailed information and knoweldge. The end product is the key factor; staffing could then be resolved between management and staff to provide that service, to encourage staff development and training opportunities: — We do not believe the final solution and structure of the Coastguards Service has been resolved and therefore it is premature to discuss staffing levels. — A more appropriate shift pattern may well be found once the final solution to operational centres is agreed. There are many alternative shift patterns to give 24 hour cover as the oil and gas industry is fully aware.

Question 6 (Chapter 5)—Under these proposals the regular Coastguard working in Maritime Operations Centres and sub-centres will draw more heavily on the local knowledge of geography, community and coastal risk provided by the network of local volunteer HM Coastguard Rescue Teams and increased liaison with partner SAR organisations. Do you agree that this is the best way to ensure the availability of such knowledge. Please provide supporting reasons for your statement We do not feel that the argument for two MOCs, closure of stations and reduction to daylight hours has been demonstrated as an adequate model for the efficient operation of the MCA. — Early confirmation of the importance of Aberdeen as a major centre, perhaps the northern MOC, is vital due to the importance of the oil and gas industry and the very large number of people working offshore in the industry. Exercises and planning for emergency response is an ongoing process and there should be no doubt as to the importance of this role in Aberdeen. — We support Shetland remaining a full 24 hour operational base and hope that the proposed period until 2013–14 will give ample time to provide evidence of its strategic importance to the entire northern area of the UKCS, both East and West of the Shetland Islands. — Co-ordination from distant bases could result in time spent contacting local volunteers to resolve locations of distress calls—time that could be vital in search and rescue. We are very concerned at the apparent loss of local knowledge of the Coastguards proposed in this consultation. The northern islands have extensive coastlines, complex and often difficult names. Volunteers represent a wealth of experience but it is unreasonable to waste time in trying to reach them when a local MCA base would operate efficiently and in a timely fashion.

Question 7 (Chapter 5)—In your opinion, will the proposed strengthening of management for the Coastguard Rescue Service organisation, including the introduction of 24/7 on-call Coastal Safety Officers, provide a more resilient response service to those in need in UK coastal areas? Please provide supporting reasons for your comments The centralised model creates significant concern: — Whilst the increase of local Safety Officers could provide some cover for the loss of local Coastguard stations we feel this is a passing of great responsibility to this level of staff. — Under the current proposals Coastal Safety Officers also appear to become the only layer of Coastguard staff with extensive local knowledge. We feel this places a great deal more responsibility on the local volunteers to provide the emergency response service. — Local knowledge is vital, even with enhanced computer-based information and we believe loss of centres and reliance on computer data bases could result in errors, time loss and could be crucial in the initial response to an incident.

Any Further Comments you May Wish to Make We are concerned that the many aspects of marine safety and emergency response re-organisation have been approached in a piecemeal fashion. Nimrod aircraft provided an important, long range observation facility and as some oil and gas operations move farther from the UK coastline this loss could be signiﬁcant. Also, we are concerned at the separate and unconnected proposals for sale of Search and Rescue helicopters, possible removal of emergency tugs, closure of MCA bases and changes of volunteer responsibilities. An holistic approach would seem more appropriate than the uncoordinated, service by service reorganisation that has been going on over recent years.

Freedom of Information Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the access to information regimes (these are primarily the Freedom cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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of Information Act 2000 (FOIA), the Data Protection Act 1998 (DPA) and the Environmental Information Regulations 2004). If you want information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory Code of Practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence. In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department. The Department will process your personal data in accordance with the DPA and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties. April 2011

Written evidence from North Wales Fire and Rescue Service (MCA 116)

Introduction 1. North Wales Fire and Rescue Service (NWFRS) covers ﬁve coastal Unitary Authority areas out of the six Unitary Authorities that make up the combined Fire and Rescue Authority (FRA) in North Wales. This coastal area stretches from Aberdyﬁ in Cardigan Bay around the Llyn peninsular and Ynys Môn (The Isle of Anglesey) through to the lower reaches of the River Dee Estuary.

Background 2. North Wales Fire and Rescue Service have been and continue to be an active partner in the Maritime Incident Response Group (MIRG) since its inception in 2006 following the “Sea of Change” project. Prior to that in common with many coastal Fire and Rescue Services (FRS) in the UK NWFRS provided an off shore capability despite the fact that such a provision was not a statutory duty on the FRA. 3. NWFRS has a history of responding to incidents involving vessels at sea as did the former Gwynedd Fire Service and Clwyd Fire Service prior to their amalgamation in 1996 to form NWFRS. 4. At that time the FRS’ response was not centrally co-ordinated. There was no consistent approach in terms of specialist equipment, the procurement of equipment, the operational procedures adopted and the training provided. These inconsistencies existed not only between the FRS’ but also with the other agencies involved. This was recognised as a serious threat to the safe and effective management of off shore incidents and, of course, resulted in the “Sea of Change” project. 5. NWFRS currently provides a MIRG response from its stations based on Ynys Môn. The provision of this resource compliments and is closely aligned to the provision of both Royal Air Force 22 Search and Rescue (SAR) Squadron at RAF Valley and the MRCC at Holyhead. 6. The close proximity of these locations makes for rapid deployment and is essential for the effective response and management of incidents at sea. The close working relationship that has developed over the years has proved extremely beneficial in the planning and preparation for incidents through combined training, exercises and events. This has resulted in a trusted rapport between colleagues across the different disciplines which in turn contributes significantly to the effective management of incidents when they occur. 7. This planning and preparation has included the vessels on which an incident could (and has) occurred. This further underpins working relationships in the event of an incident and assists the vessels’ crew in their preparation and planning. 8. Holyhead has grown significantly in importance as a passenger and cargo ferry port with 1.941 million passengers travelling to and from Ireland from the port in 2009 (Data supplied by national statistics DFT). 9. Road freight is increasing through the port to such an extent that proposals for a £70 million rail freight terminal have been tabled to reduce the impact of large goods vehicles on the environment and local road network.

10. Cruise ships are increasingly utilising Holyhead, raising passengers numbers travelling through the port, and this looks likely to increase over the coming years.

11. With all of these factors taken into account there is further investment planned for Holyhead. This would supplement the multi-million pound investment by Stenaline who operate the port. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Current Situation 12. NWFRS like many other public services is trying to maintain services in an extremely difficult financial climate. The FRA has asked NWFRS to produce savings of £2.4 million out of a £32 million operating budget over the next three years. 13. The cost of providing a MIRG response with on-going training costs and equipment maintenance is calculated on a national basis as circa £40k per FRS. 14. In the current financial climate NWFRS does not have the capacity to absorb these costs and, as a consequence, would have to advise the FRA, should there be a withdrawal of funding by the MCA, that it could no longer declare as a MIRG resource. 15. Other than the situation with regard to funding NWFRS would not be contemplating advising the FRA to withdraw from MIRG.

Risks 16. In addition to the costs burden, the loss of centralised funding and co-ordination that MIRG provides presents a number of significant risks to NWFRS and North Wales as a region. 17. NWFRS would have to allocate £40k as detailed previously if it was to maintain a MIRG response. This could only be done by diverting finance from other risk critical areas of the Service. NWFRS would not be able to justify moving finance away from areas of service delivery that the FRA has a statutory duty to deliver. This would also present an unacceptable risk to the communities we serve. 18. The removal of funding would create an uncertainty concerning capability within other FRS’. This could present an unacceptable risk to the safety of our crews when deployed, as it could not be confirmed that additional resources would be available to support a deployment at sea. 19. NWFRS would contend that resilience for the Welsh region and the UK as whole to deal with an incident at sea in UK waters would be severely affected should the FRS feel unable to declare or provide a partial unco-ordinated and ad hoc response. This has the potential to rapidly escalate to a complete inability to respond. 20. The loss of centralised funding and with it training and development presents a significant unacceptable risk to interoperability. It is likely that standardisation would be lost and with this loss the safety of responding crews becomes further compromised. The potential result is a return to the previous response situation which was deemed unacceptable through the “Sea of Change” project. 21. Removal of the MIRG response increases significantly the risk to passengers and crew of vessels that become involved in an incident involving a fire at sea. Current training standards for crews on board ship (and in some case the number of people available) do not provide for the same level of response and action as provided by fully trained dedicated and experienced fire-fighters and their commanders. 22. Without the facility to effectively bring a fire under control to enable a vessel to safely reach port, evacuation at sea in potentially adverse weather condition and darkness presents an unnecessary risk to both passengers and crew. This risk may be considered unacceptable and is extended to the large number of resources both air and sea borne that would be required to undertake such a task. 23. The tidal races and rock formations around Ynys Môn (where the port of Holyhead is located) make the coast line extremely treacherous in places and an out of control vessel could potentially founder and break up. 24. The environmental impact would be disastrous for the region of a fire on board one of the large ferries in and out of Holyhead. They carry a wide range of risks including hazardous materials on vehicles, on its vehicle decks, in addition to those carried by the vessel itself eg fuel oil. The clean up costs of such an incident are likely to be significant in comparison with maintaining funding for a MIRG response. 25. These risks are likely to increase as the volume of freight traffic increases through Holyhead to and from Ireland. 26. There is significant risk to the reputation and safety record that the UK currently holds. When reviewing data of worst case scenarios of fire involving passenger (Cruise and Ferry) vessels over the last 40 years there have been no fatalities or injuries when the incidents has occurred in UK waters. This is not the same in other countries.

Summary 27. NWFRS does not have a statutory responsibility to respond to ﬁre on board vessels at sea. 28. NWFRS is a full and active member of MIRG and has no intention of withdrawing from the group outside of the issues created by the removal of centralised funding. 29. NWFRS does not have the capacity to absorb the costs related to being a declared MIRG asset and would have to advise the FRA of such should central funding be withdrawn. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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30. The removal of centralised funding to MIRG presents a significant number of unacceptable risks. These include passengers, ships’ crew, fire-fighter safety, interoperability between FRS and partners, resilience, the environment and not least the success and safety record of the UK in dealing with such incidents. April 2011

Written evidence from the International Group of P&I Clubs (MCA 117) I am writing to you as chairman of the International Group of P&I Clubs (International Group) Salvage sub- committee, in response to your invitation to submit written evidence to the Transport Committee in respect of its Inquiry into the Coastguard, emergency towing vessels and the Maritime Incident Response Group.

1. Background 1.1 The International Group comprises 13 not-for-proﬁt mutual insurance associations known as Clubs, which individually insure third-party liabilities relating to the use and operation of ships. The Clubs are true mutuals in that the insured shipowner and charterer members are also the insurers, since they own the Clubs of which they are members. Eight of the Clubs have their head ofﬁce in the UK, two in Norway, one each in Sweden, America and Japan. The majority of the Clubs have been established for between 100–150 years. 1.2 The Clubs between them insure over 90% of the world’s ocean-going tonnage and over 95% of ocean going tankers. The Group Clubs provide cover to virtually every type of vessel and owner/operator worldwide. Governments, maritime organisations and authorities around the world recognise the strength of, and the uniqueness of the cover offered by, the Club system and the Group, which underpins the insurance requirements contained in the IMO compensation conventions in particular the 1969 and 1992 International Conventions on Civil Liability for Oil Pollution Damage (CLC Conventions) and the International Convention on Civil Liability for Bunker Oil Pollution Damage 2001 (Bunker Convention). 1.3 The main functions of the International Group are: (a) to coordinate through the Group Pool system the sharing between member Clubs of third party liability claims in excess of individual Club retentions, currently US$ 8 million and the purchase of collective insurance and reinsurance for Group Clubs for claims in excess of $60 million up to an amount of $3.06 billion; (b) to coordinate and represent the views of Clubs’ shipowner members on matters of concern to the shipping industry, States, national and regional authorities in relation to insurance and liability issues; and (c) to provide a forum for the exchange of information and views between Clubs. 1.4 The individual Group Clubs provide the broadest and most extensive cover of any protection and indemnity insurer. For pollution claims up to US$1 billion, for death and personal injury claims to passengers and crew, a combined amount of US$3 billion and for other types of claim eg cargo damage, collision, wreck removal, damage to port installations etc. in excess of US$6 billion, per vessel per incident. To provide for these high levels of cover, Clubs, as mentioned above, have a pooling or sharing arrangement whereby claims in excess of individual Clubs’ retained risk, currently US$8 million, are pooled and shared between all of the Clubs up to the limits stated above. The pooling arrangement is protected up to an amount of US$3.06 billion, by a reinsurance programme which is placed annually and is the largest marine insurance placement in the world, involving almost all of the world’s major reinsurers.

2. Emergency Towing Vessels (ETVs) 2.1 Following the incident of the “Braer”, a fully laden tanker which went aground on the Shetland Islands following an engine breakdown in extreme weather in January 1993 (and which was entered with one of the Group Clubs), the government appointed Lord Donaldson to conduct an Inquiry “to advise on whether any further measures are appropriate and feasible to protect the United Kingdom coastline from pollution from merchant shipping” (the Inquiry). The International Group gave both written and oral evidence to the Inquiry. 2.2 The Inquiry recognised that once a vessel gets into difﬁculties or risks becoming a hazard to other vessels, it is vitally important to do everything as quickly as possible to prevent the vessel becoming a casualty, with the possible consequent loss of life and damage to the environment. This is certainly the experience of the International Group. 2.3 In almost all cases where a vessel is damaged or disabled and risks grounding or sinking, the most effective way of averting a casualty is to provide emergency towing services and bring the vessel to a port or other place of refuge. Passengers and crew can then be disembarked in comparative safety and the vessel hopefully repaired and/or any escape of cargo or other pollutants, such as an oil cargo or bunker fuel, prevented or contained. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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2.4 Emergency towage can be equally important even after a vessel has grounded, for instance pulling it free before it is breached or becomes a wreck (which can in itself cause damage to the environment), or if it is involved in a collision with another vessel or some other fixed or floating object. 2.5 The industry which has traditionally provided towing services to vessels in emergency situations is the salvage industry. However the Inquiry noted that the salvage industry had been contracting for some time, largely because of a decline in casualties and accordingly in the revenues that salvage services generated. This contraction in turn had led to a reduction in salvage capacity in particular in respect of experienced salvage personnel and tugs capable of towing large fully laden vessels often in bad weather conditions. The salvage industry today, in the main through the International Salvage Union, asserts that the salvage industry continues to decline both in terms of the number of salvage companies engaged in salvage as well as in revenue from salvage or salvage related services. Accordingly there is little incentive for companies to invest in salvage tugs, equipment or personnel. 2.6 It was essentially against this background that the Inquiry put forward recommendation 85, that the UK government should set up a system to ensure that tugs with adequate salvage capacity are available at key points around the UK shores. 2.7 The recommendation was accepted and adopted by the UK government. The Maritime & Coastguard Agency (MCA) currently administers and implements the system by chartering four tugs which are located in strategic positions around the UK coast. The cost of chartering the tugs is met from the public purse. 2.8 The International Group is firmly of the view that the factors which led to the Inquiry making recommendation 85 remain as valid today as in 1994. Although standards in the shipping industry, in the context of ship maintenance, ship management, safety awareness, navigational aids and equipment have undoubtedly improved since 1994, there will inevitably be incidents involving human error or equipment failure, such as loss of power or steering, which could result in casualties with associated loss of life and damage to the environment. 2.9 The ETV system of having tugs on “stand by” provides a very effective safety net for the provision of emergency towing services when commercial arrangements cannot be made or cannot be made in sufficient time, for instance when no commercial tug is available or is of insufficient power or an ETV is nearer to the casualty in an emergency situation. The system operates even more effectively because the Secretary of State’s Representative (SOSREP) has the power to direct a master of a vessel in difficulties to accept assistance from an ETV and for the ETV to render assistance. He has no such power over a commercial salvage vessel. 2.10 Moreover the ETVS, which are available 24 hours a day seven days a week, are fitted and equipped for the specific purpose of rendering assistance to vessels in distress. Their crews are well trained and experienced with considerable local knowledge of the area in which they operate. They are used to liaising with the MCA, SOSREP and other response entities and they also participate in casualty response training excercises. 2.11 The International Group is aware of and has been involved in a number of instances when ETVs have been deployed or “tasked” and have either prevented casualties or assisted in minimising their impact. Recent examples include: 2007 “Figaro”—December—this car carrier suffered the loss of its main engine in heavy weather when preparing to pass through the Traffic Separation Scheme between Lands End and the Scilly Isles. There was a very real risk of the vessel striking Wolf Rock. As a result the ETV “Anglian Princess” was deployed and took the vessel in tow. Subsequently the “Figaro” crew was able to re-start the vessel’s main engine. 2008 “Atlantic Trader”—March—this cargo vessel lost power in heavy weather west of Hoy, Orkneys. It was taken in tow by the ETV “Anglian Sovereign”. “Mekahnik Semakov”—October—this cargo vessel lost power 2.6 miles off the Isle of Skye. It was taken in tow by the ETV “Anglian Prince” to a safe anchorage at Broad Bay, Isle of Lewis. 2010 “Wilson Dover”—March—this cargo vessel lost all power some 40 miles off the Orkneys in bad weather. It was taken in tow by the ETV “Anglian Sovereign” to Kirkwall. “Yeoman Bontrup”—July—a fire broke out on this bulk carrier whilst berthed at Glensanda. The ETV “Anglian Sovereign” attended. “Athena”—October—a fire broke out on this fishing vessel with 111 crew on board, when the vessel was 230 miles off the Scilly Isles. The ETV “Anglian Princess” was one of the first vessels to arrive on the scene. “Red Duchess”—November—this cargo vessel lost all power when close to the shore of the Isle of Rhum in heavy weather. It was taken in tow by the ETV “Anglian Prince” to a place of refuge, Stornaway, Isle of Lewis. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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2.12 The International Group believes that the examples referred to above, which are a very small percentage of the total number of incidents of ETVs being deployed / tasked since 1994, demonstrate the importance of and necessity for the system in the context of both safety of life at sea, passengers and crew, and prevention of pollution, particularly pollution from oil cargoes and bunker oil, the latter being carried on board all ships. 2.13 The International Group understands that the cost of the ETV system is in the region of £2.75 million per ETV per year ie some £11 million per annum and that the French government contributes 50% of the cost of maintaining the ETV based at Dover. This seems a relatively small sum to invest in possibly avoiding catastrophic events such as: (a) the oil pollution resulting from the sinkings of the “Erika” off the French coast in December 1999 and the “Prestige” off the Spanish coast in 2002. As at February / March of this year the claims submitted in relation to these two incidents amounted to E 388.9 million and E 1.037 billion respectively. In the case of the “Erika”, the French government’s claims amount to E 178.8 million and in the case of the “Prestige” the Spanish government’s claims alone amount to E 984,827,922; and (b) major loss of life if say a cross channel ferry or cruise vessel was involved in a collision or experienced engine or steering gear failure and risked going ashore, particularly if in heavy weather or dense fog. 2.14 The cost of the ETV system since its inception in 1994 has been paid from the public purse. This seems appropriate to the International Group since the UK community as a whole beneﬁts from the avoidance of shipping casualties and any consequent loss of life or damage to the environment. Moreover the International Group understands that the ETV systems which have been established in other states eg France, Germany, Netherlands, Norway, Spain and Australia are also government funded, several being initiated in direct recognition of the efﬁcacy of the UK’s ETV system.

3. Conclusion 3.1 The International Group believes that the ETV system that was established in 1994 on the recommendation of the Donaldson Inquiry, has worked well and more than proved its worth. It believes it would be a regressive not to say irresponsible step if the current government, after 17 years, were to withdraw funding of the system and that to do so is likely to prove a false economy bearing in mind the costs that can result from say a major oil spill. Moreover dismantling the system is unlikely to be welcomed by fellow states such as France and the Netherlands which may well be affected by pollution incidents occurring in UK territorial waters or its EEZ. The International Group believes that it is wishful thinking to believe that the need for ETVs can be ﬁlled by commercial salvors as they will be unwilling to incur the cost of maintaining salvage tugs on salvage station in the opportunistic hope of earning salvage rewards by responding to casualties . 3.2 The International Group appreciates that currently the UK’s economic position is not strong and cost saving measures are being effected in many areas. However it is perhaps worth recalling that the UK’s economic position was not greatly different in 1994 when the ETV system was established. Indeed Lord Donaldson in his covering letter to the then Secretary of State for Transport when submitting the report of the Inquiry stated: “In making our recommendations we have not only sought to give due consideration to the international and economic implications of any new measures, but have borne in mind the constraints on public expenditure which exist at the present time and may be expected to continue for some time to come.” April 2011

Written evidence from Andrew Cotterill (MCA 118) The holiday season is now upon us. I have no knowledge of the great shipping lines with all their modern magical communications technology and satellite navigation systems: but I do have knowledge of walking these coastal paths and using the sea in small leisure craft. I have also been asked to represent the Welsh Sea Rowing Association in the matter of the proposed closure of coastguard coordination centres. As responsible users of the sea, before we launch a boat the clubs in our association are asked to do a simple “risk assessment”, simply a weather report-looking at the simple variables like state of the water, weather, wind strength and direction; and any unusual hazards. Then we are encouraged to phone the coastguard station, in our case Milford Haven, to log in: giving boat type and colour, number of PoB [People on Board], direction of travel and expected end of the session: and to log out when we are safely back on land. If there is an incident, or if we are late back, the coastguards already have an idea of our location and they can contact us [by mobile phone or by VHF] to check if we are alright, and if necessary can launch a search—and—rescue mission knowing roughly where we are. Out at sea, the sea conditions can change quickly, wind can pick up, or like tonight the mist can come down. Local knowledge and speed of response is vital at sea if lives are not to be lost. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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We live by the sea, we understand the sea: in particular that it is impossible to know the sea very well, the sea is always the master; we try to be responsible and live within it’s rules. However there are also many users of the sea at holiday times or even during the winter who do not understand the sea, how it can change, and do not understand the tides and tidal flows and the weather patterns: and who go out in poor conditions and get into difficulty. And the cases every year, a fine breezy summer day, sun shining and a kiddie in an inflatable airbed gets caught by the tide or the wind and swept out to sea. In the ensuing panic, a visitor particularly can easily panic, not knowing exactly where they are; and on the Welsh coast may not even be able to pronounce the name. I am astonished that somehow the MCA assumes that a remote coastguard station will be able to pinpoint where the incident is quickly enough to launch a successful rescue. Even though I regularly walk these cliffs, I often only know the beginning and end of my walk, not the names of the individual coves along the way. It is essential that the coastguard stations are retained locally so that the local knowledge of the officers enables a speedy response. On shore, an increasing number of people are using the cliffs and the beaches. Cliffs are dangerous. Even on a well maintained coastal footpath the path can give way; often the cliffs can be hundreds of feet high; and with a narrow path close to the edge. Walking in a strong wind and rain can be an exhilarating experience but if the wind is offshore [blowing out to sea] there is an ever present danger of being blown off the cliff. It is vital that the local knowledge of the coordinating centre is maintained to affect a rescue. Perhaps it is possible to accurately pinpoint a mobile phone signal as a starting point, but often there isn’t a mobile signal: and not all walkers carry telephones: so they may have to run inland for a couple of miles to find a house with a landline telephone. Whilst all this time the casualty is trapped on a cliff ledge perhaps, or the tide is racing in. It is essential that the coastguard centre has enough local knowledge to pinpoint the location from visual clues and anecdote. Even a computer can’t do that. We know from recent fiascos in the NHS that even expensive computer solutions often just don’t work; millions of pounds have been wasted on unusable systems; so the suggested “upgrade” could easily prove again that this is the case, and all the time that casualty is slipping away. You can’t last long in the water. You can’t last long when the tide is racing in. The McA consultation document is written like an elementary exercise in writing a business plan, it makes many assumptions and assumes that the costs will behave as they are forecast- but we already know that part of the plan involves a new build in Portsmouth/ Southampton, with the equipment it is very probable there will be a significant increase in cost before it is completed. This idea of having two super-centresto cover the whole of the British Isles overnight is surely the ramblings of a mad- man, there is no way that will make the public-that’s us who pay your wages—safer. Surely the best way to improve the existing system is to keep all the stations, improving the equipment piecemeal as required, and then to link all the centres through a dedicated line. If the stations working in tandem won’t do: change the system but don’t destroy it. I went to Milford Haven [that’s 60 miles each way] to the public meeting about the proposed closure of the Milford Coastguard Centre. May I immediately point out the absolute contempt we were held in by the panel. The presentation bore no relation to reality. The Chairman was rude, and denied an early point of order when the presentation was quickly descending into jargon, which an ordinary civilian wouldn’t understand. I live within feel of the sea, 25yards from the seafront, and am able to see the always-changing face of the sea. My guess is that the consultation document was written by time-served clerks with little knowledge of the sea, possibly living as far inland as Hemel Hempstead. The consultation document says “it is the aim of the modernisation…that local geographical knowledge will be improved”. This is patently rubbish. Local knowledge can only be improved by extra training for local staff. There is no way that local knowledge can be improved by cutting the staff more-or-less in half and closing down half of the stations, and then leaving only two operational centres at night and hundreds of miles away from many of the public they are meant to be serving.. It is just not going to work and lives will be put at risk.. Two stations at night. Oh dear. They just won’t be able to cope, they will be all at sea. I go out rowing with the Aberaeron Longboat Rowing Club, there are about 20 of our sea-rowing clubs around the coast of Wales. When we go out we report to Milford Haven, and when we return. They know where we are! In the Presentation in Milford Haven we were assured that the two new Centres covering the night-time would be divided into geographical cells with detailed local knowledge: Southampton covering England and Wales, Aberdeen covering Scotland; and if either centre went down the other could still provide cover. This is only going to happen if both centres are duplicating the work of each other and both have geographical cells covering the whole coast of Britain. At the moment we are told that the existing stations are liked “only in pairs”. Surely the safest way to provide safety cover is to link all stations around the coast by a dedicated line. The tides at any point change every day, not only by the time, but also by the height. We had a situation a couple of weeks ago when, one Sunday the tides were the “smallest” ever [here in Aberaeron at 3.4 metres cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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high water]; the next Sunday the tides were the “biggest” ever with high-water here at 5’7 metres. When you have a small tide the low-water was 2. metres; on the big tide the low water was 0.1m. Even if you are a responsible user of the coastal paths and beaches, the chances are that you wouldn’t understand the extent of the tidal changes. These ﬁgures mean that, for example on small tides the water height changes slowly; on big tides the water height changes quickly because the time between high and low and back-to-high again is roughly the same. But it also means that some beaches and coves that aren’t accessible on small tides are easily reached at low water on a big tide: but then the water comes in much quicker and rises much faster so you are more likely to be trapped. The seas around Britain are cold, and life expectancy immersed in seawater can be measured in seconds [Maybe you should fence off the coasts except from 9am to 7pm when there are a few more stations open].

At Penbryn, a beach in Ceredigion, the one week, 13 February 2011, with low water of 1.9 at 1,006 you probably wouldn’t be able to walk round to the second beach. The following week the 20th the low water was at 1,621, at a height of 0.1 and you would be able to walk round to the second beach for a late picnic, then suddenly—it’s getting dark and you’re cut off and the tide is rising fast. On small tides the water may barely touch the cliffs, at big tides the water could be a couple of metres up the cliff, ok if you’re tall. And there isn’t any other way out: assuming you can make contact with the coastguards you rely on the duty ofﬁcer knowing where you are and quickly mobilizing the SAR squad. When the sea is involved, every second counts.

I doubt if you’ve thought that the only way to assure “local knowledge” is to take coach-loads of call-centre operators from Aberdeen and Southampton all around the coast of Britain which is 10,500 miles—or is it 21,000 miles, to all those little coves and beaches where the holiday-makers and walkers could get stranded and drowned.

In the Presentation we were shown these bar charts that demonstrated that the Coastguard Centres were more active during the day in June than overnight in December. Obviously. What it did not mention was that those nighttime, or even daytime- rescues in the winter can be extremely hazardous: driving rain and gale- force winds: and that the coordination of a search relies on, surprisingly, good local knowledge, because folk who get lost, or fall off a cliff, are surprisingly thoughtless when it comes to knowing exactly where they are, or having a good light to help you…

The audience was extremely knowledgeable, and polite. The questions had great depth, many from knowing the coast/sea intimately. The replies by the “coastal safety manager” purely followed the document line and were superﬁcial as standard. The Chairman routinely ignored those he thought would get too close to the bone and closed the meeting after only 90 minutes when many hands were still raised, showing a remarkable arrogance—especially when he came up to us afterwards to apologize for closing the meeting early. [I got an email from the enquiry team saying that the advertised time was 1930 to 2100 so he had to close it: but at the end there were more hands up than at the beginning and he actually had a duty to stay and ﬁnd out what we wanted to know. This was our only chance [though a public meeting in Milford Haven the following Saturday was very well attended, had a variety of speakers from all the main political parties and they all spoke with one voice: we know the sea and this is unsafe].

Also the debate in Westminster hall, [I have read the transcript] everybody who spoke, spoke from a position of knowledge and all were against the proposals.

In Milford Haven the Chairman said, “this is my eleventh meeting” We said, “this is our only one”. Of course, as the evening went on the quaint audience, whose lives are potentially at risk here, had reason to dwell on what we were being fobbed off with and realised how many points were being whitewashed, hence the many hands.

We weren’t given the chance to air our concerns. This meeting, and the documents it covered, were all designed to whitewash the proposed reorganisation.

Incidentally I heard on the news only yesterday that “they” are increasingly concerned by the over reliance on satellite communications technology as these can’t always be reliable.

The document is full of jargon about “..new concept..new procedures..more efﬁcient..latest version of technology..functionality..GIS..sophisticated..populated with large amounts of ..information..” Surely noone believes any of this?

In the end, as coastal, inshore and leisure users of the coasts, we rely on the local knowledge and coverage of the existing Coastguard Control Centres. Not what is proposed in the discussion document. Safely covered around the whole coast of Britain from Aberdeen? Or from Southampton? from Aberdeen? I don’t think so. April 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Further written evidence from Andrew Cotterill (MCA 118a)

It has now come to light that Mike Penning has apparently forbidden serving coastguards from giving evidence to your committee. I am truly disgusted at this behaviour as these are the people WHO KNOW. I attach a further letter I have now sent to Mike Penning and many others.

Mike Penning is the minister in charge of shipping. The Marine and Coastguard Agency has made far- reaching and dangerous proposals to slash the number of operational 24hr Coastguard Control Centres to just two covering the whole of the UK.

The Transport Select Committee are now having an enquiry into these proposals: but Mike Penning has just banned serving Coastguard ofﬁcers, the people who know how dangerous these proposals are, from giving evidence to the TSC.

The government is hell-bent on slashing the number of Coastguard Control Centres around the coast of the UK.

This isn’t just a minority concern, but potentially effects everyone who uses the sea, uses leisure crafts, or who uses the beaches or walks the coastal paths.

Potentially these proposals are going to cost many lives as local knowledge is vital to mobilising search- and-rescue teams, lifeboats and rescue helicopters.

Time is of the essence for folk out to sea in a capsized craft or trapped on small beaches as the tide rises.

Tide heights vary around the country, and at different times of the month.

Without detailed study daily of the tide tables you cannot know the state of local tides.

Tide heights vary every day: the tidal difference between low and high water can be as much as 6 metres around the coast here and up to 10metres on the river Usk at Newport, one of the highest tides in the world. These tidal differences are immense compared with tidal differences for example on the coast of Australia which are a maximum of only 1.5 metres.

Speed of rescue is vital. Serving Coastguard ofﬁcers are well placed to know how dangerous these proposals are. Those of us living on the coast are well aware of the dangers inherent in any coastal activity, and are mounting a concerted campaign against the plans. We go out to sea, we walk the coasts and we are intent on bringing to the attention of everyone who comes to the coast that their lives are being put at risk.

As it happens my written evidence has already been accepted by the TSC, but evidence from the serving coastguards is a vital part of the story and they must not be denied giving that evidence.

I would suggest that we, who live and work on the coast understand the problems in the way that Mike Penning, MP for inland Hemel Hempstead, can never do. May 2011

Written evidence from Les Watson, Coastguard Watch Assistant, MRCC Falmouth (MCA 120)

(A) The Mission Statement for the Maritime and Coastguard Agency

“Our vision is to be a world-class organisation that is committed to preventing loss of life, continuously improving maritime safety, and protecting the marine environment” “Safer Lives, Safer Ships, Cleaner Seas”.

Over the past six to eight months the MCA has made the following announcements: — the withdrawal of the Emergency Towing Vessels; — cessation of support for the Maritime Incident Response Group; — withdrawal of Direction Finding Equipment linked to Ch16 distress channel aerials; — savage cuts to the Coastguard Service; and — downgrading of the current practice of dedicated headset watch on Ch16.

Comment

Is the MCA mission statement “Safer Lives, Safer Ships, Cleaner Seas” still valid? cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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(B) The MCA Budget

Information regarding the MCA Budget was requested on 19 January 2011 under the Freedom of Information Act. The MCA’s reply was dated 10 March 2011. All ﬁgures in £m 2010–11 2011–12 2012–13 2013–14 2014–15 £ £ £ £ £ Programme 131 106.9 104.8 82.2 77 Admin. 0 12.9 11.9 11 10.3 Total 131 119.8 116.7 93.2 87.3

Capital 6.2 tbc tbc tbc tbc

Total Resource and Capital 137.2

Please note: The 2010–11 figure is the adjusted figure as at December 2010, which will be reflected in the Spring Supplementary Estimates The Programme figure excludes budgetary provision for future search and rescue helicopter services.

The Chief Executive held a Q&A session at on 20 October 2010 at MCA Headquarters. The following notes were published on the MCA Intranet (MNet). “Announcements of 20 October sets our cost base for next four years and gives us some sense of direction. But clear about the headline—we will be the best maritime safety organisation in the world, judged by any measure. Key numbers are: Total resource is around £111 million (excluding SAR-H costs). Of that £14 million are our administrative costs (which includes our policy and regulation setting work). In line with Departments across Whitehall, we need to make a 33% reduction against that figure over next four years—around £4.7 million. Our programme costs are close to £97 million, and we need to find a 20% reduction on that— something close to £20 million. We will find £10 million from Ministerial decision not to have tugs as public expense. We have around £2 million to find from efficiencies and a small saving is also likely from the decision to review the MIRG. That leaves us around £7–8 million to find over four years, which will come largely from plans to reshape the Coastguard service, about which we hope shortly to be putting forward detailed proposals for public consultation”.

Comment

The UK Maritime “Insurance Policies” represented by the Coastguard Service, Tugs and MIRG appear to be main target of cuts to the MCA Budget.

(C) MCA Stafﬁng Coastguards working in Ops Rooms around the country fall into the bottom three Civil Service paybands: Watch Assistants—AA grade £13,459 to £14,730* Watch Ofﬁcers—AO grade £15,171 to £18,568* Watch Managers—EO grade £20,321 to £24,873* (* In addition a 25% shift allowance is paid)

The following information was requested on 19 January 2011 under the Freedom of Information Act. The MCA’s reply was dated 22 February 2011. — Average length of service for Coastguard Watchkeeping Staff Answer: 9.5 years cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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— Number of staff in age groups Answer: Age <20 1 Age 20–25 24 Age 26–30 32 Age 31–35 56 Age 36–40 62 Age 41–45 59 Age 46–50 78 Age 51–55 87 Age 56–60 98 Age 61–65 43 Age 66–70 2 Age 70+ 0 — Number of Coastguard staff that have resigned each year for the past ﬁve calendar years, and the reason for leaving the MCA Answer: 2006 2007 2008 2009 2010 Retirement 7 9 13 12 15 To move to other jobs 0 0 0 0 0 Other 38 30 27 17 31 Totals 45 39 40 29 46 — Average Annual Salary (including Shift Allowance) of Watchkeeping Staff? Answer: £22,375.54 — Total number of staff (FTE) currently employed across the whole MCA? Answer: 1177.6 (Full Time Equivalent) — Total number of MCA Staff in receipt of annual salary within the following bands: Answers £40,000 to £60,000 171 £60,000 to £80,000 13 £80,000 to £100,000 2 In excess of £100,000 2 — Of the above, how many postholders have been advised that their posts may disappear as part of general cuts to the MCA budget? Answer: Of the above none have been advised that their posts may disappear as part of general cuts to the MCA budget. This would only occur during a formal redundancy consultation which has not been undertaken. — Of the above, how many of the posts within these salary bands are related primarily to the CG function of the MCA’s work? Answers £40,000 to £60,000 17 £60,000 to £80,000 2 £80,000 to £100,000 nil In excess of £100,000 nil — Of the above, how many of these postholders have been advised that their posts may disappear as part of the “Modernisation of the Coastguard”. Answer: Of the above none have been advised that their posts may disappear as part of general cuts to the MCA budget. This would only occur during a formal redundancy consultation which has not been undertaken.

Comments

With 143 Coastguard Staff aged 56+, it should be possible to reduce staff levels by around 25% but avoid compulsory redundancies.

Despite a proposed reduction of some 20% of the total workforce, it would appear that a proportional reduction in managerial grades is not proposed. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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(D) Network Reliability The following information was requested on 19 January 2011 under the Freedom of Information Act. The MCA’s reply was dated 22 February 2011. — Over the past five years how many times, and for how long, has a single MRCC lost all services requiring its paired station to adopt its role (list station(s), dates and times—exclude planned maintenance) — Over the past five years how many times, and for how long, have both MRCCs in a pair lost all services (list stations, dates and times—exclude planned maintenance) Answer: MCA ICT are aware of some significant outages involving a period of handover of responsibility such as: Falmouth lightning strike in February 2009—major damage with Brixham running area for a number of days. Swansea (UPS overload) in September 2009—power outage for 13 hours with Milford Haven covering co-ordination and hilltops manned overnight. Clyde (fire alarm) in September 2008—Greenock building evacuated reportedly after burnt toast set off fire alarm. Belfast ran area for 20 minutes. Yarmouth (UPS failure leading to generator control panel fire damage) in March 2006—significant damage with Humber running area for circa 15 hours. Also outside of the five year limit of the question but worthy of note due to length of paired station maintaining primacy: Swansea (fire in Regional Business Unit) in December 2005—smoke damage making building untenable for operators with Milford Haven running area for a period of 2.5 days. Brixham lightning strike directly June 2005. Falmouth UPS outage as a consequence of lightning January 2005.

Comment

There has been no occasion when the current paired stations have both lost services. The current arrangement appears to have considerable resilience.

(E) Modernisation of the CG Network To understand the exercises that had taken place to “prove” that the new set up will work, the following information was requested on 19 January 2011 under the Freedom of Information Act. The MCA’s reply was dated 22 February 2011. — The Chief Executive referred in a Telephone Q&A Session to a Table Top exercise that had been undertaken to mirror the new MOC set up. Please provide copies of the following: The Terms of Reference of the Group that undertook this exercise, and the names of the individuals that took part in the exercise. The scenarios and incidents that were considered as part of the exercise. The report written following this exercise. Answer: The table-top exercise was designed to be a test of the MOC/Day Sub-centre concept. It was carried out between MCA and PCS representatives without prejudice and examined the working of a single MOC with three sub-centres covering England and Wales only. No locations were defined as it was only a test of the concept. The concept was measured against the busiest day on record, 23 June 2006, plus an additional major incident and a complete power failure. The outcomes of the exercise were only to hold a discussion with union reps that took part on the model. No report on the outcomes of this exercise was produced by MCA. What was found was that at the peak hour, one MOC and three Sub Centres were strained for a short period of time. What was not examined was the capacity that would have been available with a second MOC for that day plus sub-centres in Scotland and/or Northern Ireland. The loading for the day in question for those areas was not significant. It is worth noting that the concept had no major issues. The loading (which was artificially inflated above the busiest day on record) did stretch the MOC and three sub-centre model that was requested by the PCS. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Comment A PCS Union Rep present at this exercise described it as “farcical”. It is understood that a further exercise is planned for Friday 15 April.

(F) The Coastguard Network in Europe To understand how Coastguard responsibilities and networks vary across Europe, and to see whether the MCA had considered Best Practice elsewhere, the following information was requested on 19 January 2011 under the Freedom of Information Act. The MCA’s reply was dated 22 February 2011. — In each (coastal) European Country which organisation is responsible for co-ordinating: Maritime Rescues. Inshore Rescues (eg capsized dinghy or windsurfer close to shore). Coastal Rescues (eg cliff rescue). Beach Rescues (eg surﬁng injuries). Littoral Searches. Vessel Trafﬁc Services. MAREPs / WETREPs. Counter Pollution. — For each (coastal) European Country: Length of Coastline (km). Number of MRCCs. Total Number of Coastguard Watchkeeping Staff employed. Total Number of VHF Aerials monitored by MRCCs. Total Number of MF Aerials monitored by MRCCs. Number of separate Coast Radio Stations. Total Number of VHF Aerials monitored by Coast Radio Stations. Total Number of MF Aerials monitored by Coast Radio Stations. Total Number of Incidents managed per annum. Total Number of Coast Rescue Teams. — Maritime Operations Centres: List of (coastal) European Countries that operate a single Maritime Operations Centre, and a list of the dates of information gathering visits made to these Centres by members of the Modernisation Team. List of (coastal) European Countries that operate “Daytime Only” MRCCs / MRSCs, and a list of the dates of information gathering visits made to these Centres by members of the Modernisation Team. The MCA refused to provide European Coastguard information as it “will be available from the relevant European organisation”. The MCA was again asked to provide any information it holds, but maintained its decision to not provide it. I have asked them again to review the request for dates of visits etc.

Comment It is not clear whether a comparison with other European Coastguard organisations, or an identiﬁcation of Best Practice, has been undertaken.

(G) VHF Channel 16 The following information was requested on 9 February 2011 under the Freedom of Information Act. The MCA’s response has been published on the MCA Intranet (MNet). Currently VHF Ch16 is monitored at each MRCC, by way of a dedicated 24/7 headset watch. At any time, 24/7, 18 coastguards are currently performing this task around the coast. — under the proposed new structure, will there continue to be a dedicated headset listening watch on Ch16? Answer No we will not continue a dedicated headset watch on channel 16 because we ceased the obligation to do so on 22 September 2003 and this has been our declared level of cover since 1 February 2005. A headset watch can be set if required see CG3 Volume 3 Chapter 2 Section 5.2.3. The Global Maritime Distress and Safety System (GMDSS) was implemented on 1 February 1999. The implementation of the GMDSS has involved the adoption of Digital Selective Calling (DSC) for cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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distress alerting in maritime radio frequency bands—eg VHF. While the United Kingdom Coastguard will continue coverage of VHF Channel 16 for the foreseeable future, from 1 February 2005, the Coastguard watch on Channel 16 will be downgraded from a dedicated headset watch to a loudspeaker watch. Also, from this date, ships that are currently obliged to keep a listening watch on Channel 16 where practicable, will no longer be obliged to do so. Where it is considered that VHF should be fitted……… it is strongly recommended that vessels are equipped with VHF DSC with its significant benefits in distress situations by February 2005. — if answer to (1) is yes...... how many coastguard officers will be undertaking this task at any one time? Will this duty be limited to staff at the MOCs, or will control of local aerials revert to the Daytime Stations during their watchkeeping hours? — if answer to (1) is no...... how will vessels call HM Coastguard (a) if they are in distress, or (b) if they wish to pass routine traffic. How many coastguard officers will be involved in monitoring such VHF traffic? Will this duty be limited to staff at the MOCs, or will control of local aerials revert to the Daytime Stations during their watchkeeping hours? how many staff will be employed at the MOCs monitoring DSC, and also how many staff will be taking Traffic Reports on Ch67. Answer Coverage will continue as currently. In the proposed new structure the allocation at a MOC or sub- Centre of any functional or geographic responsibility, and the necessary staff to undertake this, will be determined by the senior operational manager responsible for the network (located at the Maritime Operations Centre). This will be based upon an assessment of long term workload prediction, internal operational needs and the assessment of workload expected in the near future. The norm is proposed to be that control of aerials in the geographical area that a sub-centre is located would be by that sub- centre during their operating hours. An analysis of current workload, including foreseeable peak incident activity periods, has shown that with a nationally networked structure across which work can be effectively distributed, the maximum number of Coastguard officers needed on duty to meet all anticipated requirements, including emergency response, routine and secondary tasks, is between 35 and 48 during the day depending on predicted activity levels, reducing to 20–32 at night. I also refer to the Workload assessment paper that was published as part of the suite of Risk documents on 16 February 2011. — At present each station can monitor its own local VHF aerials, plus those of its paired station. Under the proposed national network, will the Daytime Stations only be able to monitor their local aerials, or will the system allow any of the eight stations to monitor all 154 aerial sites. Answer The integrated National Network will allow the MOCs and sub-Centres to monitor any aerial in the UK.

Comments The majority of Coastguard Stations around the Coast maintain a dedicated watch on Ch16. Coastguards are expressing concerns that should Ch16 aerials be monitored on loudspeaker in a busy MOC, by fewer operators than currently employed doing so, a faint distress call could easy be missed. The MCA’s own “Watersports and Leisure Report 2009” records that only a small minority of users have access to DSC equipped radios: 18.2% of yacht cruisers; 14.4% of power boaters; 6.5% of boat anglers; 6.2% of small boaters; 1.8% of rowers; and 1.6% of canoeists. The expectation that the majority of leisure craft will carry DSC equipped radios is unlikely to be reached for many years.

(H) Direction Finding Equipment The following information was requested on 19 January 2011 under the Freedom of Information Act. The MCA’s reply was dated 22 February 2011. — Total Number of VHF Aerial Sites ﬁtted with DF Equipment. — Total Cost of Upgrading Equipment to maintain DF Facility. — Estimated operating life of new DF equipment. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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— Annual Maintenance Cost of upgraded DF Facility. Answers: There are / were 48 Aerial Sites ﬁtted with VHF DF equipment. Total Costs: Capital Cost £8 million + Support Costs £16 million. Estimated Operating Life 10 years. The following explanation was circulated by the MCA in Autumn 2010:

TERMINATION OF SEARCH & RESCUE (SAR) FIXED SHORE BASED VERY HIGH FREQUENCY DIRECTION FINDING (VHF DF) SERVICE Questions and Answers What is VHF DF? Direction Finding uses the signal transmitted by a radio to indicate its bearing. Very High Frequency (VHF) includes the frequencies used by mariners.

Why are we terminating the Service? The current infrastructure became operational in the mid 1980s. An operational analysis concluded that there was no longer merit in having a shore based VHF DF capability given the provision of the availability of the service on mobile SAR assets and the steady advent of new technology for locating vessels.

Don’t we have to have a VHF DF capability? The International Aeronautical and Maritime Search And Rescue (IAMSAR) manual states that an RCC must have certain basic capabilities before it is recognised as having responsibility for a Search and Rescue Region (SRR). DF and position-ﬁxing stations are listed as being required. IAMSAR allows for these to be either shore based or mobile.

How else can a VHF DF bearing be obtained? All RNLI AWLBs and SAR aircraft have a VHF DF capability (see Comment A below). Aside from locating a vessel by their nature they may be able to render assistance. The MCA SAR aircraft can also DF on 406MhZ (EPIRB). This capability may become of increasing importance with the use of PLBs inland.

Who have we told? Our partners in Search and Rescue and Maritime stakeholders have been informed.

Do other countries have VHF DF? Few other countries have ﬁxed shore based VHF DF. These tend to be for Vessel Trafﬁc Services (VTS). The Channel Navigation Information Service (CNIS) provided by MRCC Dover has VHF DF and is not affected.

Is DF being removed to save money? Although cost has not been the driver behind our plans to terminate the ﬁxed shore based VHF DF arrangement, replacing the current infrastructure would incur a capital cost of £8 million with support costs of £16 million over 10 years. It is judged that this would represent poor value for money. The MCA is currently renewing the UK shore based DSC infrastructure for both GMDSS A1 (VHF) and A2 (MF) (30nm and 150nm from the UK coast) at a cost of £5.5 million.

How else can a Vessels position be obtained? The Global Maritime Distress Safety System (GMDSS) has the requirement for SOLAS vessels to carry two independent means of distress alerting with a position being in the distress message. These are Digital Selective Calling (DSC), and Emergency Position Indicating Radio Beacons (EPIRBs). The majority of VHF radios available to leisure users since 1999 have a DSC facility (see Comment B below). The cost of EPIRBs has fallen over recent years and we have seen a corresponding increase in take up, including amongst leisure users. HM Coastguard can also respond appropriately to other new and existing non-GMDSS alerting and locating devices. In addition, all vessels over 300 GT and an increasing number of small craft are now ﬁtted with the Automatic Identiﬁcation System (AIS). cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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When will the DF be removed from MRCCs The equipment will be removed when convenient after 31 December 2010.

Comments A. Whilst RNLI Lifeboats and SAR Helicopters have DF equipment, this will only be of use once the resource has launched. The DF facility is of most value in the Operations Room when a Distress Message is being received. If the casualty vessel is unable to pass a full position the SAR resource can be tasked to follow the DF track. B. The MCA’s own “Watersports and Leisure Report 2009” records that only a small minority of users have access to DSC equipped radios: 18.2% of yacht cruisers; 14.4% of power boaters; 6.5% of boat anglers; 6.2% of small boaters; 1.8% of rowers; and 1.6% of canoeists.

(I) Emergency Towing Vessels Risk Assessment Within the Risk Assessment published by the MCA on 11 February 2011: — Section 10 Future Coastguard Manning and Workload Assessment. — Periodicity of Counter Pollution Incidents. — Independent ﬁgures for the likelihood of a pollution incident have been prepared by the National Audit Ofﬁce. Type and Size of Oil Spill—100,000 tons. Frequency: every 17 years. Likelihood in any one year: 6%.

Comment The last major spill was the Braer in 1996, 15 years ago!

Tug Taskings The following information was requested on 19 January 2011 under the Freedom of Information Act. The MCA replied on 25 and 30 March, and 5 April 2011. — Total Annual Cost of the current 4-Tug Contract. — Total number of Taskings per Tug per year for the past five calendar years 2006 to 2010. — Of the above total, how many times did Tugs go off MCA contract. Answers: Projected gross annual contract cost for the current 4 ETV contract is £11.5 million. Projected income in respect of the Dover Strait ETV of £1.3 million. The number of Taskings for each Tug (ETV) for the last five years is shown on the table overleaf. Example: if a merchant vessel transiting the Traffic Separation Scheme between Lands End and the Isles of Scilly has an engine malfunction and is likely to be “not under command” for a period of time, the SW Approaches ETV will be Tasked by MRCC Falmouth to stand by the disabled vessel. The ETV will then be in the best position to assist the casualty vessel should the repair not be achievable, and the vessel is in a danger of drifting into danger. Note: it is understood that the Western Isles ETV regularly escorts laden tankers through the Minches Inshore Traffic route. Also shown is the number of Tows—incidents when the casualty was disabled to an extent that the ETV was required to take a Tow. If a Tow is established the ETV goes “off contract”, and the Tug Company tenders / negotiates a fee from the vessel’s owners. It is understood that the MCA receives a proportion of the charter fee. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Dover Strait SW Approaches Northern Isles Western Isles Taskings Tows Taskings Tows Taskings Tows Taskings Tows 2006 34 4 22 3 10 2 145 1 2007 40 5 32 3 7 1 123 1 2008 22 6 9 2 9 1 122 2 2009 32 6 15 2 5 1 90 0 2010 20 2 19 1 8 2 91 3

Totals 148 23 97 11 39 7 571 7

Comment Only a small proportion of Taskings develop into Tows. However each Tasking has the potential of becoming a Shipping Disaster.

Other Potential Sources of Funding In a message to staff dated 8 April 2011 the Chief Executive stated: “The MCA is holding a series of meetings with local people who perceive that they have an ongoing requirement for ETVs, with the last of the three meetings on 19 April at Clyde MRCC. Any future provision will need to be addressed locally; however the MCA will act as a facilitator for future planning.” It is recommended that consideration be given to reducing the Costs of the ETV provision. Suggestions are: — Greater uses of the Tugs for Hydrographic Survey Work—with the proviso that Coastguard Taskings for Tows (or to stand off a disabled vessel) would take immediate precedence. — Use of the Tug as a “platform” for Border Control and / or Fishery Protection activities—with the proviso that Coastguard Taskings for Tows (or to stand off a disabled vessel) would take immediate precedence. — Recovering some or all of the ETV Charter Costs through a fee (in addition to Light Dues) paid by merchant vessels utilising UK ports.

Comment A major shipping disaster would have national implications. As per the current ETV Contract, a scheme of National Resilience is required.

(J) MIRG The following information was requested on 19 January 2011 under the Freedom of Information Act. The MCA’s reply was dated 22 February 2011. — List of MIRG Teams, and the annual cost to the MCA of each team. — Total number of Taskings per MIRG team per year for the past ﬁve calendar years 2006 to 2010. Answers: The following table represents the number of incidents and location of MIRG teams that have been tasked to and attended during the period between 2006 and 2010. 2006 2007 2008 2009 2010 Cornwall FRS 0 0 0 0 2 East Sussex FRS 1 0 0 1 0 Guernsey FRS 0 0 0 0 0 Hampshire FRS 0 0 0 0 0 Highlands and Islands FRS 0 0 0 0 1 Humberside FRS 0 0 0 1 0 Jersey FRS 0 0 0 0 0 Kent FRS 0 0 0 0 0 Lincolnshire FRS 0 0 0 0 0 Lothian & Borders FRS 0 0 0 0 0 Mid & West Wales FRS 0 0 0 0 0 North Wales FRS 0 0 0 0 0 Northumberland FRS 0 0 0 0 0 Strathclyde FRS 0 0 0 0 0 Suffolk FRS 0 1 0 0 0

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The cost of MIRG for 2009–10 was £581,804 It is not broken down into individual MIRG teams as the MCA fund the whole of MIRG and each team does not have any speciﬁc allocations. These ﬁgures include, training, equipment and management costs.

Comment The cost of a serious incident has the potential of being many times the cost of maintaining the MIRG facility. As with the Tugs, is there scope for raising funds from vessels calling at UK Ports?

(K) The Civil Service People Survey Staff across the Civil Service are encouraged to take part in an annual survey. The results are published for the Civil Service as a whole, and also broken down into the constituent organisations. Statement: “I feel that change is well managed in my organisation”

% Positive Results 2009 Civil Service Wide 27% MCA speciﬁc 14% 2010 Civil Service Wide 27% MCA speciﬁc 12%

Comment The last Survey was carried out in September 2010 ie: BEFORE the Coastguard Modernisation Proposal was published. April 2011

Written evidence from Colin Small (MCA 122) INTO THE MODERNISATION OF THE MCA 1. Background and Experience of Respondent (a) Merchant Navy Radio Officer. (b) National Air Traffic Service Air Traffic Engineer/Senior Air Traffic Engineer specialising in Navigation Aids involving installation and commissioning, training, specification, purchase and acceptance testing and evaluation of systems. (c) National Air Traffic Service Officer In Charge Scottish Maintenance Centre 1984–92 responsible to HMCG for maintenance of HMCG radio systems in southern Scotland including Clyde and Fifeness in addition to other duties. (d) Civil Aviation Authority Safety Regulation Group Inspector of Air Traffic Services responsible for Approval and Safety inspections of ATC electronic systems at airfields, remote sites and air traffic control centres. (e) National Coastwatch Institution watchkeeper/Senior Watchkeeper 2000 to current date at Prawle Point.

2. General This response is made as an individual and does not reﬂect the view of NCI or any other organisation.

3. Summary Conclusion—Expansion of Coastguard Remit 3.1 If the Border Agency cutters and Royal Navy Fisheries Protection fleet were combined, the vessels of both agencies would carry out the full range of activities currently conducted by the separate agencies. Such action would significantly increase the effectiveness of both areas of interest. The Direct Flight aircraft have the capacity to patrol large sea areas and are equipped with very sensitive night surveillance equipment, which could additionally be used in an anti-smuggling or counter-insurgency role, thus enhancing the effectiveness of this asset. Our European colleagues have individually reached similar conclusions regarding the deployment of assets in that a “Joined up” maritime defence and surveillance force is both efficient and cost effective. Although there would be initial organisational difficulties it is logical that a combined Maritime service could fall under the control of an enhanced HM Coastguard. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Conclusion—Coastguard Organisation 3.2 There are signiﬁcant stafﬁng advantages to the two MOC concept but this is dependent upon robust communication and video facilities to assist staff in the precise location of casualties. 3.3 A VERY FULL risk assessment MUST be completed before the project is under way. 3.4 Issues of system redundancy MUST be fully addressed

Conclusions—Operational Equipment 3.5 GPS is a “Fragile” system and should be supported by eLORAN. HMCG sub-centres should be equipped with radar surveillance equipment particularly in TSS areas. VHF D/F equipment should be reinstated. 3.6 As additional equipment is to be procured invitations to tender must be let at European level. The ensuing selection of contractor would be time consuming if equipments of high integrity are to be adequately evaluated purchased and installed to a robust system architecture.

4. Expansion of H.M. Coastguard Remit 4.1 Coastguard services in many European countries operate composite Coastguard services that deal with all aspects of maritime activities around their coasts. In the UK model, HM Coastguard is responsible only for Search and Rescue and other activities related to maritime safety. Other activities are controlled by the Border Agency, the Royal Navy in conjunction with DEFRA, various law enforcement agencies and ﬁre brigades with coastal boundaries.

Border Agency 4.2 The Border Agency operates five cutters, which are deployed according to risk and intelligence. One or two cutters are based in Scottish waters and the remainder in other areas although availability will depend on serviceability and maintenance requirements. The approximate operating costs of the cutter fleet was £9.2 million in 2005–06, £9.5 million in 2006–07, £10.8 million in 2007–08, £10.3 million in 2008–09 and £10.9 million in 2009–10. In 2006, six arrests were made, in 2007 two arrests were made, in 2008 23 arrests were made, in 2009 five arrests were made and in 2010 (Incomplete year), three arrests were made. The figures forementioned do not include arrests made by other agencies and police forces. In terms of the arrests made directly by the cutter fleet the cost per arrest could be judged as significant. It is understood the size of the Border Agency fleet is under review. The cutter fleet is a significant resource and should be employed to maximum capability.

Fisheries Protection 4.3 The Royal Navy operate HMS Trent, HMS Mersey and HMS Tyne under formal contract to the Marine and Fisheries Agency and DEFRA to conduct inspections of all ﬁshing vessels in UK (Excepting Scottish) waters. The Fisheries Protection ﬂeet is supported by four aircraft based at Exeter and Inverness provided by Direct Flight Aviation under contract to DEFRA and Scottish Marine. The contract for the provision of support aircraft is currently under negotiation. Current costs are not known but in 2007 the costs of providing the three Royal Navy vessels was in the order of £25 million per year. It is acknowledged that these vessels were available for other duties. The cost of the provision of aircraft is unknown.

Marine Fireﬁghting 4.4 It is understood that Mr. M. Kettle is to be an oral witness before the committee and it would not be appropriate to comment on this matter as he is expert in this area.

Conclusion—Expansion of Coastguard Remit 4.5 If the Border Agency cutters and Royal Navy Fisheries Protection fleet were combined, the vessels of both agencies would carry out the full range of activities currently conducted by the separate organisations. Such action would significantly increase the effectiveness of both areas of interest. The Direct Flight aircraft have the capacity to patrol large sea areas and are equipped with very sensitive night surveillance equipment that could additionally be used in an anti-smuggling or counter-insurgency role, thus enhancing the effectiveness of this asset. Our European colleagues have individually reached similar conclusions regarding the deployment of assets in that a “Joined up” maritime defence and surveillance force is both efficient and cost effective. Although there would be initial organisational difficulties it is logical that a combined Maritime service should fall under the control of an enhanced HM Coastguard. Allowing for inflation of 3% pa the current cost of operating each Royal Navy vessel is assumed to be currently approximately £9.3 million pa. The cost of operating the Border Agency cutters is approximately £2 million pa per cutter. The Border Agency craft are capable of carrying out Fisheries protection duties at a cost of approximately £7 million pa less per cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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vessel than the Royal Navy craft. With intelligence and facility support from the Coastguard the effectiveness of our coastal defence and ﬁsheries protection would be signiﬁcantly enhanced at lower cost.

5. HM Coastguard Organisation 5.1 At a strategic level there are significant advantages in the two MOC concept. It enables staff to be deployed in the most effective manner, numbers optimised and career opportunities enhanced with the minimum of domestic disruption to individual staff members. If the previous proposal for an integrated Coastguard is accepted such a solution becomes even more attractive with wide ranging career opportunities for staff. 5.2 The concept of a two centre operation with sub-centres round the coast is very dependent upon the design robustness and integrity of the communications facilities with full redundancy in the event of system failure. It is imperative that VERY FULL risk assessments are completed before this project is under way. There is a low risk that a MOC could suffer complete operational failure, the most likely causes being loss of landlines or sabotage. If this occurred during a SAR activity the sister MOC would have difficulty in achieving operational effectiveness within an acceptable period, to be measured in minutes, even assuming the staff were fully aware of the operational situation. An integral part of the risk assessment would be to assume the remaining operational MOC would be involved in a SAR activity when the other centre failed. Staffing levels and system integrity should form part of such an analysis. It is also critically dependent upon the provision of very detailed video maps with high level update capabilities. 5.3 Inspection of the Coastguard Consultation document that the sub-centres operated the remote transmitter/ receiver (Tx/Rx) sites via voice switches in the MOC. Thus if the voice switch or other system failed in the MOC it would not be possible for the sub-centre staff to access remote Tx/Rx sites under their normal control. It would be possible to mitigate such a situation by having direct private wires from the sub station to the individual remote sites. 5.4 If the proposal for an enhanced Coastguard is accepted the sub-centres could also be used by staff currently employed by the Border Agency in addition to MCA staff such as ship surveyors and Coastal Safety managers. Thus the sub-centres would have greater organisational effectiveness and operational costs would be reduced.

Conclusion—Coastguard Organisation 5.5 There are signiﬁcant stafﬁng advantages to the two MOC concept but this is dependent upon robust communication and video facilities to assist staff in the precise location of casualties. 5.6 A VERY FULL risk assessment MUST be completed before the project is under way. 5.7 Issues of system redundancy MUST be fully addressed

6. Coastguard—Operational Equipment 6.1 It is the intention that vessel position and other voyage data is processed in the Consolidated European Reporting System/Single Vessel Database (CERS/SVD), Automatic Identification of Shipping (AIS) and SafeSeaNet. The primary source of vessel position is derived from the Global Positioning System (GPS) and it has been demonstrated by Trinity House trials that this system is not robust (Report No RPT-26-AJG-08 dated 23/09/2008) and that the adoption of an electronic system called eLORAN, a system currently in use by a number of administrations is adopted before the systems forementioned go live. 6.2 Currently all HMCG stations with the exception of Dover rely on vessel positional information provided by AIS, a system fitted to vessels in excess of 300gt although may smaller vessels are now equipped with the system, although this is not mandatory. This is the only positional information available to HMCG staff and it is therefore not adequate to be used for collision prediction. Such a situation occurred recently when a container ship was in collision with the fishing vessel “Admiral Blake”, and two fishing vessel crew were swept overboard but were fortunately recovered. Had the Coastguard been equipped with radar it could have been possible to provide information to prevent the incident. It is recommended that HMCG stations with responsibility for oversight of Traffic Separation Schemes (TSS) should be equipped with radar. 6.3 The offshore environment is becoming increasingly hazardous due to the use of R/T by Watch Officers to determine vessel separation when passing. Such incidents are occurring with increasing regularity and MCA has issued Doc MGN324(M+F) to warn Watch Officers of the dangers of manoeuvring vessels using radio comms. A radar watch maintained by HMCG would mitigate the possibility of vessel collision. There is in fact an accident waiting to happen in the Channel. If an enhanced Coastguard is adopted the radar could be used for counter smuggling and insurgency purposes. 6.4 Many leisure and small fishing vessels have little in the way of navigational and emergency reporting equipment and it is considered that the withdrawal of VHF direction finding equipment was a retrograde step as this system was often the only way of locating such craft. It is likely that this decision will result in the loss of life in the future. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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6.5 There are signiﬁcant reservations regarding the provision and system integrity of communications and video equipment. This matter was considered to some extent in the section on Organisation. 6.6 The reorganisation of Coastguard communications involves a great deal of complex engineering which is to be completed against very tight timescales. It is understood that there are questions of current equipment reliability and if this is the case it is sensible to issue tenders for the provision of replacement systems as the whole concept is predicated by equipment integrity and reliability. If this course of action is to be adopted invitations to tender must be issued at European level due to the value of the contract. The subsequent tender evaluation will of essence be time consuming if costly and politically embarrassing situations are to be avoided. It should be borne in mind that there is a long and noble history of Government computer and comms systems that have overrun both in time and cost with ensuing political embarrassment.

Conclusions—Operational Equipment 6.7 GPS is a “Fragile” system and should be supported by eLORAN. HMCG sub-centres should be equipped with radar surveillance equipment. VHF D/F equipment should be reinstated. 6.8 As additional equipment is to be procured invitations to tender must be let at European level. The ensuing selection of contractor would be time consuming if equipments of high integrity are to be adequately evaluated purchased and installed to a robust system architecture. April 2011

Written evidence from the North Sea Foundation (MCA 123) Introduction The North Sea Foundation (Stichting De Noordzee, The Netherlands), was founded in 1980 (under the name “Workgroup North Sea”) by various large Dutch environmental organizations. There was a need for an organization to coordinate and mobilize the knowledge and expertise in the field of the marine environment. The North Sea Foundation functions as a network organization open for experts in this field. It strives for a complete approach to the problems concerning the North Sea. One of the goals of the foundation is to promote meaningful dialogue over a sustainable use of the North Sea, between environmental organizations and the users of the North Sea (such as the fisheries, offshore, shipping and tourism). One of the tasks is coordination of a group of NGO’s at the International Maritime Organisation, under the flag of the Clean Shipping Coalition. The North Sea Foundation is rather surprised and concerned about the proposed measures by the UK Government not to extend the invaluable and necessary services of the current ETV program.

The Current regime A network of four ETV’s was established around the UK, after the grounding of the tanker BRAER and the subsequent Lord Donaldson report, Safer Ships, Cleaner Seas. The ETV’s commenced in the winter of 1994–95, to protect the UK coastline from shipping casualties, and have been active since. Generally they are stationed in Dover, Falmouth, Orkney and Shetland, although they are moved from time to time as dictated by operational requirements. ETV’s are also maintained by Spain, France, Holland, Germany, and Norway, South Africa and for some vulnerable area’s in the state of Alaska, USA, so the United Kingdom is certainly not unique in recognising the risks and deploying them.

The Cost Our understanding is that the cost of those ETV’s is, roughly speaking, £10–12 million a year although there is some provision for the Government to beneﬁt from commercial work undertaken by any ETV. In addition, there is a Memorandum of Understanding with the French Government who will pay for 50% of the cost of the station tug at Dover so the net cost is less than £10–12 million but it is a rounded ﬁgure, for the sake of argument. In Government terms it is a modest sum and may, perhaps, be considered as an insurance premium to protect our coastline. The Government, through the Maritime and Coastguard Agency (MCA) have indicated that the current contract, which expires on the 30th September this year, will not be renewed and neither will they be going out to tender for a replacement provider.

Task The government has in addition to the deployment of ETV’s accepted the recommendation for the appointment of a Secretary of State’s representative for Salvage and Intervention (SOSREP). The capability to interact by the SOSREP is vastly improved by the provision of ETV’s, and the vested powers to direct and control the ETV’S. The combination has so far proven to be the ideal tools to intervene and control, for rescue and early preventive actions. Certainly the combination and cooperation between the French and the UK ETV’s has been beneﬁcial at various cases. The last one was certainly the case with the ‘NAPOLI’ in early 2008. In cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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this case there were no commercial substitute tugs readily available to interact in a similar fashion as the French and UK ETV’s, and bring the NAPOLI into shallow water for further salvage work. The vested powers with the SOSREP and the Marine Safety Act, includes the power to order a casualty to take a line from a tug, if it is decided the vessel is in dangerous circumstances. He does not have the power to order a supposedly adequate commercial tug, if at all available, to accept a tow line. This difference, of prior negotiating a commercial contract with a Ship Owner, if Owners are known already, could mean the difference between preventing an accident or a full blown catastrophy, with possible severe pollution consequences.

Review The 2008 “Emergency Towing Vessels Assessment of Requirements” (MARICO UK MCA 258) review report gives a detailed overview and inside knowledge in the evolution in shipping patterns around the UK coastline, the declining state of the Commercial Salvage industry, the gamble of relying on the readily availability of commercial tugs, Risk assessments and Cost beneﬁt analysis. Not surprisingly, all analysis and recommendations are in general concurrent with the review and ﬁndings prepared in the 2001 review by the MCA review team and on which basis in 2001, the year round employment of ETV’s was continued.

Conclusion It should be clear that the North Sea Foundation (Stichting De Noordzee), is seriously concerned about the proposed steps taken by the UK Government too not extend the availability and operational functions of the ETV’s , to protect their coastline and adjacent waters. This lacuna will leave the UK coastline severely exposed to shipping casualties and consequent pollution. We are afraid that it will take another pollution incident such as the “BRAER” or the “SEA EMPRESS” to bring the UK Government to their senses. The astronomical cost of cleaning up and the damage caused to the environment by a major oil spill are well documented, particularly after the “DEEPWATER HORIZON”/Macondo incident in the Gulf of Mexico. I think it is a scenario we could well do without in the United Kingdom and adjacent waters, in particular the North Sea. We would urge you to take the conclusions and recommendations from the MARICO report seriously and maintain an adequate coverage by ETV’S around the UK and adjacent waters. We are looking forward to hearing from you in due course. April 2011

Written evidence from Save Shetland Coastguard Steering Group (MCA 124) Written evidence for the House of Commons Select Committee on Transport, in the matter of the proposed closure of the Coastguard stations at Lerwick and Stornoway and the withdrawal of the emergency tug (ETV) cover from the Northern and Western Isles.

Background Our group was set up to organise the petition against the proposed closures of the Coastguard stations and the withdrawal of the emergency tug (ETV). None of us is a serving Coastguard ofﬁcer. We are merely concerned members of the public who felt we had to do something to prevent a serious threat to the safety of our community and the environment upon which we depend.

Summary 1. The Save Shetland Coastguard Steering Group wishes to endorse the comments already submitted to the MCA consultation by Shetland Islands Council and by Tavish Scott MSP and Liam Macarthur MSP. 2. It is important to remember that the Coastguard is the fourth 999 service and, in remote areas such as Shetland, Orkney and the Western Isles, just as important to the public safety as the police, fire and ambulance services. The prime duty of the Government is to protect the public. The MCA proposal undermines that duty of care. 3. We therefore agree that Shetland’s Coastguard station needs to be open 24hrs a day. It is no use having a station part-time when you cannot predict when an incident will happen. No other life saving service is part time. 4. A glance at the map shows how foolhardy the proposals are. The distance from Aberdeen to the north of Shetland is the same as from London to Newcastle-upon-Tyne. 5. Shetland is in the middle of an area of strategic national importance, with oil and gas fields, renewable energy projects and valuable fishing grounds traversed by more and more oil tankers. There needs to be a Coastguard station as near as possible to the centre of this very large sea area, to coordinate the response to incidents. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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6. Nothing in the MCA’s consultation document demonstrates that the proposals will enhance maritime safety or the protection of the environment. The opposite is more likely. 7. There is no coherent documentation. The proposals are not based on clear evidence with authoritative references. This perhaps demonstrates that no proper project management methodology exists. For example, the number of incidents handled is not analysed by type, complexity or duration. The emphasis seems to be on major incidents involving large vessels. There is less detail on the more frequent incidents involving small fishing and pleasure vessels, where local knowledge is particularly useful, as has repeatedly been demonstrated. 8. The proposals ignore the Precautionary Principle, which states that it is up to the proposer of any change to prove that the proposal is not harmful. 9. There appears to have been no competent or coherent assessment of the risks inherent in the proposed changes. There is no detailed local impact assessment. The document merely alleges, without evidence, that there will be no negative impacts. 10. The consultation has been flawed from the start. The questions have been framed in such a way as to channel and skew responses towards approval of the proposals. The consultation document uses technical terms with which a lay member of the public may be unfamiliar, making critical analysis difficult for non-specialists. This is an old trick and it invalidates the consultation’s claims to impartiality and fairness. 11. A further defect of the consultation is that not all service users and Coastguard staff were given the opportunity to comment on the range of possible proposals before the MCA made a public announcement. 12. The consultation states that feedback is to be independently reviewed. However the person in charge of the review is a non-executive director of the MCA and a former Chief Coastguard. These people are no doubt well qualified and well intentioned. It is, however, stretching the meaning of the word to describe them as independent. 13. The entire exercise appears to be a classic case of a “pet project” which has been in preparation for several years and has now become closely identified with the personalities and careers of its protagonists. The result is a focus so narrow as to amount to tunnel vision, with the proposers of the so-called reforms now unwilling or unable, despite their avowed good intentions, to acknowledge or accept dissenting views. There must be doubt whether the relatively new Chief Executive of the MCA has had time to absorb fully all the details of the proposals and their effects. He appears to have been selectively “fed” encouraging information and optimistic predictions by subordinates who have long been committed to the project. In addition to these general criticisms, we wish particularly to emphasise some points, outlined below, which our representatives would be happy to discuss in more detail with the Select Committee, either in Shetland if the committee can arrange to visit the islands, or else at public hearings in London. We understand the committee’s constraints on time and budget but, however, are firmly of the view that the best way for Members to understand the reasons behind the strength of local opinion is to visit our islands in person.

Learning from Disasters — The extraordinary level of support for our petition (over 13,500 signatures) demonstrates the massive local opposition to the MCA’s published plans. This opposition is in large part based on the general public’s knowledge and experience of the valuable work of the Coastguard service in the Northern and Western Isles in recent decades, particularly in the handling of major emergencies around our coast, such as the Dan Air crash (1979), the Chinook disaster (1986), the Piper Alpha disaster (1988), the Braer oilspill (1993), the Green Lily grounding (1997) and the Bourbon Dolphin sinking (2007), to name a few of the better known incidents. — After the trauma of the Braer oil spill there was enormous relief when the then Government implemented many of the recommendations of Lord Donaldson’s report. People felt safer now that something positive had been done to improve safety and protect the environment around their islands. This feeling was heightened when, in response to the recommendations of an inquiry into the loss of the freighter Green Lily, four years later, the Government also accepted that an emergency tug or ETV based in Orkney and Shetland was essential for public safety and the protection of wildlife and the seafood industries. Not solely for commercial salvage considerations, be it noted, but for public safety.

How many People are at Sea and at Risk in the Area? — We wish to remind the committee that a far higher proportion of the Shetland population earn their living on or from the sea than is the case on the UK mainland. The authors of the MCA consultation document appear to be unaware of this. In addition to many hundreds of islanders who are at sea every day as ﬁshermen, salmon farm and shellﬁsh farm workers, tug crews, pilot boat crews, ferry crews, dive charterers, sea anglers and tour boat operators, there are many thousands of non- islanders working all year round in the vast sea area covered by Shetland Coastguard. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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— They include crews of oil and gas production platforms, drilling rigs, accommodation barges, seismic research ships, oilfield supply vessels, diving support ships and hundreds of freighters on passage through the Pentland Firth, the Fair Isle Channel and around Muckle Flugga at the north end of Shetland. In summer, the waters around the Northern Isles also see about 1,000 yachts and 100 cruise liners (some of them among the largest passenger ships afloat and carrying several thousand passengers and crew on a single vessel). — It is quite extraordinary that the MCA consultation document does not appear to have attempted an estimate of the number of souls afloat (and therefore, by definition, at risk) in the area that would be affected by these proposals. This would seem to be basic data for any serious system for the management of risk.

The Danger of Losing Essential Local Knowledge — One of the major risks of the proposal is the loss to the Coastguard service as a whole of the skills, experience and vital local knowledge contributed by the existing local staff at Shetland and Stornoway Coastguard stations. It is unlikely that many Shetland-based staff will be willing to transfer to Aberdeen, uprooting their families from homes, schools and community. The cost of housing in Aberdeen is much higher than in Shetland and few Coastguard officers would be able to afford a move in order to secure a relatively poorly-paid post in an understaffed and overstressed Aberdeen control room (see below). — In the main, it will be recently qualified staff with little or no previous local connection who will be willing and able to redeploy to the mainland. Unemployment in Shetland is low (around 1.5%) and there are plenty of better-paid jobs available in the islands. People choose to work for the Coastguard service in Shetland because of their interest in and commitment to the job, not because of the financial rewards. — Another negative effect of the proposals would be the loss of the close and effective working relationship that has been built up between Coastguards in Shetland and Orkney since the closure of the Kirkwall Coastguard station some 10 years ago. It would be very difficult to replicate and rebuild this if everything were controlled from Aberdeen, 200 miles south of Lerwick. — If the MCA plan to use databases to help with local knowledge (which, they claim, will not be lost), how do they think they will find the pertinent information? The correct terms would have to entered into the search function on their computer to find the desired data. So if the officer who answers a call finds it difficult to understand the message or details and has difficulty in ascertaining the correct spellings for things such as local dialect place names, then a database is useless. Local pronunciations are often different from chart spellings.14 Also, it may only be a short, one-line message that needs good local knowledge to decipher quickly. Even using wildcard searches it would make things difficult because, even if the information is tagged with all the possibilities for that one word or phrase, then the officer would spend a lot of time searching through endless results and wasting time. And who is going to input the information to the database in the first place? In the proposers’ enthusiasm for technological wizardry, this has not been properly thought through. — The effect on the staff of an enlarged control centre in Aberdeen is not properly assessed in the consultation document. In fact the numbers of staff proposed would be inadequate for the tasks they are likely to face when controlling this vast area of coastline and open sea. We would like to present detailed evidence to the committee on this point.

Low Morale and Civil Rights — It must be asked also whether it is a benefit to the service as a whole to antagonise the workforce with unreasonable and ill thought out reforms that are clearly designed primarily to save money rather than enhance public safety. The effects on morale do not seem to have been considered. — We have particular concerns about the undue pressure that MCA management have put on individual Coastguard officers to suppress their professional opinions and defer to the highly questionable arguments put forward in the consultation document. We fear that, like so many synthetic consultation exercises, this one is a sham. The pressure not to make public comments on an issue of vital public concern appears to us to be an infringement of the civil rights of employees. 14 A good example is marked on the charts as Wether Holm Baa, a sunken rock west of the island of Whalsay, a fishing island with a very strong local dialect. When a local vessel stranded on this rock some years ago the skipper reported to Shetland Coastguards at Lerwick: “Wir pa Waddrim Baa” [“We are on the Wether Holm Baa”]. An officer unfamiliar with the local dialect would have had no idea what he was talking about. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Effects on Local Volunteers — Of particular concern is the effect on recruitment and retention of volunteer coast rescue teams in remote rural districts. The Coastguard service has, over many years, built up a network of trained, experienced volunteers who have repeatedly proved their ability to work as a team co-ordinated by full-time local sector officers. The system works, as was demonstrated again recently in the locally co-ordinated search for a missing fisherman off the east coast of Shetland. The financial rewards are meagre. These teams give the Coastguard their time, experience, skills and commitment as a public service, for minimal reward. Good morale is as vital as regular exercises. — The loss of the Lerwick Coastguard station could only damage morale and discourage recruitment and retention of these essential auxiliaries. The experience in Orkney since the closure of the Kirkwall Coastguard station underlines this point.

Loss of Public Conﬁdence and Cooperation — A related hazard is the undermining of public conﬁdence and cooperation. It is noticeable that, since the closure of the Orkney Coastguard station, the Orkney public make fewer calls to the Lerwick station that now covers their area than they did to the Kirkwall station. Thus the service as a whole loses thousands of useful eyes and ears, in addition to the goodwill of the public whose taxes pay for it.

Reliability of Communications—Fundamental Flaws in the MCA’s Argument — The consultation document’s use of BT’s “availability statistics” for radiotelephone and electronic data links between Shetland and the UK mainland (ie how often their system is functional) distracts us from the real issue, which is the effect that a loss or reduction in service has on the ability of the Coastguard service to manage an incident, given that no-one knows when an outage may strike or for how long. — If the Coastguard radio communication systems experience disruption, as they often do, or if they fail altogether, as sometimes happens for up to 12 hours, it is essential to have a backup system so there is still some means of controlling and directing search and rescue operations. It needs to be “bomb-proof”. Under the MCA proposals, it would not be. — The forthcoming connection of Shetland’s telecommunications to the Faroe Telecom fibre-optic cable will greatly improve the situation but will not remove the need for autonomous local backup in the event of failure. The Faroe cable is regularly severed by irresponsible trawlers. Microwave links will still be needed. — It is certain that occasional communication blackouts will continue to occur, even with the new fibre optic cable between Shetland the outside world. At a recent public meeting in Lerwick Town Hall the Regional Director for Scotland and Northern Ireland admitted that although this was foreseeable, no contingency arrangements had been proposed or considered. This is a central flaw in the MCA proposals and cannot be nuanced or fudged away. — When the link to the mainland is lost, the existing organisation at the Lerwick Coastguard station, or Marine Rescue Coordination Centre (MRCC), makes it possible, albeit with difficulty, to maintain coverage and control of an incident using local communications. This is because the service in Shetland is equipped to operate autonomously until communications are restored. For example, officers and volunteers in Coastguard vehicles can be sent quickly to prominent hills and headlands where they can use hand-held radios, mobile phones or, in some cases, landlines to maintain contact with the MRCC, to pass messages to a casualty and to send situation reports. — Without the autonomy and built-in resilience of this local organisation, large areas of the coastline would be “blind” and effectively without cover if and when the MOC in Aberdeen lost contact with Shetland. — The removal of the emergency tug (ETV) will make matters worse because its communication system will no longer be available as a repeater station, for example to relay messages to mobile Coastguard units if shore transmitters are off the air. Nor would it be available to provide radar cover, for example if a vessel in distress has no automatic identification system (AIS) fitted or has an AIS fault. — During May 2011 a major emergency exercise is planned by DECC and the MCA for the open Atlantic oil and gas fields west of Shetland. It will simulate a “Deepwater Horizon” scenario with an uncontrolled and prolonged blow-out from a deep sea well. More than 100 staff from various agencies will take part, presumably including Shetland Coastguard staff at Lerwick, although the exercise is to be coordinated from Aberdeen. Two questions arise from this: is it seriously proposed that such a major and prolonged emergency could be managed effectively without a Marine Rescue Coordination Centre on the nearest land (ie Lerwick)? And have the scenario planners included a contingency plan for a 12-hour loss of communications between Aberdeen and Shetland during the exercise? cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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— Some of the detailed questions that arise include the following: — If the links with Aberdeen Marine Operations Centre (MOC) are down, to whom do the Shetland coast rescue teams speak in an emergency? — How could they handle a Mayday call if they could not contact Aberdeen? — As coast rescue teams have no authority to launch a lifeboat or a search-and-rescue helicopter, who would do this in a communications blackout if the emergency were being handled by Aberdeen? — Do the MCA planners realise that our coast rescue teams have no radios with digital selective calling (DSC) and that their mobile phones may not work if there is a power cut due to storm damage?

Recipe for a Perfect Storm? — If we study the weather data for Shetland over the past 40 years, along with the history of maritime emergencies, it appears that the conditions causing a loss of communication links are also likely to cause a major disaster. A “perfect storm” is the potential result, where communications with the mainland fail precisely when they are most needed. — There are on average about 100 days a year with winds of Force seven or more. Prolonged gales and storms are frequent, regularly disrupting communications as well as problems for vessels at sea. Examples include the Force 11 winds accompanying the grounding of the Braer (January 1993) and the Green Lily (November 1997). — In summer, thick fog can blanket the islands for days on end, disrupting ﬂights and thus delaying the arrival of technicians to repair defective equipment. Fog is frequently accompanied by high atmospheric pressure, which regularly disrupts microwave communications used by the emergency services. — Shetland and Orkney can also be affected by bad weather on the mainland. For example, low tides and south-easterly gales can sometimes close Aberdeen Harbour, cutting off Northlink’s ferry and freight services, which would be required to transport equipment and personnel to the islands in an emergency. — Fog at Aberdeen Airport can also disrupt communications with the islands, reinforcing the point that it is important for the Coastguard service in Shetland to be as resilient and self-reliant as possible, not simply an unstaffed outstation of Aberdeen.

Who Speaks to the Reporters? — A major gap in the MCA document concerns arrangements for handling the media in the event of a major incident involving the Coastguard service. Past experience (Dan Air, Chinook, Piper Alpha, Braer, Bourbon Dolphin, etc.) has shown that several hundred correspondents from all over the world will descend on Shetland if there is a “big story”. — It is essential to have a local contingency plan for such an event, if the media are not to obstruct operations, and this must necessarily involve locally based staff with local knowledge if the organisation is not to be portrayed as ignorant and out of touch with reality. — The task cannot effectively be performed by PR staff and headquarters managers flown in from outside for the occasion. The MCA’s media expert, Mark Clark, is very experienced in this field and, we suggest, might be able to give the committee a frank and professional assessment of the difficulties in dealing with the media when a major incident happens in a remote location.

Reform is Needed and Welcome but this is Change for the Worse — We do not oppose reform and improvement in the Coastguard service. Indeed we would welcome it. It is essential always to keep working practices and technology under review. — There are certainly tasks that the local coastguards might take on, to make more efﬁcient use of resources. Examples include co-ordination of SAR helicopters once RAF Kinloss closes, responsibility for annual survey of small vessels, and closer liaison with police and other emergency services, perhaps in a shared emergency control centre.

We would be happy to discuss these and other ideas with the committee and thank you for your attention to the points raised above. April 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from Wendy Mallon (MCA 127) Letter to Chair from Ms Wendy Mallon Thank you for your recent correspondence. I recently sent you a copy of my letter to my MP Rt Hon Greg Knight concerning my request for him to ask a parliamentary question regarding comparisons of calls/incidents initiated by DSC and VHF Channel 16. I have since heard back from him with a copy of the response from Mike Penning. I quote—“The Maritime and Coastguard Agency could only gather the date you have requested at a disproportionate cost. It is not recorded in a readily accessible format and would require a manual check of all incidents”. Attached is my reply to Mr Knight setting out the details of my explanation as to why this is so important. I thought you might be interested as I understand a further Select Committee meeting is being held regarding the whole HM Closures. I thank you for your time. Letter to Rt Hon Greg Knight MP Thank you for your letter dated 22nd February regarding the question DFT ref: 2754/10/11. I apologise for not writing sooner but I have just come back from Scotland. In answer to your question. I am not sure that it would require a manual check, however in view of the MCA proposals, this DfT question is vitally important as shown below. HM Coastguard staff have pointed out to MCA Management the problems that would occur in monitoring VHF Channel 16 (the distress and calling frequency), following the proposed closure of Maritime Coastguard Co-ordination Centres (MRCC). This would mean one Coastguard operator monitoring up to 16 aerial sites for distress in incoming calls. This would be an impossibility to carry this out effectively at anytime but particularly at times of high atmospheric pressure when stations such as Humber MRCC can receive coast stations from as far away as Denmark and Northern France. Obviously an operator monitoring 15 or 16 aerials, as would be required if Humber closed for the night and handed over to the South Coast, would be in a very real danger of missing distress calls as people at one end of the area making calls to one another or to HM Coastguard, may drown out possible distress calls to one another or to HM Coastguard, may drown out possible distress calls elsewhere in the area. With many distress calls you will get one call, possibly with a position, occasionally followed by mothering further, so there is only one chance as the people in distress may already be in the water, eg MV Rema off Whitby, 25 April 1998 @ 02:21 hrs. Already the MCA has stated that the very valuable direction finding facilities at the MRCC’s will not be maintained and the function therefore will become obsolete meaning it will become more difficult to find a casualty if no position is broadcast. The MCA has stated that this difficulty will be overcome by the use of Digital Selective Calling (DSC), a type of paging system which once activated, alerts the MRCC to a distress. If operated correctly it will give a position. The problem with this, is in the majority of incidents dealt with by HM Coastguard, the casualty vessels are either small fishing vessels or small, private pleasure craft. The MCA have taken the view that all the people will be properly equipped and trained in the operation of the new equipment. In a regulated system ie, as in Portugal, where people going to sea are required by law to be properly qualified and equipped and the vessels are inspected and must be sea-worthy, this system may work. UK governments seem to be reluctant to push for this legislation where which, if backed up by compulsory insurance to recover the cost of rescues, would not only reduce the number of incidents but would find the running of HM Coastguard services. In the majority of the UK Coast people are going to sea on a shoe-string budget, ill-equipped, poorly trained and in some cases, in un-seaworthy vessels. They do not have DSC equipment and have only just started to carry VHF radios, most of which are unlicensed. At the moment HM Coastguard does not attempt (quite rightly), to enforce licensing regulations as its more important to have contact with a distress vessel, however with DSC system the radios will need to be registered because when a distress alert arrives at the MRCC it arrives as a Maritime Mobile Service Identity (MMSI) number which needs to be de-coded to find out the vessels identity. In the case of a hand held DSC unit, it is the hand held set which is issued with the MMSI making it even more difficult to tie-in to a specific vessel, even if HM Coastguard is lucky enough for it to have been registered. In the real world (not the MCA ideal one) people are not equipped with DSC and the majority of incidents alert HM Coastguard via VHF Channel 16. The only way I can see to prove this important point which is key to whether the proposed system will work, is to compare how MRCC’s receive calls for assistance. Which is why I have suggested you ask this question. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Regarding the question it is important that any answer does not include distress calls received from outside the UK Search and rescue region. UK HM Coastguard stations regularly receive DSC alerts from commercial Merchant vessels operating outside the UK SAR region; if these were included it would distort the ﬁgure comparisons we are after. I apologise again for the longevity of this letter and I do thank you for your time and the interest you have shown in this matter. I look forward to hearing from you. March 2011

Further written evidence from Wendy Mallon (MCA 127a) Thank you for your recent reply regarding the latest information I sent you with reference to HM Coastguard and the proposed reliance on DSC alerts. Please find attached a letter to Greg Knight MP (Rt Hon) and a copy of the two press releases. I hope you find this information useful. Once again I thank you for your time and your continued interest. 29 March 2011 Dear Mr Knight, I apologise for pre-empting your reply to my latest letter regarding HM Coastguard and the MCA proposed reliance on DSC alerts. At the risk of bombarding you with yet more information please find attached two press releases15 from the MCA public press office website. I feel like the two examples illustrate the points I’ve previously raised, beautifully. I would also like to draw your attention to worrying trends within HM Coastguard. In view of the changes proposed, several senior experienced staff have already left this service to work in the wind farm industry, which finds the experience gained at HM Coastguard invaluable to their work. The wages offered are in excess of £60,000, but with considerable risk in view of the fact that they offer no pension, sick pay etc, etc. The previous good pensions and working conditions provided by the HM Coastguard are being eroded and the full extent of this decline is not yet known. Understandably, the MCA cannot compete with the private sector in the remuneration stakes. But they should continue to offer excellent job security, conditions and fair pensions. Without the continuation of these good conditions, staff may feel they may as well get three times the wage and poor conditions than receive poor conditions and 3rd of the pay possible. This is in no way should be taken as a threat, but it is a worrying concern and I feel ministers should understand what is at stake with these proposed cuts. I hope you find this information useful and once again I thank you for your time and interest. 29 March 2011

Further written evidence from Wendy Mallon (MCA 127b) Thank you for your departments recent correspondence. Further to my letter of 10 March, I think you may be interested in an update of the situation regarding experienced staff leaving HM Coastguard. The consequence of the staff departures has caused dangerously low manning levels at certain stations around the coast, particularly at stations that are under threat of closure where job departures has been greatest. This situation could result in stations closing at night to maintain manning levels through the day and also put additional strain on those staff remaining and at adjacent stations who have to attempt to take up the stack. I understand that the select committee has become aware of a certain level of bullying by the MCA, discouraging members of staff from disclosing information to the press that will support the employees case. I can conﬁrm that this is true. At the public meeting for Humber MRCC at Bridlington, HM Coastguard staff were told not to tell members of the public that they were staff and were given orders not to wear uniform. 15 MCA press release, “Humber Coastguard urgently seeking boat owner”, 26 March, No. 80–11 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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The Management proposing the closures have claimed that local knowledge can be backed up by IT systems, including the use of Google mapping. Humber MRCC has recently had an update of computers running “vision” and internet; since this update, it is almost impossible to load Google Street level. This is typical of MCA promises and MCA reality. Although I am not a member of staff, obviously I am close to someone who is, someone who is afraid that it could ruin his career prospects if the agency knows the information he has passed through me to the select committee. I am happy for the information to be published if required as long as my address can be withheld. If this must be disclosed for evidence, then please would you keep this letter as private correspondence. April 2011

Written evidence from Shetland’s volunteer Coastguard Rescue Service (CRS) (MCA 128) 1. Foreword At a Station Officers meeting in Lerwick on the 15th January 2011, I was asked to draft a response on behalf of all 16 of Shetland’s Coastguard Rescue Teams to the proposals outlined in HMCG’s Consultation on proposals for modernising the Coastguard 2010 document. Shetland’s Coastguard Rescue Service comprises, from North to South and separated by some 90 miles as the crow flies, the following Coastguard Rescue Teams: Baltasound CRT, Unst, Shetland Isles Fetlar CRT, Fetlar, Shetland Isles Gloup CRT, Yell, Shetland Isles Mid Yell CRT, Yell, Shetland Isles North Roe CRT, Mainland, Shetland Isles Hillswick CRT, Mainland, Shetland Isles Sullom CRT, Mainland, Shetland Isles Huxter CRT, Mainland, Shetland Isles Whalsay CRT, Whalsay, Shetland Isles Walls CRT, Mainland, Shetland Isles Lerwick CRT, Mainland, Shetland Isles Bressay CRT, Bressay, Shetland Isles West Burra Isle CRT, Burra Isle, Shetland Isles Noness CRT, Mainland, Shetland Isles Sumburgh CRT, Mainland, Shetland Isles Fair Isle CRT, Fair Isle, Shetland Isles This document details why we think that the proposals are flawed and should be significantly revised before more monies are wasted and more importantly lives and the environment put at risk.

Executive Summary The Shetland Coastguard Rescue Service main concerns regarding the MCA consultation document are as follows: 1.1 The proposals do not demonstrate that maritime safety will be enhanced. 1.2 Management of the consultation: 1.2.1 No coherent documentation—documentation produced during the consultation period is ad hoc and cobbled from documents produced for other purposes perhaps demonstrating that no proper project management methodology exists; 1.2.2 The precautionary principle has not been utilised whereby new proposals demonstrate that any new system will show that no-one will be harmed; 1.2.3 The use of BT availability statistics (ie how often that the system is fully functional) distract from the real issue which is the effect that a loss or degradation of service provision has on the ability of HMCG to manage and respond to incidents given that no-one knows when that outage or degradation may occur nor for how long; 1.2.4 The data on which the proposals are based only considers the number of incidents and do not take into account the duration, complexity, number of resources committed nor follow up phases; 1.2.5 The consultation states that feedback is to be independently reviewed, however the person in charge of the review, a Coastguard Rescue Service Manager and former Chief Coastguard—QED this is not independent. 1.3 Resilience during communications outage/reduction in service: 1.3.1 At the Lerwick town hall public meeting the Deputy Director of ICT for MCA acknowledged that cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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a 12 hour outage was not only possible but inevitable even with an enhanced BT infrastructure between Shetland and the mainland. Without an autonomous Shetland MRCC, 24/7 the Shetland CRS finds this totally unacceptable given that the outage cannot be predicted. In addition at the meeting it was stated by Regional Director SCOTNI that even though this is foreseeably no contingency arrangements have been proposed or considered; 1.3.2 The overriding concern of Shetland Station Officers is that should the Shetland MRCC close is how do they respond to an incident when they cannot communicate with the proposed MOC and vice versa?; 1.3.3 Current resilience is provided by the Shetland MRCC being able to act autonomously. For example in the event that aerial sites are affected, Shetland MRCC can deploy Coastguard vehicles as required because the MRCC is hardwired to the Lerwick aerial in addition, the internal Shetland BT network is also autonomous allowing the MRCC to call out CRTs—if this MRCC is closed that resilience is lost; 1.3.4 How would an Aberdeen MOC manage an emergency in Shetland and Orkney when communications inevitably fail and how will they communicate with the Shetland CRS?; 1.3.5 Coastguard vehicle radios are not equipped to deal distress calls using Digital Selective Calling on Channel 70 neither is the CRS trained to deal with this modern way of signalling an emergency. 1.4 Local knowledge may, according to the Chief Coastguard, be “parochial and unquantifiable” but in reducing the time to rescue, is absolutely vital. A MOC based in Aberdeen cannot hope to have the level local knowledge that currently exists in the Shetland MRCC.

2. Protecting our Seas and Shores in the 21st Century 2.1 In developing a rational argument for change it is usual to give examples where service provision is stretched to a point where significant change is not only identified but is required. The consultation document provides two examples of real incidents, the bulk carrier Yeoman Bontrup and the sailing vessel The Lord Rank. Whilst acknowledging that both incidents were significant events to those involved there are others examples that could have been used as pointers to future challenges to HMCG. 2.2 West of Shetland oil and gas exploration 2.2.1 The capsize and subsequent sinking of the Bourbon Dolphin was a tragedy which moved through numerous phases, lasting many days from initial response, rescue co-ordination, pollution prevention, salvage to witness statement by investigation teams and state prosecutors. The Bourbon Dolphin tragedy is significant because of the ever increasing exploration and exploitation of the deep waters of the West of Shetland and the implications, as noted in the consultation document, that weather conditions are becoming more extreme. 2.2.2 The World Wide Fund (WWF) reported on its website16 on 4th April 2011: 2.2.2.1 “According to the environmental statement by oil exploration company HESS to drill a well called Cambo 4 the Shetland Islands and their internationally-important colonies of seabirds would bear the brunt of a spill and pollute some of Scotland’s most important fisheries. It also said that attempts to contain the slick “are unlikely to be effective” because of the low temperatures, heavy seas and high winds common in the area. Last month the House of Commons Energy and Climate Change select committee also expressed concern that inadequate equipment and poor planning could delay attempts to cap a leaking well off Shetland.” 2.3. Terrorism and eco-activism 2.3.1 On 10 February 2008 the Safe Scandinavia was involved in a bomb threat17 incident which would have required the evacuation of 539 personnel from the accommodation platform. Whilst referencing a potential “flu pandemic” the consultation document does not mention the threat of either overt terrorism nor ecologically inspired actions or disruptions such as the Greenpeace demonstration which stopped the Stena Carron from sailing for over four days. During which protesters attached themselves to the anchor chains on 21st September 2010 in response to the Deepwater Horizon incident in the Gulf of Mexico. 2.4. The “Perfect Storm” 2.4.1 Other pointers to the future challenges for HMCG include the significant rise in the numbers of 100,000 grt class cruise liners that are now a regular feature of the northern isles summer calendar and carrying in excess of 2600 passengers and crew. The communication links between Shetland and the mainland are not as robust as they are on the mainland, as acknowledged by the MCA’s deputy Director of IT at the Lerwick public meeting when he acknowledged that a 12 hour outage, even with an enhanced BT network was not only possible but inevitable. 2.4.2 The mere thought that a “perfect storm” of extreme weather, loss of communication with the 16 WWF Website: Shetland oil report disaster warning; http://195.225.218.226/what_we_do/changing_the_way_we_live/education/ index.cfm?4597 17 The Timesonline.co.uk : http://www.timesonline.co.uk/tol/news/uk/article3344680.ece cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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mainland, coincident with significant event is therefore very real and must be addressed. We believe that the “Precautionary Principle”18 must be invoked and the MCA dismissal regarding outages challenged. The MCA have discounted the upgrading Shetland MRCC to a MOC, despite the proximity of the existing and peripheral fields to the east and north, termed the East Shetland Basin by the oil industry and the West of Shetlands (sic), termed for good reason the Atlantic Frontier due to the poor communications infrastructure. 2.4.3 Wikipedia explains the Precautionary Principle as follows: “The precautionary principle or precautionary approach states that if an action or policy has a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action or policy is harmful, the burden of proof that it is not harmful falls on those taking the action.” 2.4.4 Simply put, it is for those proposing closure of the Shetland MRCC to demonstrate that in doing so that there will no harm to either people or the environment resulting from the neither the loss of local knowledge nor loss of communication with the mainland. The consultation document, however, provides no such demonstration nor does it demonstrate in that overall maritime safety will be enhanced.

3. The Coastguard Today 3.1 Evidence for the need to change is presented by MCA in two graphs that show diurnal and annual variations in the number of “events” received by HMCG. This is a single data set has not been normalised nor analysed to take into account the severity of the incident the number of CG, SAR and other resources deployed (if at all), the number of phases of the incident and nor the time to either resolution or to stand down. 3.2 This reliance on a single data set significantly (and we believe deliberately) skews the justification for the wholesale re-structuring of the Coastguard. We believe this approach is flawed neither taking into account that the next ‘event’ at any MRCC could range from a query regarding the weather, a mayday from a fishing vessel in danger of sinking or as in the case of the Safe Scandinavia, 539 persons requiring the evacuation from an accommodation platform in the North Sea, illustrating the re-active nature of the HM Coastguard business. 3.3 No account seems to have been taken of geographical differences in the nature of “events”. For example, the south coast of England experiences are greater propensity for recreational related incidents whereas in Scotland “events” tend towards marine related—offshore oil and gas, shipping, fishing and aquaculture. 3.4 Shetland is a true maritime economy, its port and harbours working 24/7 and 365 days a year providing for the oil and gas industry and having one of the UK’s most viable fishing fleets (creel boats, whitefish and the ocean capable pelagic vessels). In addition, Shetland has a large aquaculture industry (ie salmon and mussel farms) the backbone of which is an extensive fleet of workboats. The nature of the people who work in these industries is such that when they call for help, the situation is serious, usually requiring the co-ordination of multiple assets to effect a rescue and usually exacerbated by extremes of weather.

4. Modernising Structures and Systems 4.1 “The heart of the proposals is a move away from regional centres each looking after a geographical limited area with a limited pairing capability, to a nationally networked system with Maritime Operations Centres equipped to manage all incidents wherever they might occur” No evidence has been presented to support why this particular conclusion has been reached. Indeed it is even more surprising in light of the announcement on 20th December 2010, by the Fire Minister to scrap the replacement of 46 ﬁre control centres with nine regional centres at a cost of £423 million.19 4.2 Lack of contingency In 2010 Shetland MRCC was without communication with mainland for a total of 11 days.

18 Health and Safety Executive: United Kingdom Interdepartmental Liaison Group on Risk Assessment (UK-ILGRA); http:// www.hse.gov.uk/aboutus/meetings/committees/ilgra/pppa.htm 19 BBC Website: http://www.bbc.co.uk/news/uk-england-12042563 cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Figure 1 UK SEARCH AND RESCUE AREA CLEARLY ILLUSTRATING SHETLAND’S GEOGRAPHICAL ISOLATION20

4.2.1 Currently if communication links to the mainland are lost, Shetland MRCC can operate autonomously not only maintaining a radio watch but maintaining the capability to manage HMCG’s rescue and co-ordination roles and responsibilities. If the consultation proposals are implemented and links south fails then there will no cover. Deploying CRO’s to man the hilltops is not a realistic option as Channel 16 for emergency use is being replaced by digital selective calling (DSC) which CRO’s do not have access to. 4.2.2 In the event that an Emergency Position Indicating Radio Beacon or EPIRB is activated it will be received by HM Coastguard on the mainland but they will have no ability to co-ordinate or manage a rescue. It may be that a Coastguard MOC in Aberdeen are able to launch the Sumburgh based helicopter or the Aith and Lerwick lifeboats but once launched they will have no contact with any rescue co-ordination centre. 4.2.3 In a perfect world where there is a multiplicity of communication links with back-ups, fail overs and un-interruptible power supplies there may well be a case, communication wise for a MOC. However, the reality is that links both current and planned, between Shetland and the mainland will never be robust enough that total communication failure can be ruled out. 4.2.4 The chain of microwave transmitters from Bressay via Fair Isle, Westray etc. to the mainland are each susceptible to lightning and other weather related failures such that either the signal is lost or severely degraded enough to give significant communication problems. Those who manage networks in the North Isles are well aware of not only how often that fibre optic cables are dug up on the mainland and equipment failure in remote transmitter sites but of the length time that it takes to effect a repair. This can be considerable particularly when transport links are affected by weather, whether that is snow, extreme winds or the blanket fog that can lay over the North Sea for days in summer. It is for this reason that there has to be local contingency which is robust and based in the Isles. 4.2.5 At the Lerwick public meeting the Regional Director for Scotland and Northern Ireland, acknowledged that no contingency plans had been thought about or developed regarding a communications outage to the northern isles. We believe that this is a serious flaw in the consultation document. 4.2.6 Despite mentioning in Chapter 1, page 12 of the consultation document that weather conditions are becoming more extreme is it surprising that no reference is made to weather related risks in 20 Maritime and Coastguard Agency: http://www.mcga.gov.uk/c4mca/mcga07-home/emergencyresponse/mcga-searchandrescue/ mcga-theroleofhmcoasguard.htm cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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the risk register section of the Support Brief—Coastguard Technology Refresh21 document posted on the Coastguard website. In light of the lightning strike on the Westray (Orkney Isles) transmitter which caused such disruption in 2010 and other known weather related failures such as the microwave dish which fell off the Bressay transmitter in a storm force 1022 in 2008, the omission is unforgiveable. 4.2.7 Loss of local links and identity “The desirability of sustaining a regional presence for the regular Coastguard, maintaining strong linkages between the Coastguard Rescue Service and the communities it serves.” 4.2.8 Shetland is predominantly a maritime economy made up of aquaculture, offshore and fisheries (pelagic, demersal and shellfish) and tourist industries and as such Shetland Coastguard’s assets, comprising the SAR helicopter based at Sumburgh, the Shetland MRCC Lerwick, the Shetland and Orkney Coastguard Rescue Service, the two RNLI lifeboats in Shetland and the three in Orkney, are an integral part of that community. It is bizarre to suggest that replacing Shetland MRCC with a Maritime Operations Centre in Aberdeen, over 200 miles away, could generate the sense of community that currently exists. Table 1 COMPARISON OF DISTANCES AND EQUIVALENTS FOR ILLUSTRATIVE PURPOSES Location 1 Location 2 Distance (miles) Aberdeen Baltisound CRT, Unst, Shetland 253 Stornaway, Western Isles Baltisound CRT, Unst, Shetland 262 London Douglas, Isle of Man 264 London Carlyle 261 London Blyth (10 miles north of Newcastle) 257 London Lizard point 264 4.3 Day-time hours working 4.3.1 Shetland’s maritime and offshore economy works 24/7, 365 days a year with minimal diurnal or annual variation and does not fit with normal office hours working. No other emergency service works part time.

5. The Proposed Structure 5.1 As outlined above the proposals rely on a single data set—the total number of “events” excluding training, exercise, faults and London. The data set takes no account of the severity or duration of either the incident or whether the “event” actually translated into an incident requiring Coastguard co- ordination. It is therefore concerning that such a significant re-organisation as this, is based on this single data set. 5.2 HMCG is a re-active service; whilst past incidents can inform structures and watch patterns any reactive service must have sufficient “spare capacity” to cope with major emergencies which by their very nature are non-predictable. As previously stated incidents in Shetland waters tend to be of a more serious nature requiring the use of multiple resources over many hours, sometimes stretching to days and moving through different phases. It seems counter-intuitive therefore that there can ever be an “efficient” level of watch officer workload when you cannot predict whether the next incident is a bomb threat on a North Sea accommodation rig or a request for an update to the weather forecast. A similar situation occurs in permanently staffed fire stations, particularly at night. 5.3 Project risks 5.3.1 Documents released subsequent to the opening of the consultation period seem to suggest that some risk assessment and impact analysis has been carried out but this appears piecemeal and fragmented. Under the UK Office of Government and Commerce’s own project management methodology, PRINCE223 (et seq) at each key project stage, the initial risk register is reviewed, updated and above all, signed off accordingly. This type of formal methodology identifies risks to the overall project succeeding including for instance, the fact that the business case is not sufficiently robust or that the technology will not work in the way that it was proposed or indeed, as in this case, that the consultation proposal itself could be rejected—a risk also having consequential costs and possibly safety issues attached to it. 5.3.2 Under a formal methodology, the use of a single data set would be highlighted as risk and would be accompanied by the appropriate documentation; none has been presented to date. A risk management approach to this project would also seek to learn lessons from similar projects that have failed and given the Fire and Rescue Service has similar remits this would naturally lead to a review of the assumptions and actions in the failed Fire Co-ordination Centre project. 21 Maritime and Coastguard Agency Website: http://www.mcga.gov.uk/c4mca/mcga07-home/shipsandcargoes/consultations/mcga- currentconsultations/hm_coastguard_proposals_for_modernisation_consultation_2010/consultation-risk.htm 22 Hurricane force 12 winds have in recent years become common in Shetland and Shetland Waters. 23 Office of Government Commerce Website: http://www.ogc.gov.uk/methods_prince_2.asp cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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6. Strengthening the Coastguard Rescue Service 6.1 As with other sections of the consultation document, this section raises more questions than it answers. Whilst the impact on Coastal Resources Staff is outlined there is no direct mention on the impact on the Coastguard Rescue Teams themselves. There is not enough detail to assess how these changes would impact locally either initially or in the long term. 6.2 The Shetland CRS is lucky in that they currently have very good working relationships not only between the CRT’s but with the Sector Manager and the Shetland MRCC; these proposals threaten those relationships. There is a trust between the Shetland CRS and the Shetland MRCC and in times of distress knowing the person(s) on the end of the radio underpins and supports that trust.

7. Improving Efﬁciency and Value for Money 7.1 It is the opinion of the Shetland Coastguard Rescue Service that these proposals do not enhance maritime safety but are focussed on saving money. Shetland as a true maritime economy was traumatised by 90,000 tons of crude oil coming ashore from MV Braer in a storm force 10. Nothing in these proposals, given the rapid and continued expansion in the “Atlantic Frontier” and peripheral oil and gas ﬁelds to the east, demonstrates that the risk of a similar event happening again will be reduced. April 2011

Written evidence from Outer Hebrides Coastguard Task Group (MCA 129) Marine Coastguard Agency: A Flawed Modernisation Proposal 1.1 The Outer Hebrides Coastguard Task Group (OHCTG) welcomes the Transport Committee’s inquiry into the modernisation of the coastguard service and related issues and welcomes the opportunity to provide written evidence. Representatives of the OHCTG would be happy to provide oral evidence to the Committee if asked. 1.2 OHCTG has carefully considered the proposals presented in the Marine Coastguard Agency (MCA) document: “Protecting Our Seas and Shores in the 21st Century: Consultation on Proposals for Modernising the Coastguard 2010”. Following extensive local consultation and detailed independent research OHCTG takes the view that the MCA proposals are fundamentally flawed. OHCTG does not believe that the proposals will enhance the service; instead we believe it will increase risk and compromise the safety of shipping and mariners around the UK in general and around the north and west of Scotland in particular. 1.3 OHCTG is supportive of the modernisation of the coastguard service, but do not believe that the proposals brought forward by the MCA are appropriate for a number of reasons. 1.4 OHCTG believes the MCA proposals to be ill thought through from both a technical and cost basis and as a result their implementation will inevitably lead to serious, detrimental safety and environmental impacts. 1.5 The MCA have not been able to credibly articulate the benefits arising from their proposals and as a result there is no confidence in their approach or in their proposals. Their proposals do not carry the confidence of the public of the Outer Hebrides; local coastguard staff; front-line volunteers; the fishing community; the Local Authority or the Outer Hebrides Community Planning Partnership. 1.6 The community of the Outer Hebrides believes that the proposals, if implemented, will in effect dismantle both the local and the wider UK insurance policy against serious incidents. 1.7 OHCTG is seriously concerned that the underpinning rationale behind the proposals does not appear to be maritime safety. From discussion with senior MCA officials it would appear that the proposals are driven by a mix of internal MCA issues such as resolving industrial relations; resolving lease issues arising from particular stations and as a method for the MCA to realise value from particular saleable assets. 1.8 The cost savings to be achieved from these proposals would appear marginal over a 25 year period— any savings will be lost if, for example, one major tanker incident occurs in the Minch. 1.9 The proposals are technically flawed with serious doubts in regard to the proposed technology solution. These concerns are underpinned by a March 2011 report from The Royal Academy of Engineering entitled “Global Navigation Space Systems: Reliance and Vulnerabilities”. The report overviews reliance issues and in the Executive Summary states: “A failure, or loss of signal due to some outside influence, can result in a range of consequences depending on the application…where systems are used in safety of life critical applications, the consequences can be more severe—in some situations, even if operators are well-versed in procedures for a loss of GNSS (Global Navigation Satellite Systems) signals, the number of interlinked systems simultaneously activating alarms can lead to eroded situational awareness of operation in what could well be an emergency situation”. 1.10 It is due to this risk of “eroded situational awareness” that the OHCTG believes that the technology solution proposed by the MCA carries too high a level of risk and should not be implemented. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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1.11 The proposals will lead to the loss of local knowledge, which is an issue of significant concern in an area where the Gaelic language predominates. 1.12 The proposals to base the service around two Marine Operation Centres is seriously flawed; has not been appropriately risk-assessed; will not provide the required resilience and will lead to staff employment / retention challenges. 1.13 OHCTG is supportive of a well-thought through and thoroughly analysed modernisation of the coastguard service. The primary goal of that modernisation should be to enhance the safety of coastal communities and mariners. 1.14 The cumulative impact of the proposed modernisation; the withdrawal of the Emergency Towing Vessel (ETV); the withdrawal of the Maritime Incident Response Group; the withdrawal of Nimrod and the continuing uncertainty around the helicopter rescue service create unacceptable risk. 1.15 All of these issues would be challenging in their own right and would require careful planning and implementation. Implementing these elements simultaneously represents bad strategic planning and in the view of the OHCTG can only be characterised as dangerously reckless. 1.16 The proposed reforms are viewed as an efficiency saving but the potential gains are minimal. The savings are such a small part of the Department of Transport’s overall budget that they were not included in the Department’s Comprehensive Spending Review. 1.17 OHCTG does, however, recognise the need for savings to be made to assist the reduction of the UK’s structural deficit. Reductions in lifeline services, such as the coastguard service, have to be carefully planned and thought through, with the primary goal being enhancement of marine safety. OHCTG does not believe this has been achieved within the MCA consultation proposals. OHCTG takes the view, however, that there are alternative models that will protect and enhance safety, while at the same time achieving cost savings. We believe that the following draft proposal will achieve these two critical goals.

Coastguard Modernisation: A Positive Alternative 2.1 As stated above OHCTG is supportive of the modernisation of the coastguard service, but does not believe that the proposals brought forward by the MCA are the right approach for this critical and highly regarded service. Representatives of OHCTG were therefore heartened to hear Mike Penning, the Parliamentary Under-Secretary, state on a recent visit to Stornoway that the MCA proposals would not be implemented in their present form and that he was looking for groups and individuals to bring forward alternative proposals. OHCTG welcomes this approach and believes that there is a strong case for an alternative model to be developed. 2.2 It is the view of OHCTG that there is a strategic need to provide adequate and well-resourced coastguard cover for the entirety of the UK coastline. In the view of the OHCTG that cover requires to be 24-hour provision and as such we see little to no benefit in the provision of “daylight hours” stations. 2.3 To ensure the type of cover OHCTG believes to be essential for the safety of our communities OHCTG would advocate the establishment of 12 Marine Rescue Coordination Centres (MRCC), each operating 24 hours per-day. This approach would see the reduction and evolution of the existing MCA estate while simultaneously enabling retention of the current workforce’s skills, experience and local knowledge. This approach would also allow sites to mutually support each other, should one be experiencing a particular surge in activity. 2.4 OHCTG’s 12-centre model would propose six stations for England plus two stations for Wales, covering approximately 40% of the UK Search and Rescue Region (SRR). The model would have one station in Northern Ireland. In Scotland three MRCCs are proposed. 2.5 In Scotland OHCTG take the view that a West Coast, North Coast and East Coast MRCC are appropriate. These would be located in Stornoway, Lerwick and Aberdeen, with the four (Scotland + Northern Ireland) stations covering 60% of the UK SRR. This will provide an appropriate spread of strategic centres and would provide a balanced service map across the UK. 2.6 Linking Stornoway, Lerwick and Aberdeen would create a Scottish “tri-service” centre, which would allow the co-location of resilience. Under the model Stornoway would have primary responsibility for the West Coast while Aberdeen would have primary responsibility for the East coast and Shetland the North Coast including Orkney and Shetland. 2.7 The most significant difference between this approach and the MCA’s proposals is that the “local” MRCC would retain overall command of any incident. This approach would ensure that the station with the best knowledge of the particular area would retain command of the incident. In the view of the OHCTG this approach would be significantly more resilient than the two MOC approach proposed in the MCA consultation. 2.8 In the view of the OHCTG it is essential that there is a full appreciation of what is meant by the term local knowledge. In the view of the OHCTG local knowledge is not the ability to remotely call up a “google map”. To us local knowledge is a detailed “situational awareness” of the coastal and maritime environment— cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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it is a deep understanding of the geographical features; topography; weather; daily activity patterns; the users of the water (fishing/merchant/leisure etc); the users of the coastline and littoral areas (walkers/anglers, etc); the culture; the language and accents; the personalities; communities and lastly, it is the critical working relationship between the station and the units it calls out and the civil contingency partners with whom it works. 2.9 The proposed OHCTG model would deliver this critical local knowledge, but it would also be able to incorporate the “operational pairing” referred to by the MCA consultation document. The model would also have the added advantage of reducing manpower requirements while allowing appropriate system flexibility to facilitate leave, training, etc. 2.10 It is anticipated that each MRCC would require approximately 22 operations staff. 2.11 Each of the 12 MRCCs would provide: — capacity for critical local knowledge; — an embedded presence in local communities, which would command the confidence of the general public and marine users; — direct or indirect links to all coastguard aerials, with the capability of receiving communications from vessels anywhere around the UK coast; — more sites to spread the load will enable a major incident affecting any one site to be handled more efficiently thus increasing resilience; — the ability to handle 999 calls made to the coastguard from any location within the UK on both landline and mobile phones; — island-based stations (Stornoway, Shetland and Belfast) in remote sites, which will provide enhanced resilience in the event of a national crisis; — staffing to cope with peak national demand, day and night, achieved at best cost via flexible staffing models, risk assessed staff reductions, etc; and — balanced work-loading across the service, providing greater flexibility to manage training, leave, sick absence, while also providing staff with opportunities for role enhancement/new responsibilities; 2.12 OHCTG takes the view that the 12 MRCC model may prove to be more politically acceptable both to the devolved administrations of Scotland, Wales and Northern Ireland and to the Members of the Westminster Parliament who will be responsible for signing off on this modernisation. 2.13 In relation to Stornoway OHCTG sees a series of overwhelming reasons for an MRCC presence. These can be summarised as follows: — it is self-evident that the more remote a community the greater the risk—this is particularly true of a island community which faces some of the UK’s most hostile weather conditions; — the Outer Hebrides (and indeed the north-west coast of Scotland) is a unique part of the UK that is heavily dependent on the sea and as such views the coastguard service as a major element of the emergency services; — the Stornoway service has strong links and bonds to the community and the community in return has a high level of confidence in the service—that confidence would be detrimentally affected by the loss of the service; — a critical understanding in relation to local Gaelic/Norse place names including duplications and spelling/phonetic difficulties; — the provision of assistance to the police in the co-ordination of land Search and Rescue operations; — the provision of assistance and indeed a lead role in non-maritime emergency incidents eg weather related; — detailed understanding of helicopter operations and the associated terminology / support requirements such as fuel sites, helicopter landing sites and safe helicopter transit through military danger areas etc; and — the existing Stornoway station is a modern, adaptable site, wholly owned by the MCA which already houses many functions and facilities. 2.14 It is also critical to be aware of the strategic location of the present Stornoway facility and the key role it undertakes in relation to international shipping in the north Atlantic. The coastguard station is a reporting station for international shipping entering, transiting and exiting European waters. This is a critical pan- European function that allows a full understanding of shipping active in British and European waters.

Withdrawal of the Emergency Towing Vessel 3.1 OHCTG views the withdrawal of the ETVs as an entirely retrograde step. It is viewed as regrettable in the extreme that the withdrawal was announced with no formal consultation or discussion. It is understood that cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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that the need for ETV provision is not disputed but that the UK Government does not believe that it is now appropriate for the ETV provision to be publicly funded and that a commercial solution be brought to bear. 3.2 The approach and need for ETV provision is most eloquently stated within the MCA’s own documents. An MCA Report entitled “Emergency Towing Vessels Assessment of Requirements”, undertaken by Marico Marine and dated November 2008 states at the synopsis: “The United Kingdom appears to have little option but to continue its involvement in the contracting of Emergency Towing Vessels (ETV). Lack of capability within the commercial tug and towage sector (in effect market failure), European Union obligations, and societal expectations (zero tolerance of major marine environmental incidents) combine to dictate the need for this contingent capability. In cost benefit terms, averting one major shipping disaster and environmental incident of the scale of the Prestige would justify a contract price far in excess of that currently being paid until its expiry in 2011 and beyond.” 3.3 The Executive Summary is equally unambiguous. It states: “The present contract, which operates until the end of September 2011, deploys four relatively large tugs sourced from the offshore oil sector on permanent stand-by at four strategic locations (Dover Strait, the Western Approaches, the Fair Isle Strait and The Minch). They represent a major resource capability in seeking to avert a major merchant-shipping casualty (grounding, foundering, sinking etc) and, in particular, a subsequent marine environmental pollution (oil and/or other hazardous substances) occurrence anywhere within the UK’s Pollution Control Zone (UKPCZ). The key function of an ETV is to intercept ships that are disabled, largely the result of mechanical (engine and/or steering) breakdown, thence secure a tow to bring the crippled vessel under control to prevent catastrophic event escalation. The ETV may also be required to tow the casualty to a location of safety, generally known as a place of refuge. This must often be achieved in a limited time frame, or window of opportunity, prior to the vessel incurring significant damage and losing structural integrity, such as might follow being driven ashore, as seen in the loss of the tankers Amoco Cadiz and Braer, or simply succumbing to the elements, as was the case for the tanker Prestige.” 3.4 The ETVs were put in place following the recommendations of Lord Donaldson following the Braer disaster. Shipping movements and tonnages have greatly increased since the Braer. Given that increased activity, it is the view of the OHCTG that the loss of the ETV will inevitably lead to an incident, which will result in devastating environmental impacts. The costs of any such incident will be significantly greater than any savings to be realised through the ETVs’ withdrawal. 3.5 OHCTG does not believe that there is a commercial solution available in the north west of Scotland. A commercial operator will not come in to fill the void left by the withdrawal of the ETV. As the MCA report states that is clear market failure. 3.6 Given available ETV capacity in the North Sea and English Channel, the view of OHCTG is that there is a high probability of a market-based solution being brought to bear in these areas. That there may be a market-based solution in one part of the country should not, however, lead to the conclusion that there is a market solution readily available for the entirety of the UK. 3.7 OHCTG would advocate a position where the southern ETVs are put out to market solution, but that the two northern ETVs are retained by the public sector until a mechanism can be developed to allow a revising of the contract arrangements. 3.8 There may be some merit in seeking a more commercial approach, but the unilateral cancellation of the ETV contract will significantly jeopardise that goal.

Recommendations 4.1 OHCTG has thought carefully about the issues brought forward by the MCA modernisation proposals. We are supportive of the modernisation of the coastguard, but believe the proposals presented through the consultation to be seriously ﬂawed. It is the view of the OHCTG that these proposals if implemented will increase risk to and compromise the safety of shipping; will have little impact on overall costs and that there are more appropriate alternative solutions. 4.2 OHCTG would therefore respectfully recommend, based on the above conclusions, that the Transport Committee: (a) advises the UK Government against progressing the proposals put forward by the MCA in relation to coastguard modernisation as they do not carry the conﬁdence of the public and service users; are not in the best interests of the UK’s coastal communities and are not in the best interests of mariners due to the fact that the proposals carry an unacceptable level of risk; (b) advises the UK Government to seek a fresh approach to coastguard modernisation based around a 12 MRCC solution operating 24 hours; this approach to have the goal of delivering savings, while providing wide geographic coverage and ensuring the retention of a robust, technologically sound service which maintains critical local knowledge and experience; and cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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(c) advises the UK Government to seek a fresh approach to the withdrawal of ETV services, with particular regard to the north-west of Scotland, where it is clear that there is market failure and no realistic prospect for a commercial solution. April 2011

Written evidence from Northumberland Fire and Rescue Service (NFRS) (MCA 130) Northumberland Fire Authority (NFA) is submitting evidence following the announcement that The Transport Select Committee is to conduct an inquiry into: (a) the Government’s proposals for modernising the Coastguard; (b) the impact of the Government’s decisions not to renew the current contract for emergency towing vessels when it expires in September 2011; and (c) to review arrangements for the Maritime Incident Response Group, which responds to incidents at sea for which fire-fighting, chemical hazard and/or rescue teams may be required. Specifically, NFA wish to provide comment upon item (c).

Introduction 1. Northumberland Fire and Rescue Service (NFRS) is one of the 15 Fire and Rescue Services (FRSs) which comprise the UK Maritime Incident Response Group (MIRG) which provides a national resilient response to fires on board ships at sea. 2. Northumberland is the most northerly English county and provides MIRG response cover primarily to the North East coast of England. The next nearest MIRG FRSs are Lothian and Borders and Humberside. 3. NFRS MIRG team provides direct principal response support to vessels accessing and departing the major North East ports of Blyth, Tyne, Sunderland, Teesport and Berwick. 4. NFRS benefits from having a RAF Search and Rescue base—RAF Boulmer—within its county boundaries. 5. NFRS became a formal MIRG declared asset for the Maritime Coastguard Agency following notification to the Chief Coastguard by (ex) Chief Fire Officer Brian Hesler on 2 July 2007 with an original MIRG establishment of 50 personnel.

Submission 6. NFA considers that the current co-financing arrangements between MCA and MIRG FRSs ensures that a fully integrated, resilient and interoperable response is available to provide a response to fires on board ships off the UK coast. 7. NFA acknowledges and agrees with the comments contained within the MCA independent report by BMT Isis “Review of Requirements in Relation to Assisting with Incidents Involving Fire, Chemical Hazards and Industrial Accidents at Sea” (MCA Consultancy Project Ref CO96), in relation to the cost benefits of maintaining a MIRG response and the value for money provided by the “The existing form of provision (MIRG) has inherent cost advantages because all the basic training and non-MIRG Firefighter training time is funded elsewhere” and “Any commercial equivalent would be expensive and unlikely to constitute an emergency service”. 8. A business review carried out in 2010 on behalf of the MCA by independent scrutineers BMT Isis Ltd as part of the implementation programme of the MIRG concluded that for a proposed reasonable worst case scenario of: “A passenger vessel fire that potentially needs to be controlled for up to two days, has the potential to cause loss of life and cannot be contained by the ship’s finite resources” A risk classification of very high risk is indicated. The risk rating is based upon the following criteria: — a likelihood of one in 200 over a five year period.24 (one in 1000 per annum) — an impact of “Significant” (likely to involve 10 or more fatalities) 9. NFA acknowledges that all mariners receive fire fighting training under The Standards of Training, Certification & Watch Keeping (STCW) Convention and that the primary aims of a ships personnel in the event of a fire is to maintain the integrity of the ship, contain any fire until the ship can reach a place of safety and prevent the partial or full evacuation of the ship. 10. NFA however, also agrees with the International Maritime Organisation (IMO) Maritime Safety Committee recognition that there is a requirement for the provision of external firefighting support and 24 Civil Contingencies Act cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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assistance to be available to a ships Master. The IMO’s Maritime Safety Committee (MSC) published a Circular in 2006, “Guidelines on the provision of external support as an aid to incident containment for SAR authorities and others concerned” (MSC.1/Circ.1183). 11. The national MIRG strategy aims to ensure that fires on board vessels can be contained and effectively managed to allow the vessel to return to port and be brought alongside to enable sufficient shore based resources to be deployed to deal with the incident. In the opinion of NFA, the deployment of local authority professional firefighting teams from the MIRG to a fire on board a vessel at sea significantly reduces the likelihood of an evacuation being necessary, with the consequential reduction of risk to the passengers and crew associated with a full or partial evacuation at sea. 12. The MIRG project has, for the first time, enabled an appropriate and resilient capability to be available to respond to incidents off the North East coast of England by professionally trained and appropriately equipped local authority firefighters. The MIRG response provides much greater security, protection and risk mitigation than has ever previously been available within the region. 13. NFRS MIRG has recently undertaken a structural review to ensure that an effective response can be made whilst at the same time ensuring value for money locally for the Northumberland taxpayer and nationally for MCA/DoT is maintained. Redesign of the NFRS response has resulted in a reduction in NFRS MIRG establishment of approx. 35% whilst maintaining confidence that the requisite response can be maintained. 14. NFA considers that the continuation of national central funding to support a redesigned and leaner MIRG response, which takes cognisance of the requirement to reduce financial burden should be maintained, particularly as the MIRG provides a resilient and active control measure against a national risk profile for incidents on board vessels at sea. 15. Loss of central match funding for the provision of a nationally integrated and interoperable MIRG response will result in NFA having to reconsider its current position as a declared asset to the MCA due to the additional financial burden placed upon local service budgets. NFA would consider it likely that this position will be repeated within some, if not a majority of UK MIRG Fire Services. If this is the case, then the principles and rationale for establishing the MIRG in the first place ie interoperability, resilience, effective and timely support, defined standards of response, strategic risk based cover and standardised governance arrangements will be weakened and potentially lost. 16. The importance of the current governance arrangements for the UK MIRG should not be under estimated. UK MIRG FRSs operate to standardised risk assessments, and mobilisation and operational protocols. This ensures that personnel deployed to vessels at sea have confidence that supporting personnel from other MIRG FRSs will be fully competent to perform the firefighting at sea role, will be familiar with operational practices and safe systems of work and will be using compatible and standardised equipment. 17. Given the potential hazards and risks of committing personnel to a fire on board a vessel at sea, it is essential that Principal or Senior Officers have the confidence in the risk assessment methodology and the underlying processes used to determine if a MIRG team is mobilised and subsequently committed to an incident. The current national arrangements provide that assurance, and include a detailed pre mobilisation assessment, in conjunction with national MIRG and MCA officials, to ensure that the decision to mobilise is as robust as possible. 18. MIRG personnel undertaking firefighting and containment operations on board a vessel ensures that a full risk assessment, operational appraisal and appropriate firefighting/defensive activity has been undertaken before the vessel is brought into port or a safe haven. The removal of a MIRG response will, in the opinion of NFA, add to the inherent risk associated with ship firefighting when the vessel is brought alongside and shore based resources are then committed to deal with the incident. The standard of ship firefighting and containment which has preceded the arrival of the casualty vessel into port may be of variable standard and could potentially compromise firefighter safety. 19. MIRG FRSs provide ship firefighting support to neighbouring fire authorities via Service Level Agreements, within the parameters of arrangements made under Sections 13 of the Fire and Rescue Services Act 2004 or the specific MIRG / FRS handover protocol. 20. Non-MIRG FRSs may receive beneficial support to their own pre-determined response to a ship alongside due to either: — a MIRG team which is already on board the vessel when it is brought alongside remaining in support of the shore based response whether from a operational or command perspective; or — by mobilisation a MIRG contingent, upon request, to the ship berth to assist the Incident Commander and shore based personnel with a specialist and dedicated command or ship firefighting team. 21. Should the reduction of central funding for the UK MIRG result in a reduction of FRSs providing an at sea response, then NFA consider that the outcome will be a return to a disjointed and localised response which is unable to meet the national risk profile of the UK and an inability to deploy MIRG resources to significant areas within the United Kingdom Search and Rescue Region (UKSRR). cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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22. An additional consequence will be a compromising of the current quality assurance processes which have been established since the MIRG inception under the Sea of Change project and a decline in development of specialist ship ﬁreﬁghting command and control techniques which are then shared as best practice within the UK Fire and Rescue community.

Conclusion 23. Northumberland Fire Authority consider that the current MIRG arrangements represent a necessary and appropriate provision to deal with the risks associated with increased passenger and commercial shipping operating off the coast of the UK. 24. Northumberland Fire Authority considers that a strategically located, interoperable and integrated response using specially trained personnel from local authority FRSs should be retained. 25. Northumberland Fire Authority believes that a continued MIRG provision should be centrally funded to reﬂect the national response capability which MIRG provides. NFA also believe that the match funding arrangements which support the current MIRG response represents clear value for money for the UK taxpayer. 26. Without a continuation of central funding to support the provision of the NFRS MIRG team, NFA will undertake a review of the current arrangements with a view to determining whether to continue or withdraw from the national MIRG response. April 2011

Written evidence from Kent and Medway Fire and Rescue Authority (MCA 131) 1. The Department for Transport has stated that our seas are becoming more congested, ships are getting larger, and our coastline is getting busier. This Authority is concerned that the withdrawal of crucial funding for the MIRG would have a severe impact on UK maritime safety and resilience especially in these times of heightened national security. 2. Kent and Medway Fire and Rescue Authority (KMFRA) has a legal obligation to respond to ﬁres onboard ships at its ports but not at sea. It does however have a long history associated with incidents in the marine environment. Signiﬁcantly, the Authority provided a large response to the Herald of Free Enterprise ferry disaster in 1987 at the request of the UK Government. There had been no pre-planning for this type of response and it provided a catalyst for discussions on the ability of the UK to make provision for future marine disasters off its own coastline. 3. The Authority was therefore keen to be instrumental in the development of the Maritime Incident Response Group (MIRG) in 2006 and has fully supported the MIRG programme and the professional response it provides to the marine industry since inception. The Authority considers MIRG a fundamental part of the national resilience arrangements and considers that it should be treated in the same way as the New Dimensions programme and funding.

Impact on Kent and Medway Fire & Rescue Authority 4. The English Channel and North Sea shipping routes are some of the busiest shipping lanes in the world, transporting not only passengers, but freight and bulk Liquid Natural Gas along the Kent coastline. In particular the Port of Dover is one of the busiest passenger ports in the world, handling 13 million passengers and 5 million vehicles every year. At peak periods up to 150 vessels leave for the continent each day, including cruise liners whose numbers are expected to increase in the coming years. The increased passenger and vehicle demand in the period leading up to and during, the Olympic Games will be substantial, and Dover docks have been identified as one of the national sites that will require specific consideration in relation to counter terrorist measures. All of these features make this Port a special risk for the UK. 5. Should the financial support which is currently provided by the MCA for MIRG be withdrawn this would have a significant impact in the way KFRS delivers its marine response. The Authority has considered this issue and cannot foresee a situation where vessels with people on board are at risk following a fire and there would be no response from this county. However, the level of response provided by this Authority would not be to the same level or receive the same support as provided under the MIRG arrangements. 6. Given this, the following points are areas of concern for this Authority and would need to be taken into account when considering whether there could be a response to an incident at sea: — The Authority is keen to ensure the maintenance of fire fighter safety and would be concerned at the additional level of risk to which fire fighters will be exposed through smaller team size and delayed response from other Fire & Rescue Authorities; — Fewer MIRG teams would result in slower back-up support and reduce UK maritime civil resilience; — The loss of the Fire Liaison Manager would see reduced co-ordination and standards across the 15 MIRG teams; cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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— Delayed response times which would increase the likelihood of greater ﬁre spread; and — Future response is likely to be conﬁned to the territorial coast line of Kent. 7. The review report clearly indicates that there is a high risk of this type of incident occurring off the UK coastline and that the current MIRG model is the most appropriate method of responding to this risk. The withdrawal of funding for MIRG therefore seems to be counter-intuitive to the outcomes of the review report. I thank you for taking the time to read this submission, and look forward to hearing the outcomes from the Committee inquiry. April 2011

Written evidence from David Pockett (MCA 132) 1. I am a founder and the former CEO of London Offshore Consultants Group, a leader in investigating and managing maritime casualties and incidents. I am a special casualty representative (SCR) and have been involved in well over 100 marine casualties world-wide. I was also the industry representative on the panel for the selection of the new SOSREP, Hugh Shaw, who replaced Robin Middleton on 1 January, 2008. 2. Since inception of the SOSREP, I have assisted on maritime exercises and also attended casualties in UK territorial waters as SCR or marine adviser where the SOSREP was present and also an emergency towing vessel (ETV)—“ANGLIAN MONARCH”. One such casualty was “MANAAV STAR” which grounded on Camber Sands. I am also aware that there have been many incidents whereby an ETV has been able to respond and in so doing, save lives and/or prevent a risk to the marine environment. The statistics will speak for themselves. 3. It is well known that the Dover Strait is one of the busiest shipping lanes in the world and as such, vulnerable to collisions and groundings. Despite the stringent traffic separation regulations in force, there will always be rogue vessels not complying. With an ETV from the UK strategically positioned in the vicinity, there exists a “first aid” measure which can be critical intervention for both human safety and the protection of the marine environment. To rely on other “chance” commercial salvage tugs to respond in a timely manner might be an adequate measure if readily available, but today, there are no dedicated salvage stations and few tugs available having the specification of the present ETVs. Moreover, relying upon commercial towing vessels also runs the risk of delays due to contractual reasons. It is to be noted that the funding of the ETV in the Dover Strait is shared with the French government. 4. The four ETVs currently under contract, are stationed in strategic positions around the UK coast, selected such that they might be best placed to respond to an emergency in the shortest possible time. Of course, the ETVs may be unemployed” for a considerable period. The same applied to tugs on the traditional salvage stations in days gone by. Salvage/towing companies could ill-afford to continue on an “on-spec” basis. It is argued that the absence of salvage stations left a serious gap in rapid response. The introduction of the ETVs has gone some way to filling that gap although the system can never be perfect. A prime example is the response by the ETV close to the Isle of Skye in 2010 when a nuclear submarine ran aground. Without such facility, the consequences could have been dire. 5. The ETVs were established in 1994 as a result of an in-depth Inquiry (Safer Ships, Cleaner Seas) carried out by the late Lord Donaldson prompted by the tanker “BRAER” incident off Shetland. The advent of the SOSREP system was also as a result of Lord Donaldson’s 1999 Report on Salvage Intervention and their Command and Control. It is noteworthy that the UK led the field in introducing the ETV system, to be followed by France, Germany, Spain and others. It is also noteworthy that the concept of the SOSREP system is the envy of most maritime nation states. Both “systems” were deemed highly necessary at the time of their inception with minimal opposition. They have been a hallmark of the UK’s highly responsible attitude to safety at sea and the protection of the marine environment. 6. Why then the need to be rid of ETVs at least? Government cut-backs is of course cited as the prime reason for making drastic changes to the ETVs (and the Coastguard and Marine incident Response Group). And yet in our every days lives, and not least in the UK, the promotion and training in safety, as well as the continuing prime focus on the environment, and ways and means to reduce and/or eliminate pollution, have been paramount. Notwithstanding, marine incidents resulting in pollution, personal injury and fatality continue, and will continue to occur until eternity. A mere glance at statistics illustrates this fact. Human error is an inherent risk which will never be eliminated. Mother Nature too will not change. Can one put a price on safety and the protection of the marine environment? Well, it would seem that the UK Government has done so but where are the supporting figures and facts? Surely, one needs to consider the numerous incidents which have been responded to by ETVs and then consider the consequences of a failure to respond. One also needs to consider a variety of “worse case scenarios” and the consequences of there being no intervention from an ETV. These might include but should not limited to: (i) A very large crude oil carrier (VLCC) rendered “not under command” ie without power and steering and drifting to the shore. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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(ii) A cross channel ferry in serious difficulties in mid-summer with a full complement of passengers on board. (iii) The latest design of very large container ship in a collision and which might be towed to safety rather than lose its cargo of containers, many of them dangerous goods and non-biodegradable. (iv) A vessel or rig drifting in the North Sea with a risk of colliding with manned offshore installations or sinking on “live” oil pipelines. 7. The counter argument to this is that one should be able to rely on the rapid intervention of commercial towing vessels in all the above cases. However, that assumes they might be readily available and are adequate for the task. I submit that such assumptions would be foolhardy. The current ETVs have bollard pulls of over 150 tons and are therefore heavy duty workhorses able to undertake robust towage operations. It is rare for tugs of a similar power being readily available and close to busy shipping traffic lanes such as the Dover Strait. With offshore installations, there are of course safety vessels operating at each field but again, it is rare for every powerful tugs to be conveniently available in the event of an emergency whereby a large bollard is required. 8. I submit that it is not the time to take a retrograde step and ignore the warnings of yesterday and which triggered the advent of ETVs. The consequences would be too dire and the Government would be shedding responsibility for safety at sea and “cleaner seas”. To put the responsibility in commercial hands is fraught with risk and is, effectively, turning a blind eye. Moreover, it would be to ignore the highly respected and well considered conclusions drawn by the late Lord Donaldson following exhaustive enquiries arising out of what could have been one of the worst environmental disasters in the history of the UK. 9. At best, the Government should find ways to reduce the costs of the ETVs rather than bring the contract to a close. This might involve: (i) Reducing their number. (ii) Negotiating a re-tendering process. (iii) Consideration of smaller tugs in some circumstances. (iv) Examination of costs to the user of such services and how these may be revised. (v) Considering a wider “sharing” partnership (as with France in the Channel) with Netherlands and Norway. 10. In my submission, the risks of ridding the UK Waters of ETVs have not been fully understood and appreciated. The proposal does not appear to be based on rational thinking and opposes modern day attitudes to safety and the environment, the very things where the UK has been the vanguard for so many years and set the standards. April 2011

Written evidence from Outer Hebrides Community Planning Partnership (MCA 133) MARINE COASTGUARD AGENCY: A FLAWED MODERNISATION PROPOSAL 1.1 The Outer Hebrides Community Planning Partnership (OHCPP) welcomes the Transport Committee’s inquiry into the modernisation of the coastguard service and related issues and welcomes the opportunity to provide written evidence. Representatives of the OHCPP would be happy to provide oral evidence to the Committee if asked. 1.2 The OHCPP has carefully considered the proposals presented in the Marine Coastguard Agency (MCA) document: “Protecting Our Seas and Shores in the 21st Century: Consultation on Proposals for Modernising the Coastguard 2010”. Following extensive local consultation and detailed independent research the OHCPP takes the view that the MCA proposals are fundamentally flawed. The OHCPP does not believe that the proposals will enhance the service; instead we believe it will increase risk and compromise the safety of shipping and mariners around the UK in general and around the north and west of Scotland in particular. 1.3 The OHCPP is supportive of the modernisation of the coastguard service, but do not believe that the proposals brought forward by the MCA are appropriate for a number of reasons. 1.4 The OHCPP believes the MCA proposals to be ill thought through from both a technical and cost basis and as a result their implementation will inevitably lead to serious, detrimental safety and environmental impacts. 1.5 The MCA have not been able to credibly articulate the benefits arising from their proposals and as a result there is no confidence in their approach or in their proposals. Their proposals do not carry the confidence of the public of the Outer Hebrides; local coastguard staff; front-line volunteers; the fishing community or the Local Authority. 1.6 The community of the Outer Hebrides believes that the proposals, if implemented, will in effect dismantle both the local and the wider UK insurance policy against serious incidents. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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1.7 The OHCPP is seriously concerned that the underpinning rationale behind the proposals does not appear to be maritime safety. From discussion with senior MCA officials it would appear that the proposals are driven by a mix of internal MCA issues such as resolving industrial relations; resolving lease issues arising from particular stations and as a method for the MCA to realise value from particular saleable assets. 1.8 The cost savings to be achieved from these proposals would appear marginal over a 25 year period— any savings will be lost if, for example, one major tanker incident occurs in the Minch. 1.9 The proposals are technically flawed with serious doubts in regard to the proposed technology solution. These concerns are underpinned by a March 2011 report from The Royal Academy of Engineering entitled “Global Navigation Space Systems: Reliance and Vulnerabilities”. The report overviews reliance issues and in the Executive Summary states: “A failure, or loss of signal due to some outside influence, can result in a range of consequences depending on the application…where systems are used in safety of life critical applications, the consequences can be more severe—in some situations, even if operators are well-versed in procedures for a loss of GNSS (Global Navigation Satellite Systems) signals, the number of interlinked systems simultaneously activating alarms can lead to eroded situational awareness of operation in what could well be an emergency situation”. 1.10 It is due to this risk of “eroded situational awareness” that the OHCPP believes that the technology solution proposed by the MCA carries too high a level of risk and should not be implemented. 1.11 The proposals will lead to the loss of local knowledge, which is an issue of significant concern in an area where the Gaelic language predominates. 1.12 The proposals to base the service around two Marine Operation Centres is seriously flawed; has not been appropriately risk-assessed; will not provide the required resilience and will lead to staff employment/ retention challenges. 1.13 The OHCPP is supportive of a well-thought through and thoroughly analysed modernisation of the coastguard service. The primary goal of that modernisation should be to enhance the safety of coastal communities and mariners. 1.14 The cumulative impact of the proposed modernisation; the withdrawal of the Emergency Towing Vessel (ETV); the withdrawal of the Maritime Incident Response Group; the withdrawal of Nimrod and the continuing uncertainty around the helicopter rescue service create unacceptable risk. 1.15 All of these issues would be challenging in their own right and would require careful planning and implementation. Implementing these elements simultaneously represents bad strategic planning and in the view of the OHCPP can only be characterised as dangerously reckless. 1.16 The proposed reforms are viewed as an efficiency saving but the potential gains are minimal. The savings are such a small part of the Department of Transport’s overall budget that they were not included in the Department’s Comprehensive Spending Review. 1.17 The OHCPP does, however, recognise the need for savings to be made to assist the reduction of the UK’s structural deficit. Reductions in lifeline services, such as the coastguard service, have to be carefully planned and thought through, with the primary goal being enhancement of marine safety. The OHCPP does not believe this has been achieved within the MCA consultation proposals. The OHCPP takes the view, however, that there are alternative models that will protect and enhance safety, while at the same time achieving cost savings. We believe that the following draft proposal will achieve these two critical goals.

Coastguard Modernisation: A Positive Alternative 2.1 As stated above the OHCPP is supportive of the modernisation of the coastguard service, but does not believe that the proposals brought forward by the MCA are the right approach for this critical and highly regarded service. Representatives of the OHCPP were therefore heartened to hear Mike Penning, the Parliamentary Under-Secretary, state on a recent visit to Stornoway that the MCA proposals would not be implemented in their present form and that he was looking for groups and individuals to bring forward alternative proposals. The OHCPP welcomes this approach and believes that there is a strong case for an alternative model to be developed. 2.2 It is the view of the OHCPP that there is a strategic need to provide adequate and well-resourced coastguard cover for the entirety of the UK coastline. In the view of the OHCTG that cover requires to be 24- hour provision and as such we see little to no beneﬁt in the provision of “daylight hours” stations. 2.3 To ensure the type of cover the OHCPP believes to be essential for the safety of our communities the OHCPP would advocate the establishment of 12 Marine Rescue Coordination Centres (MRCC), each operating 24 hours per-day. This approach would see the reduction and evolution of the existing MCA estate while simultaneously enabling retention of the current workforce’s skills, experience and local knowledge. This approach would also allow sites to mutually support each other, should one be experiencing a particular surge in activity. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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2.4 The OHCPP’s 12-centre model would propose six stations for England plus two stations for Wales, covering approximately 40% of the UK Search and Rescue Region (SRR). The model would have one station in Northern Ireland. In Scotland three MRCCs are proposed. 2.5 In Scotland the OHCPP take the view that a West Coast, North Coast and East Coast MRCC are appropriate. These would be located in Stornoway, Lerwick and Aberdeen, with the four (Scotland + Northern Ireland) stations covering 60% of the UK SRR. This will provide an appropriate spread of strategic centres and would provide a balanced service map across the UK. 2.6 Linking Stornoway, Lerwick and Aberdeen would create a Scottish “tri-service” centre, which would allow the co-location of resilience. Under the model Stornoway would have primary responsibility for the West Coast while Aberdeen would have primary responsibility for the East coast and Shetland the North Coast including Orkney and Shetland. 2.7 The most significant difference between this approach and the MCA’s proposals is that the “local” MRCC would retain overall command of any incident. This approach would ensure that the station with the best knowledge of the particular area would retain command of the incident. In the view of the the OHCPP this approach would be significantly more resilient than the two MOC approach proposed in the MCA consultation. 2.8 In the view of the OHCPP it is essential that there is a full appreciation of what is meant by the term local knowledge. In the view of the OHCPP local knowledge is not the ability to remotely call up a “google map”. To us local knowledge is a detailed “situational awareness” of the coastal and maritime environment— it is a deep understanding of the geographical features; topography; weather; daily activity patterns; the users of the water (fishing/merchant/leisure etc.); the users of the coastline and littoral areas (walkers/anglers, etc.); the culture; the language and accents; the personalities; communities and lastly, it is the critical working relationship between the station and the units it calls out and the civil contingency partners with whom it works. 2.9 The proposed OHCPP model would deliver this critical local knowledge, but it would also be able to incorporate the “operational pairing” referred to by the MCA consultation document. The model would also have the added advantage of reducing manpower requirements while allowing appropriate system flexibility to facilitate leave, training, etc. 2.10 It is anticipated that each MRCC would require approximately 22 operations staff. 2.11 Each of the 12 MRCCs would provide: — capacity for critical local knowledge; — an embedded presence in local communities, which would command the confidence of the general public and marine users; — direct or indirect links to all coastguard aerials, with the capability of receiving communications from vessels anywhere around the UK coast; — more sites to spread the load will enable a major incident affecting any one site to be handled more efficiently thus increasing resilience; — the ability to handle 999 calls made to the coastguard from any location within the UK on both landline and mobile phones; — island-based stations (Stornoway, Shetland and Belfast) in remote sites, which will provide enhanced resilience in the event of a national crisis; — staffing to cope with peak national demand, day and night, achieved at best cost via flexible staffing models, risk assessed staff reductions, etc.; and — balanced work-loading across the service, providing greater flexibility to manage training, leave, sick absence, while also providing staff with opportunities for role enhancement/new responsibilities. 2.12 The OHCPP takes the view that the 12 MRCC model may prove to be more politically acceptable both to the devolved administrations of Scotland, Wales and Northern Ireland and to the Members of the Westminster Parliament who will be responsible for signing off on this modernisation. 2.13 In relation to Stornoway the OHCPP sees a series of overwhelming reasons for an MRCC presence. These can be summarised as follows: — it is self-evident that the more remote a community the greater the risk—this is particularly true of a island community which faces some of the UK’s most hostile weather conditions; — the Outer Hebrides (and indeed the north-west coast of Scotland) is a unique part of the UK that is heavily dependent on the sea and as such views the coastguard service as a major element of the emergency services; — the Stornoway service has strong links and bonds to the community and the community in return has a high level of confidence in the service—that confidence would be detrimentally affected by the loss of the service; — a critical understanding in relation to local Gaelic/Norse place names including duplications and spelling/phonetic difficulties; cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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— the provision of assistance to the police in the co-ordination of land Search and Rescue operations; — the provision of assistance and indeed a lead role in non-maritime emergency incidents eg weather related; — detailed understanding of helicopter operations and the associated terminology/support requirements such as fuel sites, helicopter landing sites and safe helicopter transit through military danger areas etc.; and — the existing Stornoway station is a modern, adaptable site, wholly owned by the MCA which already houses many functions and facilities. 2.14 It is also critical to be aware of the strategic location of the present Stornoway facility and the key role it undertakes in relation to international shipping in the north Atlantic. The coastguard station is a reporting station for international shipping entering, transiting and exiting European waters. This is a critical pan- European function that allows a full understanding of shipping active in British and European waters.

Withdrawal of the Emergency Towing Vessel 3.1 The OHCPP views the withdrawal of the ETVs as an entirely retrograde step. It is viewed as regrettable in the extreme that the withdrawal was announced with no formal consultation or discussion. It is understood that that the need for ETV provision is not disputed but that the UK Government does not believe that it is now appropriate for the ETV provision to be publicly funded and that a commercial solution be brought to bear. 3.2 The approach and need for ETV provision is most eloquently stated within the MCA’s own documents. An MCA Report entitled “Emergency Towing Vessels Assessment of Requirements”, undertaken by Marico Marine and dated November 2008 states at the synopsis: “The United Kingdom appears to have little option but to continue its involvement in the contracting of Emergency Towing Vessels (ETV). Lack of capability within the commercial tug and towage sector (in effect market failure), European Union obligations, and societal expectations (zero tolerance of major marine environmental incidents) combine to dictate the need for this contingent capability. In cost benefit terms, averting one major shipping disaster and environmental incident of the scale of the Prestige would justify a contract price far in excess of that currently being paid until its expiry in 2011 and beyond.” 3.3 The Executive Summary is equally unambiguous. It states: “The present contract, which operates until the end of September 2011, deploys four relatively large tugs sourced from the offshore oil sector on permanent stand-by at four strategic locations (Dover Strait, the Western Approaches, the Fair Isle Strait and The Minch). They represent a major resource capability in seeking to avert a major merchant-shipping casualty (grounding, foundering, sinking etc) and, in particular, a subsequent marine environmental pollution (oil and/or other hazardous substances) occurrence anywhere within the UK’s Pollution Control Zone (UKPCZ). The key function of an ETV is to intercept ships that are disabled, largely the result of mechanical (engine and/or steering) breakdown, thence secure a tow to bring the crippled vessel under control to prevent catastrophic event escalation. The ETV may also be required to tow the casualty to a location of safety, generally known as a place of refuge. This must often be achieved in a limited time frame, or window of opportunity, prior to the vessel incurring significant damage and losing structural integrity, such as might follow being driven ashore, as seen in the loss of the tankers Amoco Cadiz and Braer, or simply succumbing to the elements, as was the case for the tanker Prestige. ” 3.4 The ETVs were put in place following the recommendations of Lord Donaldson following the Braer disaster. Shipping movements and tonnages have greatly increased since the Braer. Given that increased activity, it is the view of the OHCPP that the loss of the ETV will inevitably lead to an incident, which will result in devastating environmental impacts. The costs of any such incident will be significantly greater than any savings to be realised through the ETVs’ withdrawal. 3.5 The OHCPP does not believe that there is a commercial solution available in the north west of Scotland. A commercial operator will not come in to fill the void left by the withdrawal of the ETV. As the MCA report states that is clear market failure. 3.6 Given available ETV capacity in the North Sea and English Channel, the view of OHCTG is that there is a high probability of a market-based solution being brought to bear in these areas. That there may be a market-based solution in one part of the country should not, however, lead to the conclusion that there is a market solution readily available for the entirety of the UK. 3.7 The OHCPP would advocate a position where the southern ETVs are put out to market solution, but that the two northern ETVs are retained by the public sector until a mechanism can be developed to allow a revising of the contract arrangements. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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3.8 There may be some merit in seeking a more commercial approach, but the unilateral cancellation of the ETV contract will signiﬁcantly jeopardise that goal.

Recommendations 4.1 The OHCPP has thought carefully about the issues brought forward by the MCA modernisation proposals. We are supportive of the modernisation of the coastguard, but believe the proposals presented through the consultation to be seriously ﬂawed. It is the view of the OHCTG that these proposals if implemented will increase risk to and compromise the safety of shipping; will have little impact on overall costs and that there are more appropriate alternative solutions. 4.2 The OHCPP would therefore respectfully recommend, based on the above conclusions, that the Transport Committee: (a) advises the UK Government against progressing the proposals put forward by the MCA in relation to coastguard modernisation as they do not carry the conﬁdence of the public and service users; are not in the best interests of the UK’s coastal communities and are not in the best interests of mariners due to the fact that the proposals carry an unacceptable level of risk; (b) advises the UK Government to seek a fresh approach to coastguard modernisation based around a 12 MRCC solution operating 24 hours; this approach to have the goal of delivering savings, while providing wide geographic coverage and ensuring the retention of a robust, technologically sound service which maintains critical local knowledge and experience; and (c) advises the UK Government to seek a fresh approach to the withdrawal of ETV services, with particular regard to the north-west of Scotland, where it is clear that there is market failure and no realistic prospect for a commercial solution. April 2011

Written evidence from the Chartered Institute of Logistics and Transport UK (MCA 134) Introduction 1. The Chartered Institute of Logistics and Transport in the UK (“the Institute”) is a professional institution embracing all transport modes whose members are engaged in the provision of transport services for both passengers and freight, the management of logistics and the supply chain, transport planning, government and administration. We have no political afﬁliations and do not support any particular vested interests. Our principal concerns are that transport policies and procedures should be effective and efﬁcient and based, as far as possible, on objective analysis of the issues and practical experience and that good practice should be widely disseminated and adopted. 2. The Institute has a specialist Ports, Maritime and Waterways Forum, a nationwide structure of locally based groups and a Public Policies Committee which considers the broad canvass of transport policy. This submission draws on contributions from all these sources. 3. The Institute welcomes the opportunity to comment on the proposals to terminate the current arrangements with regard to Emergency Towing Vessels and the Marine Incident Response Group both of which were established in order to make our coastlines less vulnerable to catastrophic incidents and their consequences which may result in loss of life, vessels and serious pollution. We believe these cuts to be ill advised and detrimental to the safety of life, property and the environment.

Emergency Towing Vessels (ETVs) 4. Following the grounding of the “Braer” and subsequent oil pollution at Garthness, Shetland on 5th January 1993 the Marine Accident Investigation Branch (MAIB) Inquiry noted: “17.3 Another issue of concern is the availability of suitable tugs around the UK coast, in light of the decline in recent years of the UK towage and salvage industry. The Government has commissioned a survey to establish the availability of salvage resources to assist a disabled tanker off the coast of the United Kingdom. The results of the survey have been made available to Lord Donaldson’s Inquiry.”25 5. The recommendations made by Lord Donaldson in his report “Safer Ships, Cleaner Seas”26 highlighted the need for four ETVs strategically placed around the UK to cover the Marine Environment High Risk Areas. 6. On 15 February 1996 the “Sea Empress” grounded on her approaches to Milford Haven causing massive pollution in those approaches and along the Pembrokeshire coast. The cost of that clean up was estimated at £60 million however with the ongoing damage to the economy and environment the ﬁnal cost is reckoned to 25 Marine Accident Investigation Branch, 1993. Report of the Chief Inspector of Marine Accidents into the engine failure and subsequent grounding of the Motor Tanker Braer. [Online] Available at http://www.maib.gov.uk/publications/investigation_reports/1990_to_1998/braer.cfm 26 Cm2560. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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be double that at £120 million. The Institute understands that a saving of £35.2 million is expected to be made over the spending review period by withdrawing the ETV service.

7. Since Lord Donaldson’s report there have been numerous incidents around the UK coast, including the high proﬁle “MSC Napoli” and more recently HMS “Astute” emphasising the right decision and obvious need for ETVs.

8. The size of ships is continuing to increase; the number of ships calling at or transiting our waters is rising; the oil and gas platforms remain a navigational hazard and the building of numerous offshore wind-farms compounds that risk.

9. In summary the need for ETVs as recommended by Lord Donaldson was supported by a great wealth of evidence and reasoning. That need is just as compelling today if not more so due to the higher risks involved. We would be very rash to ignore those risks and terminate the existing arrangements.

The Marine Incident Response Group (MIRG)

10. Due to the decline in coastal Fire and Rescue Services (FRS) resources available to support the Coastguard service in responding to ﬁres onboard ships at sea, the Maritime Coastguard Agency agreed to fund a research program to redress the issue in September 2002. The primary aim was to produce a strategy report for the Department for Transport in relation to the way UK FRS could support the MCA. Subsequently the research project expanded into the development and implementation of what is now known as the MIRG.

11. In April 2006 the then Secretary of State for transport formally launched the implementation of the new MCA/Fire service partnership as the MIRG. The cost of the initial research and original set-up was in excess of £3 million.

12. Having spent that amount in a well researched and considered scheme it beggars belief that it is to be scrapped after ﬁve years.

13. Within four weeks of the MIRG going live in 2006, a MIRG team was deployed to a serious fire on the cruise ship MV “Calypso” in the English Channel with 480 persons onboard. Numerous other incidents have occurred since then the latest occurring last year when a fire broke out onboard a fishing vessel at night 15 miles off the coast of Cornwall which needed the crew evacuating, the MIRG on board to tackle the fire and the emergency tug to stabilize the ship as it threatened to capsize.

14. The MCA MIRG website states: “1.4 An increasing decline in UK resilience for dealing with fires at sea provided the catalyst for the ‘sea of change’ project which at the request of the Secretary of State for Transport was launched by the MCA in partnership with the Chief Fire Officers Association (CFOA) in January 2003.” “1.5 The primary aim of the project was to formalise a fully trained, equipped and integrated FRS response to assist the MCA (through the Coastguard) in dealing with incidents involving fire, chemical hazards and industrial accidents at sea. This response would be drawn from the thirty nine coastal FRS’s who collectively represented the CFOA Marine Operations Group (MOG)”27

15. The mission statement of the MIRG is: “To save life. To reduce loss and mitigate environmental and ecological damage. To render where appropriate all humanitarian services.”

16. MRIG underpins the MCA vision “To be a world class organisation that is committed to preventing loss of life, continuously improving maritime safety and protecting the marine environment”.

17. Is all that now to go by the board and be ﬂushed down the scuppers?

18. The FRS and MIRG are held in the highest regard by seafarers the world over. Indeed it is the Fire Services which train the seafarers to the required competence in basic, advanced plus command and control for the Standards of Training Certiﬁcation and Watch-keeping (STCW) levels. However despite this training it in no way fully prepares them in the event of a serious onboard ﬁre. In coastal waters the professional and expert assistance of the MIRG is crucial in minimising the loss of life, ship and subsequent damage to the environment.

19. Sadly ﬁres and hazardous cargo incidents continue to occur in our UK waters and it is only by the timely intervention of the MIRG that loss of life, ships and pollution is kept to a minimum. April 2011

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Written evidence from Holman Fenwick Willan LLP (MCA 138) GOVERNMENT’S DECISION NOT TO RENEW ETV CONTRACT With regard to the Transport Select Committee’s examination of the impact of the Government’s decision not to renew the UK Emergency Towing Vessel (“ETV”) contract, we are grateful for the opportunity to provide our comments on this subject.

Our Background 1. Holman Fenwick Willan LLP has a long-standing reputation in providing legal services on all maritime- related issues. We act, and have acted for over a hundred years, for all manner of clients in the maritime sector, including shipowners, charterers, professional salvors and underwriters. We are one of the world’s leading shipping law firms, and are frequently recognised as such. 2. Furthermore, we have first-hand knowledge of the UK ETV service. We have acted on behalf of the current ETV providers (JP Knight) and their predecessors (Klyne Tugs) on various ETV-related matters. 3. We therefore feel that we are in a good position to understand the consequences of maritime incidents/ accidents, both nationally and internationally. We are familiar with their effects on domestic coastlines, the environment in general, local populations and businesses, and fully understand the role of ETVs in limiting the number and severity of these incidents. Holman Fenwick Willan LLP’s view is that the rationale behind the ETV contract is still totally sound, that the withdrawal of ETV funding will severely jeopardise the UK’s maritime defences and that this decision will result in the breaking up of an essential service that fulfils a major protective role. 4. We would like to stress that this letter has been drafted from an independent viewpoint. We have not been instructed to write this letter, nor are we receiving any sort of remuneration for its production. We have chosen to draft this letter in our own time as we are concerned about the potential ramifications of this hasty decision.

Development of the UK ETV Fleet 5. You will no doubt be aware that following the “BRAER” incident in 1993, Lord Donaldson produced his excellent report “Safer Ships, Cleaner Seas”. One of the most notable recommendations of the report was the establishment of a network of ETVs, strategically located, to protect our coastline and seas from maritime catastrophes and their consequences. The ETV response not only assists in protecting the maritime environment and coasts, but is also a significant source of comfort for the maritime industry and the UK population in general. 6. Over time, and particularly in the aftermath to the “SEA EMPRESS” disaster, the UK’s ETV provision was seen as an essential part of the UK’s emergency maritime response capability and the decisions were taken to (1) enlarge the fleet and (2) ensure it was kept on standby 24-hours a day, 365 days a year. 7. This year-round service has been consistently supported by official MCA reports, including: (1) A Review of Emergency Towing Vessel (ETV) Provision Around the Coast of the United Kingdom (published in January 2001); and (2) Emergency Towing Vessels Assessment of Requirements, prepared by Marico Marine (published November 2008). There has also been significant and continuous support for ETV provision from within the MCA and the shipping industry in general. 8. It is of particular interest to note that most of the latest proposals concerning ETV provision (prior to the decision to withdraw funding) were centred around the potential enlargement of the UK’s fleet to five vessels (with one vessel to be based in the Irish Sea area). There was no real discussion about withdrawing the fleet.

Basis to the Government’s Decision 9. The Government’s decision has clearly been based around the supposed ﬁnancial need to make rapid short-term savings. This is a political issue upon which we shall not provide our comments. We are aware of two additional factors that have been mooted as apparently justifying the Government’s decision: (1) There has been a reduced number of domestic incidents in recent years and that these have been of limited severity; and (2) The Government believes that any necessary ETV services can be provided by the private sector. 10. We have a number of observations to make on these points.

Reduced Number/Severity of Incidents 11. We admit that certain statistics lead to the impression that there are a reduced number of incidents at sea and that the impact of such incidents may not be as serious as has been witnessed in the past. On the other hand, it cannot be forgotten that, regardless of what the statistics show, there have been numerous serious (or cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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potentially serious) incidents in the near past, one of the most notable being the breaking up of the “MSC NAPOLI” off the coast of Dorset in early 2007. Without the assistance of two of the French ETVs, the consequences of this casualty could have been much more serious than they were. 12. These short-term statistics are, however, completely incidental to the primary function of ETVs, which is to provide a 24-hour preventative response to assist vessels in distress or that are disabled. The ETVs’ role is to provide assistance well in advance of a situation becoming potentially dangerous. 13. To many, these incident statistics simply show that the ETV fleet has proven effective in fulfilling its preventative role. To us, these statistics serve to show that the UK has (1) been rather fortunate over the past few years, and/or (2) adopted suitable prevention measures to foresee and provide for an effective incident response (including providing funding for a professional and dedicated ETV fleet capable of assisting vessels in difficulty and of preventing any potentially-disastrous escalation). 14. We are more familiar than most with the amount, nature and severity of incidents that can occur at sea. We are involved in dealing with maritime casualties around the globe and can state, in our honest opinion, that human error/misfortune nearly always plays a role in such casualties, cannot be completely eliminated, and cannot be contained to certain geographic regions. In sum, incidents happen and can happen anywhere. The withdrawal of the ETV fleet will remove one of the essential preventative tools for dealing with such incidents when they do happen and for ensuring that apparently minor incidents are addressed and contained before they are allowed to escalate. 15. Furthermore, and as you will no doubt be aware, modern ships are built with ever-increasing cargo and bunker capacity. The consequences of any incident that is allowed to escalate would therefore result in potentially much more serious effects. With this in mind, and although we do not believe that any decision on the provision of a dedicated ETV fleet should be based on simple financial analysis, we would like to point out that any cost of maintaining an ETV provision would be dwarfed by the financial effects of any single maritime catastrophe. By way of example, the use of ETVs would quite possibly have resulted in a saving of approximately £650 million in relation to the “PRESTIGE” incident in 2002. If converted to the present day, and assuming the involvement of an even larger vessel, this figure would no doubt be much closer to the £1 billion mark, or higher. 16. Other industry developments should also raise considerable concern about the withdrawal of the ETV fleet. For instance, increased transhipment of cargo, and in particular crude oil, linked to the introduction of larger commercial vessels. Also, the push to encourage short-sea shipping will no doubt increase coastal traffic dramatically, make shipping lanes even more congested than at present, and therefore greatly increase the risk of casualties much closer to the shoreline.

Private Sector Capability 17. Traditionally, salvage services were provided by the private sector. The Government has indicated that it would like to return to this situation. 18. It is true that, following the gradual introduction of larger vessels as mentioned above (together with the linked increase in transhipment of cargoes) there is a good argument to proceed to a certain modernisation of the MCA’s emergency maritime response procedures and capacity. We are far from convinced, however, that such modernisation should take the form of a complete withdrawal of the UK’s ETV capability, seemingly without the provision of a similar service. 19. Rather, increased vessel size would surely suggest that the current ETVs should be upgraded to ensure the adequacy of any emergency response. In this regard, we would invite the Committee to note that the four ETVs currently deployed around the UK coastline are categorised as “Type 2” (with bollard pull of between 100–200 tonnes). These probably have sufficient towage power to enable them to assist the current largest tankers in service. 20. However, no other tugs around the coast would appear to have that capacity, and especially such capacity that is directly oriented towards providing emergency towage services in adverse weather/sea conditions. Were any of the larger container ships or gas carriers in service today to be disabled for whatever reason and require assistance, the current ETVs would provide an absolutely essential first response. We openly admit that even these specialist tugs would likely have insufficient power to deal completely with such an incident. However, they are the only vessels available in the UK that would be able to have any real impact during the period following disablement and preceding any potential catastrophe. The impact would possibly be limited to preventing the disabled vessel from drifting too rapidly (rather than preventing the drift altogether), but they could well buy sufficient time for further assistance to arrive. 21. It is simply unrealistic to suggest that the private sector can supply such an essential, specialist service. The running, maintenance and training costs are unavoidably high. Any potential remuneration is likely to be very low, especially considering that major casualties are irregular and, thankfully, infrequent. This issue is not new and was recognised by Lord Donaldson back in 1994. Private sector solutions are now even more likely to prove completely unsatisfactory. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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International Considerations 22. Similar government-funded ETV fleets are in place around the coastlines of a large number of our close neighbours: Spain, France, Holland, Germany and Norway to name but a few of the closest. We would invite the Committee to note in particular that the Norwegian Government is building purpose built ETVs to patrol its coastline. Equally, less than 10 years ago, France invested very heavily in the construction of two state of the art salvage tugs—the Abeilles “BOURBON” and “LIBERTE”. 23. There is therefore considerable stupefaction abroad about the UK’s decision, which greatly undermines the robustness of the Western European ETV network. Considering the successful co-operation that has been developed over time (especially, due to the geographic proximity, with France), it seems to be a significant and unwelcome step backwards in this combined maritime response capability that is likely to undermine international co-operation in this domain for years to come. 24. On an economical level, there is significant competition between the large ports surrounding the English Channel/SW area of the North Sea. Taking into account the huge liabilities for which shipowners and insurers would be responsible in case any casualties were left unattended, a dedicated ETV service provides significant comfort to the industry in general. The proposed removal of ETVs may well discourage commercial shipping activities within the UK in favour of increased activity on the continent. 25. Even on a legal level, the Government’s decision seems unsound. By withdrawing its ETV provision, the UK would be in clear breach of numerous international treaties. For instance articles 98 (Duty to render assistance to ships in distress, including through international co-operation) and 192 et seq of the 1982 UN Convention on the Law of the Sea (environmental provisions). In particular, article 194 requires states to take “all measures” to “prevent, reduce and control pollution” by using “the best practicable means at their disposal and in accordance with their capabilities”. 26. Furthermore, “measures taken pursuant to this Part shall deal with all sources of pollution of the marine environment [and] shall include, inter alia, those designed to minimize to the fullest possible extent: ... (b) pollution from vessels, in particular measures for preventing accidents and dealing with emergencies”. 27. We would also invite the Committee to read the text of the 1992 OSPAR Convention and that of the 1990 OPRC Convention in this regard.

Domestic Law 28. Finally, we would like to raise the issue of the potential illegality of the Government’s decision. We regret that we never received instructions to consider a judicial review of the decision, for we feel that any such challenge would have stood a good chance of success. 29. Some arguments that could have been raised (and in our view) successfully, would have been that the legal rationale to the decision was based purely on irrelevant considerations (such as spending cuts under the current economic recession), or at least without taking account of all of the relevant information available on the subject and that should no doubt have been taken into consideration. 30. We have already shown that pure financial concerns are not really applicable to the provision of an ETV service. The primary purpose of the UK ETV network is to prevent maritime incidents in order to protect the sea environment (pursuant both to national and to international legal requirements). If we refer to the judgments in the cases of R v ILEA Ex parte Westminster City Council [1948] 1 KB 223 and Padfield v Ministry of Agriculture, Fisheries and Food [1968] 1 All ER 694, it is clear that (while the ETV network still remains valid for its purpose, which it clearly does) pure economic pressure should not be a relevant consideration in deciding on its future. 31. In any case, if the Government had referred to any or all of the official reports that it had already commissioned on the subject of ETV provision over the years, it is abundantly clear that it would have been wholly unreasonable to withdraw funding for the ETV fleet. The clear conclusion to every single report that we have seen on the subject of ETVs, makes it clear that the risk-benefit analysis ALWAYS falls in favour of retaining a year-round, specialist ETV fleet. The only suggestions that are made concern the reduction of costs associated with the fleet (eg sharing the financial burden with neighbouring states, and authorising the ETV fleet to conduct parallel activities in exchange for remuneration).

Conclusion For all of the above reasons, we believe that the decision to withdraw ETV funding (and therefore, to all practical purposes, to withdraw the UK ETV fleet), without providing for an alternative emergency response capability, is extremely unwise, seriously flawed and, quite possibly, illegal, being materially driven solely by short-term financial considerations. Should this decision be maintained, the ETV fleet consigned to history, and we suffer the misfortune of a maritime incident of “BRAER”, “ERIKA”, “PRESTIGE” or “SEA EMPRESS” proportions, the national cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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economic costs (not to mention the immediate public reaction), would make the cost of maintaining the UK ETV network pale into insigniﬁcance. We sincerely hope that these observations will have been of interest to the Committee and that our comments will be given due consideration in the decision-making process. If we can be of any further assistance in this matter or if you would like to seek clariﬁcation of any of our comments then please do not hesitate to get in contact. April 2011

Written evidence from Coastguards at MRCC Thames (MCA 141) Introduction This document, submitted by PCS members of Thames Coastguard is intended to propose an alternative conﬁguration of HM Coastguard that is different to the existing arrangements and different to the proposals outlined by the MCA in the recent consultation document.

Maintain 1. Thirteen 24/7 Maritime Rescue Co-ordination Centres (MRCCs). 2. London Coastguard. 3. CNIS/VTS/VTM station at Dover with no SAR responsibility. 4. The number of Sector Managers to remain the same. 5. Local Knowledge.

Reduce 1. The above would require the closure of four current MRCCs. The decision regarding which MRCCs stay open should be made taking into account: (a) the utilisation of existing properties which also house other MCA facilities such as radio masts, Marine Ofﬁces or where the MCA owns freehold; (b) the number of incidents handled by each MRCC per annum; and (c) the requirement to have an appropriate geographical spread of stations. 2. Remove CSM grade. 3. Remove Regional Management and centralise.

Change 1. As above, MRCC Dover to co-ordinate CNIS, VTS, VTM as required with no SAR responsibility. 2. Rescue Co-ordination Centre Manager’s role to encompass District responsibilities and to line manage Sector Managers. Job title to change to reﬂect this.

Watch Keepers London Coastguard 6 Dover 20 13 MRCCs 218 Total 244 Admin 4 248 Staff will be able to cope with peak national demand during the day and at night. This will be achieved by introducing modern stafﬁng rosters including options such as: 1. Flexible working. 2. Annualised hours. 3. Bulk of leave to be on a rota basis with additional ad-hoc days. 4. Watch levels based on an operational risk assessed basis. This will also allow personnel to be released for training and development. Grading and salary of watch keepers to be negotiated by PCS. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Equipment Continue to use the equipment to be rolled out during the current RER programme.

Resilience By keeping 13 MRCCs, this ensures greater 24-hour resilience in the very unlikely event that a disaster should strike more than one site. 1. MRCCs to be linked to both of their flank stations. For example, as each MRCC around the country is linked to both its flank stations, there are always two sites able to assist whichever site becomes disabled (daisy chain communication configuration). 2. London Coastguard “one-way” linked to flanks for London resilience. 3. Resilience for Dover CNIS/VTS/VTM station provided by: (a) Gris Nez Traffic for CNIS duties. (b) Remaining MRCCs for VTS/VTM duties using AIS.

With this configuration stations are able, in an emergency, to support their flank stations. By having each flank linked this means that two stations can take the load from one station’s outage. In the extremely unlikely event that two adjacent MRCCs suffer a concurrent outage, they will both have one of their flank stations each to support them.

After Reorganisation Leisure Sector reforms 1. Introduce legislation to make the MCA a licensing authority in the leisure sector. 2. Generate revenue by the introduction of leisure craft licensing. 3. Improve safety of leisure craft user by insisting on standards of training and equipment. April 2011 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from Andrew J Mahood (MCA 142) The reasons I think that the change to the manning and hours of service to Coastguard Service and MRCC’s is wrong are: I have been in the Coastguard for 20 years now, I served at Stornoway, Forth and now Humber (Bridlington). MRCC Humber is a Maritime Rescue Co-ordination Station. They plan to drop its staff by approx 75% (31 down to 10—28 are watch keepers who man the station 24/7). This will be replaced by a MOC (Maritime Operations Centre—one at Lea on Solent and the second at Aberdeen). We are not Call Takers as the Minister of Transport would have you believe. He is an ex Fireman and is using his experience in this to make that statement. The Watch keeping Coastguards at Humber are Front line and not call takers. We have to come into the service with a maritime and SAR background. Do one years training then are examined at the end of this. We are continually examined throughout our service to make sure we maintain our levels of work. As we progress through our career we have to continuously take promotional courses and maintain these standards. A call taker takes a call and passes it on, we don’t, we have to decide what, where and how the Incident is to be acted out. We remain in charge throughout of the Incident (I am a trained Search Mission Co- ordinator and get examined every ﬁve years to make sure this standard is maintained). We are experienced and highly trained SAR professionals. We are the Front of making life saving decisions. We are one of the cheapest stations to run 24 hours every day: Look at the cost of the ones they have chosen to be MOC’s in comparison TOTAL RUNNING COSTS OF MRCCS 2009–10 MRCC Total Cost (£) Aberdeen 280,311 Belfast 76,004 Stornoway 55,150 Shetland 53,036 Clyde 112,441 Forth 44,622 Falmouth 84,649 Milford 87,380 Swansea 89,771 Holyhead 69,454 Liverpool 63,924 Brixham 112,172 Dover 93,183 Thames 61,039 Solent 86,718 Humber 50,106 Portland 50,120 Yarmouth 96,806

We cover the two busiest shipping ports in the UK (Tees and Humber). We cover the two highest chemical areas in the UK (Tees and Humber). We attend the COMAH (Control of Major Accident Hazards—eg accidents at a Chemical plant that could mean a release of poisonous gas into the atmosphere, or even Nuclear from a power station) with authorities throughout our area. (Our area is from the Scots Border down to just South of the Humber, out halfway across the North Sea. It will go further down when we take over MRCC Yarmouth’s area, this also includes work done inland eg up the rivers Tyne, Wear, Tees, Humber, Ouse and Trent. Also included will be the Norfolk Broads). We help in searches inland when our resources can be helpful—this includes Bad Weather assistance. (see the Incident at Whitby on the North York moors last December where 400 cars were trapped). We attend local Resilience, Flood, Control, Communications and other Civil Contingency meetings and exercises with the following Counties: Northumberland. Sunderland. Cleveland. North Yorkshire. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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West Yorkshire. South Yorkshire. Lincolnshire. We also hold the Accident plans for those areas. To reduce the MRCC’s to two major ones open 24 hours would mean they would have to hold many thousand of these plans to cover the total UK (Remember if one of the MOC’s had to close due to some unseen happening the other would be expected to hold the same amount of documentation as well as local knowledge of its area). We also deal with Police and the other Rescue services for these areas as well. We deal with over 140 coastal rescue units in the Humber’s patch, one of the highest in the UK. We are one of the busiest Stations in the UK: how many incidents did the Coastguard respond to in the years of 2009 and 2010: 2009 2010 Aberdeen 1,082 994 Belfast 572 647 Brixham 1,324 1,355 Clyde 1,491 1,395 Dover 968 811 Falmouth 2,380 2,275 Forth 508 532 Holyhead 987 857 Liverpool 1,295 1,203 London 741 945 Milford haven 770 784 Portland 1,447 1,319 Shetland 342 392 Solent 2,376 2,310 Stornoway 442 418 Swansea 1,836 1,766 Thames 1,304 1,217 Yarmouth 1,008 975 Humber 1,574 1,581

If these figures are broken down further you will see that some of them from some of the stations actually include Exercises they carryout and put as Incidents in the Coastguard Vision/Boss system. You also cannot predict incidents no matter what trends show from Statistics. NB: MRCC Humber pairs with Yarmouth so we already have Local Knowledge of that area. When Yarmouth closes within the next year as planned then our figures will start to include their Incidents therefore putting our Incidents to nearly 3,000 per year. Incidents are increasing in numbers yearly. We also share some of the duties (NAVTEX) carried out by the MRCC Falmouth and do it on a week about with them. When Falmouth suffered a Lightening Strike and was out of service for several weeks MRCC Humber carried out this service 24/7 during that period. Humber has many highly populated areas in its area and this causes and increase of Incidents to persons. We have assisted in serious inland flooding for over six years throughout our area. We not only have the in- depth Local Knowledge—which is needed straight away and the delay in having to contact a third party could well be fatal or environmentally catastrophic—is not acceptable. Local knowledge people say is important, and now they say they can get that from a computer, a local Coast Guard Rescue Officer or Lifeboat crew man—well I say this causes a delay which in life saving is not permissible if you want to save a life, speed and time is important. I also believe real local knowledge is really what we call situation awareness, as I know my area I know what is available, what is happening now and what can happen, not to mention my experience of working this area for a long time—a computer does not have that, this is in the minds of Science Fiction Readers, not Coastguards. We will have already dealt with this type of Incident several times. We have also dealt with Incidents where Poisonous Gas Clouds have released from industrial accidents and we have closed rivers for ship traffic (including ferries carrying 1,600 passengers). cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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We conduct Safety Events throughout our area so would not be able to release full time staff to organise/ manage and attend at these. We work well with the additional resources that in our area, this includes the Sea Safety groups, how can this continue when the new MOC will be three hundred miles away? We are an Insurance Policy to save peoples lives by being instantly there with the knowledge of our areas to start SAR straight away 24/7. This will be stopped under the new set up. I believe in resilience, that is why I attend meetings with other Councils and their emergency services as said earlier. We should have our own resilience by having main MRCC’s, two on the South Coast Solent and Falmouth), two on the English West Coast (Liverpool and Swansea) and one in Belfast. For Scotland we should have Clyde, Stornoway and Aberdeen. On the English East coast Humber should share that with Dover (which will remain open for the CNIS—It only has slight SAR incidents and could cover up to the Thames). These stations can be linked via the system of Data links we already use through BT. We can then shift links as required in Emergencies or an overload of work, and as some will close to one another we could quickly and temporarily move staff. They should also be 24 hour stations. We can increase our SAR Duties by also taking over inland areas such as the Highlands and the Moors etc, we already have the co-ordination skills needed in this. I do think we should take over Vessel Trafﬁc Management for vessels transiting round the UK coast. We also need a more hands on management staff and board who have come from a SAR Co-ordination background, these must also be leaders and not just Managers. This is the age of the mobile phone, years back if anybody seen an Incident they had to run to a BT Call box and dial 999, nowadays people have mobile phones and the thrill of dialling 999 prompts them. The result is now I can get multiple calls from people about the same incident and if they are not questioned correctly then mistakes, possibly fatal, can be made by the MRCC Staff. April 2011

Written evidence from Kevin Rogers (MCA 144) Notes: Coastguard Modernisation Proposals These brief notes relate to the MCA document “Protecting our Seas and Shores in the 21st Century— Consultation on proposals for modernising the Coastguard 2010”. To put this submission into context, my credentials are as follows: Watch Assistant, Watch Officer and Watch Manager for six years at MRCC Milford Haven before leaving in August 2010; member of Dale Coastguard Rescue Team since 2002; IT Consultant for many years; recreational sailor and, for good measure, son of a “traditional” Coastguard who gave 20 years service. Firstly, it is important to note that the Coastguard is an emergency service like Police, Fire and Ambulance not an agency like Highways—people’s lives depend on prompt and effective actions by its staff. Amalgamation some time ago with the MSA (Maritime Safety Agency) to create the MCA has led to it being treated as a “poor relation” for many years, especially since, by its very nature, it is not a revenue generating operation. There is a definite need to modernise the Coastguard but this requires investment in new technology and revised working practices, not a complete decimation of a tried and tested organisation. To many, the MCA proposals appear more like an ego-driven vanity project rather than a rational attempt at making it better able to perform its core function—saving lives. Despite claims to the contrary, those responsible for the plan do not appear to have recent operational experience using the current array of equipment. Additionally, it seems that there was little, if any, involvement of operational staff in MRCCs to provide better insight into current operational difficulties and possible ways to improve the service in the future.

Commercial versus Recreational — The proposals talk about new functions and systems such as VTS, AIS, LRIT and CERS, all of which relate to commercial shipping. Scant regard seems to have been given to the needs of the recreational sector which accounts for around 70% of all incidents. This would appear to show a lack of focus on the real “customer base” of the Coastguard service and this is the one which the new structure is least able to serve. — Commercial vessels are well regulated, carry a prescribed minimum ﬁt of communication equipment and are generally crewed by competent professional mariners—they can be tracked/ monitored from well out to sea and can be expected to respond in standard ways in emergency situations. On the other hand, recreational boaters, coast path walkers and beach users may have little knowledge of their environment and be unaware of likely dangers—they cannot be easily monitored, have variable means of communication and may react in unpredictable ways when faced with danger. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Local Knowledge — The proposals indicate a heavy reliance on the “local knowledge” inherent in Coastguard Rescue Teams and RNLI crew. Whilst the existence of such excellent knowledge is undeniable it is wrong to suggest that it can replace the, perhaps less intimately detailed, knowledge possessed by staff in MRCCs. When an emergency call arrives in an Operations Room, it is the staff on watch at that time who need to have enough familiarity with their area to determine the location well enough to task the most appropriate resource(s) to assist or effect a rescue. Any delay in determining the location can have serious consequences for those in difficulty–on land we talk about the “golden hour”, at sea or on the coast this can be reduced to the “golden few minutes” since this is sometimes all that’s available before communications fail or a vessel founders. — Another aspect of local knowledge that appears to have been dismissed as unimportant is the issue of non-English place names, dialects and unofficial nicknames. Both Wales and Scotland have their own languages and there are regions of England and Northern Ireland which have strong dialects. MRCCs staffed by people who live in the community they serve or, as is often the case, were born in the area will always be better able to decipher place names—they will be familiar with the pronunciation of names by local people and aware of the usual “anglicised” variations given by visitors to the area. In addition, locally based staff will know the unofficial names often given to beaches, coves, points, inlets, etc. — In many areas, Operations Room staff are also members of local SAR providers—in the case of MRCC Milford Haven, 25% are either RNLI crew or Coastguard Rescue Team members. Not only does greatly enhance the local knowledge available in the Operations Room, it also promotes excellent working relationships with the SAR partners because of the obvious empathy demonstrated by the staff.

Resilience — The terms “resilient” or “resilience” occur 18 times in the MCA proposals which describe changing from nine pairs of stations to just one pair plus a handful of “day” stations. There is much talk of this arrangement being “more resilient” than the existing system but it’s difficult to see how putting all one’s eggs in two baskets instead of 18 could achieve this. Whilst the current system does have its deficiencies, when one station suffers a complete failure only its section of the coast is affected—important radio sites in that area can be manned by Coastguard Rescue Service teams and telephone calls diverted; if the Southampton MOC fails it seems that only VHF DSC antennae will be switched to Aberdeen, leaving vast tracts of England and Wales without voice RT capability on channel 16 with a consequent risk of distress calls going unheard. — The essential problem with the current system is that all lines from aerial sites are routed to the MRCC that controls them. The termination equipment shares the same power supplies and MCA- wide networking as the MRCC’s operations room. In the event of a catastrophic failure that renders the MRCC out of action, the aerials cannot be made available to a paired or flank station. An obvious improvement would be to route connections from aerial sites to at least two MRCCs or data centres—in the event of an MRCC failure, the aerials are still available to its pair or a flank station. This would provide excellent resilience.

Technology — The MCA proposals state that the new MOCs will be “Equipped with the latest technology to integrate data allowing faster and better decision making”. However, during the series of public meetings organised by the MCA it was revealed that there will be no new technology introduced, just “refreshed” versions of existing software and systems.

Vision — Vision is the Coastguard service’s Incident Management system and was introduced in 2004. It has its origins in systems supplied to the Fire&Rescue and Ambulance services—in fact it is only relatively recently that the “number of pumps” box was removed from the Coastguard version; not exactly a great indicator of a desire to invest in the “latest technology”. — Apart from a simple “gazetteer”, Vision does not currently possess a “database” that would assist in identifying a location from garbled information given in a 999 emergency call. It is difﬁcult to see how it could ﬁll the gap in local knowledge of a remote MOC operator compared to one in a local MRCC. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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VHF DF — One of the most useful tools for identifying the location of a VHF radio caller is the DF (Direction Finding) capability ﬁtted at some aerial sites. Provision of this feature has been limited at best but is now being removed completely, apparently for reasons of cost. This is a great loss and demonstrates a lack of understanding of the need to quickly identify the position of a distress caller—as stated previously, the initial moments of an incident are the critical ones. You cannot task a resource to effect a rescue unless you have a good idea of the casualty’s position.

MOC Structure — The proposals give an indication of the number of operators at a MOC but not a precise description of their roles, just a generic one. During the rounds of public meetings arranged for each MRCC, MCA staff revealed the notion of “geographic cells” within a MOC to deal with a given section of the coast. This, it seems, was in response to frequent suggestions from the public, Coastguard officers, RNLI crew and Coastguard Rescue Service volunteers that local knowledge derived from dealing with an area of coast was important and would be lost in the new structure. It appears that the MCA are “making it up as they go” and do not themselves have a clear idea of how the proposed system would operate. — At present, any watch at an MRCC will be led by an officer with an SMC (Search & Rescue Mission Coordinator) qualification attained after gruelling training and rigorous assessment. This person is responsible for assessing an incident, determining which resource(s) to task and coordinating all aspects of the incident as it progresses. From the little information presented in the MCA proposals, the future system would see all 999 and distress calls being handled initially at a MOC and, during the day, being handed on to an appropriate sub-centre to coordinate. It is difficult to see how this could produce an effectively prosecuted incident: Where is the SMC? What happens when subsequent 999 calls relating to the same incident are received at the MOC and have to be off-loaded to the sub-centre? How will VHF aerial allocation be managed? None of this is presented in the proposals.

Risk Assessment — The Transport Select Committee will be well aware that the MCA did not provide a risk assessment to accompany their proposals, only doing so after it was pointed out to them that it was required. This does seem to hint at a somewhat “amateurish” attitude to proposals which are likely to affect the safety of many people and the jobs of around half of the existing staff. — When it was eventually produced, the risk assessment also demonstrated a lack of clarity and some obvious errors, perhaps as a result of being hurriedly put together rather than already being in existence as was suggested. The very ﬁrst row of the risk matrix contains an error—the “impact” of a mission failure changes from 4 in the current system to 3 in the new one, painting the new system in an even better light. This type of error is unforgivable when the stakes are so high. — The risk assessment also appears ﬂawed. Without rational explanation, the “impact” of SAR Coordination “mission failure” varies from 3 to 5—one would imagine that “mission failure” in a SAR operation would always command the highest impact. Strangely, for such a failure on the part of the Coastguard Rescue Service suffers a consistently higher “impact” score. It is hard to give this assessment much credence.

VHF Channel 16 — It has been revealed that the VHF channel 16 listening watch at the MOCs will be via a loudspeaker. For some years the provision of this watch at MRCCs has been designated as a speaker watch with the use of headset at the discretion of the Watch Manager. Throughout this period, a headset watch by a dedicated operator has been the standard operating practice around all MRCCs. Why should this be? It’s simple, there is a greatly increased risk of a faint VHF distress call being missed using loudspeaker compared to headset—Watch Managers want to provide the best possible service. — The average number of aerials listened to by a channel 16 operator is 8. The MCA have not indicated how many aerials will be fed to a single loudspeaker at a MOC but it is likely to create a cacophony of sound and make the chance of a distress call being missed high.

Summary The MCA proposals appear to focus on commercial vessels and their issues whilst ignoring recreational maritime and coast users who are the main source of incidents—the latter group will be poorly served by the proposed system. Local knowledge in the ﬁrst moments of an incident is of vital importance—a remote operator relying on an, as yet undeﬁned, computer system or needing to make a telephone call to a Coastguard Rescue Service cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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volunteer or RNLI crew member cannot provide the same level of response as a local operator who has excellent knowledge of his/her area. The new system is claimed to be more resilient but simply mirrors the existing paired station arrangement that is deemed to lack resilience. It is hard to give this claim much credence, especially since no detail has been provided. April 2011

Written evidence from Dominic Lonsdale (MCA 145) In a previous session a member of the committee explained that he had worked in a Call Centre and was thus familiar with the type of tasks that HM Coastguard Maritime Rescue Coordination Centre (MRCC) Staff undertook. My assertion is that the actions taken by HM Coastguard MRCC Staff are slightly more complex than he believes. To illustrate my point I would like to compare the difference between a Fire Control Room and a Coastguard MRCC. The Fire Control Room receives a 999 call. The caller gives the location of the fire. The Control Room despatches assets and a Commander to the scene. The Commander On Scene directs the assets. The Control Room function ends as the units are despatched unless the on scene commander requires further assets. HM Coastguard receives notification by many means, directly from the casualty, from a third party that the casualty has spoken to or has observed the casualty, from another agency or by inference following the discovery of an abandoned boat or wreckage. The location of a fire is usually obvious and clearly reported to a Fire Control Room. MRCC staff often have to deduce the location of a maritime or coastal incident from detailed questioning using their knowledge of places that do not have postcodes. Fires are normally visible, take place in small areas, typically in a patch 20 metres by 20 metres or less, do not move and have a fixed address. A maritime incident may involve drifting vessels or survivors in locations that may take an hour or more to reach, by which time the parties concerned have moved significant distances and are not easily visible. It is not enough to allocate a unit and tell it to go to a certain place. A search plan must be drawn up in order to find the casualty. The area to be searched may be many square miles and the plan may assume a search duration of several hours. Once the casualty is found further action may be required to remove the persons to a place of safety and plans made for their reception, possibly at a hospital. Arrangements must be made with the Ambulance Service and hospitals as the casualties reach land. Detailed liaison may be needed with other agencies such as Borders and Immigration if the casualties are not UK citizens. All of which is very different to directing an RAC repair van to a stationary vehicle on a length of road and leaving him to sort it out when he finds the broken car. In the last 48 hours I have worked a number of incidents but I will draw your attention to only two quite routine events and explain them very briefly in order to try to explain the breadth of our workload. A diver made a rapid ascent. The dive boat skipper requested medical advice for his casualty which we provided by direct communication from a specialist centre. A helicopter was tasked to lift the diver. A Coastguard Team was tasked to clear the landing site. An ambulance was tasked to transport the diver either to a re-compression chamber (which we had briefed and arranged) or to the hospital Intensive Care Unit according to the opinion of the doctor (which we had arranged) at the helicopter landing site. Meanwhile the dive boat had preceded at best speed to facilitate the transfer from boat to helicopter leaving other divers behind as they surfaced. A problem we solved. A suicidal male had left a note indicating his intentions. Analysis of his background, history and employment by the MRCC staff, using detailed psychological profiles, in consultation with the police, suggested he might have killed himself or be planning to do so in a very inaccessible area of the coast. At the request of the police, two Coastguard Rescue Teams were deployed, a helicopter was used for searching specific areas identified by the MRCC staff and an inshore lifeboat was also tasked for searching the shoreline. Again the MRCC staff developed detailed search plans using analysis of the ground and the likely behaviour of the missing person. They are not the actions of call centre staff but rather coordinators who manage the complete incident and take responsibility for its management right to the conclusion. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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I hope this has helped you to understand a little more about what we do. April 2011

Written evidence from Save Milford Haven Coastguard Campaign (MCA 146)

Introduction

1. Save Milford Haven Coastguard Campaign was formed to raise awareness of the Maritime & Coastguard Agency (MCA) Consultation on proposals for modernising the Coastguard 2010—Protecting our Seas and Shores in the 21st Century.

2. The Campaign Group is formed of Concerned Members of the Public, Local Businessmen & Local Councillors, A Regional Welsh Assembly Member, a serving Coastguard and ex-Coastguard Operations Room staff, & Serving and ex-Coastguard Volunteers.

3. We do not intend to offer Alternative Proposals which would result in the closure of any MRCC, but will attempt to address the questions within the Consultation.

4. In January 2011, a paper and online petition was set up opposing the MCA and Government Proposals to close MRCC Milford Haven. To date, the combined total of these two Petitions is in the region of 18,000 signatures. We intend to submit this petition to Downing Street on 10 May 2011.

5. Wales First Minister Mr Carwyn Jones AM has signed the petition, along with many other Welsh Assembly Members. Additionally, Sir Tom Jones OBE has also signed the petition, along with Rosie Swale- Pope MBE, Adventurer and Round the World Yachtswoman.

6. The MCA Proposals have met with united Cross Party opposition at the Welsh Assembly.

7. The Local Authorities of Pembrokeshire, Carmarthenshire and Ceredigion have voted in opposition to the MCA Proposals, unanimously in Pembrokeshire and Carmarthenshire.

8. Pembrokeshire Coast National Park opposes the closure of MRCC Milford Haven.

9. At the MCA Public Meeting held for Milford Haven, the Public were left unconvinced by a very poor presentation from the MCA and which resulted in a unanimous public vote of no conﬁdence in the proposals.

10. The Save Milford Haven Coastguard Campaign has held two successful support Rallies in Milford Haven.

11. The ﬁrst Rally was held in February on the 15th Anniversary of the Sea Empress Disaster. It also coincided with the visit of Sir Alan Massey to MRCC Milford Haven. At this event, Welsh Assembly Members from three parties spoke in opposition to the Proposals.

12. The keynote speaker at the second Rally was Jane Davidson AM, Welsh Government Environment Minister, speaking in opposition to the proposals.

13. At the second Rally, the Campaign was strongly supported by Pembrokeshire Conservative MP’s Stephen Crabb & Simon Hart. Additionally, Anglesey Labour MP Albert Owen & Carmarthenshire West Plaid Cymru MP Jonathan Edwards, all spoke in support of retaining MRCC Milford Haven. Other Welsh Assembly Members speaking that day were Joyce Watson (Lab), Nerys Evans (Plaid Cymru) and Angela Burns (Con).

14. Save Milford Haven Coastguard Campaign submitted a response to the Transport Select Committee on 26 March 2011.

15. Save Milford Haven Coastguard Campaign has been invited to give Oral Evidence to the Transport Select Committee on 24 May 2011. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Milford Haven Port 1. Milford Haven is now the third largest port in the UK and is one of the largest oil and gas ports in northern Europe. A large concentration of petrochemical and liquid natural gas (LNG) industries have developed along the Milford Haven Waterway with two LNG Terminals, two Oil Refineries, and a Gas Power Station due to commence operation in 2012 It is also the location of the largest petroleum tank farm in the United Kingdom. 2. All of these energy installations are in very close proximity to one another on both sides of the Haven. 3. In 2010, the Port handled over 65 million gross tonnes of shipping, which amounted to nearly 43 million tonnes of cargo, and with 25% of the UK petrol & diesel requirements, and 30% of the UK gas requirements now handled at the Port, Milford Haven is now considered to be the “Energy Hub” of the United Kingdom. 4. Milford Haven is developing as a Cruise Ship destination, and International tourism has also increased, with the arrival of transatlantic liners. In 2011 alone, there are seven planned Cruise Ship visits. 5. Pembrokeshire has three major ferry routes to Ireland, carrying freight and thousands of passengers each year. Irish Ferries has recently secured a 10 year contract for the Pembroke to Rosslare Ferry Route. 6. There is still a small commercial fishing fleet operating out of Milford Haven, and a large number of foreign fishing vessels also use the port to land or to shelter in adverse weather. 7. In addition to the large volume of heavy Commercial Shipping, Milford Haven is also host to a dense concentration of Non-Regulated Pleasure Craft (NRPC) and recreational coastal users. 8. There are two marinas within the Haven alone; a £5 million investment has recently been announced for Milford Haven Marina. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Pembrokeshire 1. Pembrokeshire is a Maritime County, bordered by the sea on three sides. It has a population of approximately 118,000 people and attracts in the region of 4 million visitors a year. 2. It is one of three National Parks in Wales, and it is the UK’s only coastal National Park known as the Pembrokeshire Coast National Park (PCNP). 3. It includes a 186-mile walking trail known as the Pembrokeshire Coast Path. 4. Pembrokeshire relies heavily on tourism and leads the way in Coastal Tourism in Wales. It is able to boast 13 Blue Flag beaches, 13 Green Coast Awards, and 33 Seaside Awards. 5. Pembrokeshire alone is the location of some 33 Sites of Special Scientiﬁc Interest (SSSI’s). Additionally Skomer Island itself is a: — National Nature Reserve (NNR); — Special Protection Area (SPA); and cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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— Geological Conservation Review Site (GCR). 6. The waters around Skomer Island form part of the Pembrokeshire Islands Special Area of Conservation (SAC) and the Skomer Marine Nature Reserve (MNR).

7. In addition to the established gas and oil industries in Milford Haven, Pembrokeshire expects to see signiﬁcant growth in Offshore Renewable Energy Installations (OREI’s). 8. More recently, Energy and Climate Change Secretary Chris Huhne has approved plans to undertake construction work on a new facility in Ramsey Sound off Pembrokeshire which will generate enough power for 10,000 homes. Mr Huhne stated: “The UK’s great marine heritage and our engineering genius make the potential for wave and tidal energy here vast.” 9. With the expected development and proliferation of OREI’s, in the future Pembrokeshire will also be able to consider itself the “Aberdeen of Renewables”. 10. Pembrokeshire has experienced a considerable amount of notable maritime disasters and high proﬁle Search & Rescue incidents. Examples are: — 1978—”Christos Bitas”—4,000 tonne Oil Spill. — 1988—”MFV Inspire”—Sunk (Night). — 1996—”Sea Empress” Disaster—73,000 tonne Oil Spill (Night). — 1997—French Fishing Vessel “Toul An Trez” sunk on Christmas Eve (Night). — 1998—French Yachting Legend Eric Tabarly lost overboard (Night). — 1999—”Blackfriars” (1,500 Tonne Tanker) run aground on Christmas Eve (Night). — 2007—”Jack Up Barge” collapsed in Milford Haven. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Ceredigion 1. Ceredigion has a coastline in the region of 60 miles and is known as the Ceredigion Heritage Coast. Along this runs the Ceredigion Coast Path. 2. The Welsh Assembly Minister for the Environment Jane Davidson AM recently opened a link between the two Coast Paths of Pembrokeshire and Ceredigion producing a continuous 250 mile Coastal Trail. 3. Four sections of the Ceredigion Coastline are designated as Heritage Coast whilst two areas within Cardigan Bay are Marine Special Areas of Conservation (SAC) 4. The Ceredigion Coast is also a popular tourist destination. Recent years have shown an increase in coastal tourism, with a large number of passenger vessels operating off the West Coast during the season, particularly for whale and dolphin watching in Cardigan Bay.

Local Knowledge 1. The Consultation Document states that “Managing an incident at sea is a considerable responsibility and requires substantial experience and knowledge, including an understanding of tides and weather, radio communications protocols, the theory and practice of search planning, an ability to assess risks, and decision- making skill. Over time Coastguards in Coordination Centres study for and acquire specialist, professional qualifications covering Search Planning, Radio Communications and how to act in the role of Search Mission Coordinator”. The statement failed to include a number of points: I. Managing an incident on the Coast is also a considerable responsibility which requires substantial experience and knowledge—Local Knowledge in particular! Over time Coastguards in Coordination Centres acquire a significant amount of local knowledge and local expertise and it is recognised that this knowledge is a fundamental tool in the armouries of an SMC. II. The statement also fails to mention that Coastguards are required under MCA Regulations to undertake an examination on Local Knowledge once every two years. 2. Coastguard Coordination Staff throughout the United Kingdom develop their intimate and vital local knowledge & relationships over many years. Staff in Milford Haven and Swansea, are required to undertake a Local Knowledge examination once a year. This Local Knowledge should never be undervalued. In practice it can be divided into three elements; Location Awareness, Situational Awareness, and Operational Relationships. I. Location Awareness enables a Search & Rescue Mission Coordinator (SMC) to immediately identify an incident location & task the appropriate SAR resource, when somebody finds themselves in Grave & Imminent Danger. It allows them to assess and plan a SAR Mission quickly and effectively. Additionally, it allows them to be aware of and assess any associated dangers that may exist during the incident. Both the Consultation Document and MCA panel members at public meetings have indicated the intention to rely on the CRS and RNLI to compensate for a reduction in this aspect of local knowledge but without stating that there would be an obvious delay in obtaining such information. It has also been suggested that computer systems at MOCs will assist in this area but no indication of the precise nature these systems other than to say they will be “enhanced versions” of the current incident management software which has very little functionality of this type. II. Situational Awareness enables an SMC to maintain a “Surface Picture” or “Maritime Domain Awareness” of their particular Search & Rescue Region (SRR). In the event of being alerted to a distress and emergency situation, an SMC is often able to identify a “Non-Declared Resource” and task them to assist when necessary. A ‘Non-Declared Resource’ is something other than RNLI cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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or Coastguard. Pleasure craft, Pilot Vessels, Water Ranger, MOD Ranges Safety Vessels & Fishing Vessels could all be considered “Non-Declared Resources”. III. Operational Relationships are established over time between SAR providers and their controlling Coordination Centre. It is widely considered that an element of “local knowledge” is the strong and valued relationships plus mutual respect that Coastguard Operations Room Staff develop with Local SAR Stakeholders, be they Coastguard Rescue Volunteers or RNLI Crew etc. This is something that Volunteers consider to be important, particularly so during SAR (Search & Rescue) Operations. 3. Coastguard Coordination Staff also build up strong relationships with other Agencies such as UK Border Agency & Customs, Police and Fire & Rescue Marine units, Port Authorities, Ferry Operators, and Clubs & Organisations etc. The importance of these relationships should not be undervalued or underestimated. 4. Whilst recognising that Coastguards of today are not “perched on cliff tops with binoculars”, it is particularly true that MRCC Milford Haven is able to maintain an effective “Maritime Domain Awareness” over a particularly busy waterway. As a result many incidents have been successfully resolved off the Pembrokeshire coast by utilising a “Non-Declared Resource”. 5. Many MRCC Staff are also SAR volunteers, be it Coastguard Rescue Service (CRS), RNLI or Independent SAR Providers, and this enhances the local knowledge held at an MRCC even further. At MRCC Milford Haven, 25% of Staff are SAR Volunteers. 6. At the Transport Select Committee meeting the MCA’s Director of Maritime Services stated that in the future Coastguards would only be required to “have a degree of coastal knowledge”. However, at the Public Meeting at Milford Haven MCA representatives stated that Coastguards in the MOCs would operate in “geographical cells” and that “the same level of local knowledge” would be maintained as with the current system.

Security 1. With the increased status of Milford Haven as the “Energy Capital of the UK” comes an increased security risk. This risk has been identified by the Welsh Affairs Select Committee in their Fifteenth Report,28 which identified the importance of Milford Haven to the whole of the UK. Subsequently additional funding was provided to Dyfed Powys Police to provide a dedicated Armed Response Team for the Port. 2. The Report recognised that the threat to maritime infrastructure has been raised and addressed by the UK Government’s updated National Security Strategy. 3. It also states that to ensure Welsh ports are secure “depends on number of different aspects. These include: dedicated police and border agency staff; intelligence-sharing on the threat facing ports; co-operation from stakeholders such as the Coastguard, and the local community”. 4. The Report goes on to mention “the important role that the ports communities and stakeholders play in assisting with the gathering of information and intelligence needed to assess security risks. The role of Maritime and Coastguard Agency was in particular deemed to be significant in alerting the authorities to unusual activities along the coast.” 5. Milford Haven Coastguard is a partner in “Coastwatch Wales”. This is an initiative designed to enhance the security of the Welsh coast line by identifying both vessels and individuals engaged in suspicious maritime and coastal based activity. Such activity could be linked to smuggling, organised crime or terrorist activity. 6. Coastwatch Wales is an amalgamation of specialist officers and agencies including Customs, Immigration, Police, Coastguard and the Royal Navy. Its intention is to disrupt those engaged in criminal activity through effective communication with the maritime and coastal community and continue to make the coastline and waterways of Wales a safe environment for all to enjoy. 7. Evidence of this cooperation can be found in the “Closer Working in West Wales” Document. This is an HM Customs initiative to improve communication, understanding and liaison between West Wales Maritime Agencies and Communities. 8. MRCC Milford Haven offers an overt and strategic security presence overlooking the Port of Milford Haven, at least to the level of “Deterrent”. 9. There is the potential to increase the level of Port Security and adopt a “pilot scheme” of closer inter Agency co-operation if Dyfed Powys Police Marine Unit were to co-locate at MRCC Milford Haven. 10. Dyfed Powys Police Marine Unit currently operate within the Milford Haven Waterway. 11. If sufficient space exists within MRCC Milford Haven to accommodate Dyfed Powys Police Marine Unit, it could be co-located and offer the following benefits: — Reduce costs for Dyfed-Powys Police & Home Office. 28 Welsh Affairs Committee—Fifteenth Report. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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— Strategically relocate Marine Unit Vessels to the centre of the Haven. — Provide instant access to AIS data for Vessels of Interest. — Availability for secondary SAR operations within Milford Haven. — Provide enhanced security for MRCC Milford Haven. — Provide security for Marine unit equipment. — Improved relations and co-operation between HMCG and Dyfed Powys Police. 12. Consideration should also be given to developing inter Agency co-operation with UK Border Agency (UKBA). 13. The UKBA who are currently located in Pembroke Dock could also co-locate at MRCC Milford Haven, which would also generate additional cost savings and considerable benefits for Government: — Further enhance the overall security profile at Milford Haven, commensurate with the importance of the Port to the UK. — Reduce costs for UK Border Agency & Home Office. — Improved relations and co-operation between HMCG and UK Border Agency. — Increased profile for Coastwatch Wales.

VHF Channel 16 1. Although the MCA has not declared a “dedicated VHF Channel 16 headset watch” since 2005, the majority of MRCCs currently utilise a Coastguard Officer dedicated to the monitoring of VHF Channel 16— the International Distress, Safety & Calling channel. 2. OFCOM figures indicate that, of 50,000 licensed marine radio users, only 60% are licensed with Maritime Mobile Service Identifier numbers (MMSI) for use with DSC. This leaves 20,000 licensed radio users who rely on VHF Ch16 Radiotelephony (RT) as their primary means of distress alerting. These are just the licensed ones—it is likely that there are considerably more equipped with unlicensed VHF sets. There is an estimated 3 million small boat users in the UK. 3. Whilst we recognise it to be “labour intensive”, the provision of a dedicated VHF Ch16 Operator is seen as a particular strength of the current Coastguard service since it affords the many thousands of people who do not possess Digital Selective Calling (DSC), Automatic Identification System (AIS) or an Emergency Positioning Indicator Radio Beacon (EPIRB) the best possible chance in the event of a distress or urgency situation. On the other hand, the MCA decision to remove Direction Finding (DF) equipment from its communications network is considered to be ill conceived and a weakness of the current system. 4. Given that around 75% of Coastguard incidents emanate from the recreational maritime sector, it would be helpful for the MCA to present statistics relating to Distress & Urgency Alerting by DSC against that of VHF Radiotelephony. Additionally, they should offer detailed information relating to the number of MRCCs that still provide a “Dedicated” Channel 16 Operator against those that do not. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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5. VHF Channel 16 on a “Loud Speaker” watch in a busy Maritime Operations Centre will create intolerable noise levels and will undoubtedly increase the risk of a faint distress call being missed. 6. It causes considerable concern to learn that in the event of a failure at one MOC, the VHF Antennae that will be switched to its pair are only those carrying VHF DSC. This will leave a considerable area of the UK’s Coast with no VHF RT coverage and increase the chance of distress calls being missed.

Resilience 1. The current structure of “18 MRCCs grouped in nine pairs” has been described as “not a truly integrated system” and that “each MRCC operates as a Coordination Centre for a defined geographical area”. Given that the MRCCs are only linked in pairs, it is correct to describe the current system as “not truly integrated” and it is reasonable to express concerns regarding its resilience. 2. It is misleading, however, to describe as a weakness that each MRCC maintains SAR Coordination responsibility for a defined geographical area. Any Rescue Coordination Centre, whether Aeronautical (ARCC), Maritime (MRCC) or Joint (JRCC) operates as a Coordination Centres for a defined geographical area. These are normally referred to as Search & Rescue Regions (SRRs). They are an International obligation, not a weakness. 3. The grouping of MRCCs into pairs has allowed the introduction of the Area Operation concept, where one MRCC links to the VHF antennae network of its flank MRCC and, through the use of a shared Incident Management System, can assume overall SAR Coordination responsibility for the SRRs of both MRCC’s. Clearly this strength does offer “Limited Resilience”. It is obviously beneficial also in that it allows for stronger relationships to be developed and closer cooperation between staff at both MRCCs, development of the Local Knowledge required maintaining an effective SAR response for the entire Area, the harmonisation of work practices and procedures and close liaison during Operational Exercises. 4. A significant weakness is stated to be “Limited Resilience”. The Consultation Document describes that “there is no interoperability between pairs, or nationally. So in the event of a problem affecting both Centres in a given pair, it is not possible for radio aerial links and other information sources to be transferred to another Centre to allow the incident to be managed from there”. I. The MCA has produced no evidence of a problem affecting both MRCC’s in a given pair. II. However, using the MCA’s own argument of a problem affecting twoMRCCs at the same time, we believe it is far better to fully network the entire existing MRCC infrastructure, fully interlinking all systems and allowing complete interoperability. III. Only then will Coastguard Officers begin to develop the Local Knowledge required for that of other MRCCs. Only then should the MCA assess whether a reduction in MRCCs is feasible with regard to Local Knowledge requirements for Coastguard Officers who would have to cover significantly larger stretches of coastline. 5. The MCA has offered no information regarding fall-back arrangements in respect of a problem affecting both MOCs. Given the proposed reduction in Operational Coastguard Staff by 243, and staffing level for Sub- Centres of 10, it is difficult to see how there would be sufficient staff in the UK to cope in the event of both MOCs suffering operational failure. 6. It is fair to assume that with only 2 x 24 hour MOC’s, the maritime and coastal emergency response system could be easily put out of action through cyber-attack. 7. In 2004, the MCA experienced such an attack, and this was following no less than 6 Government alerts to a possible security breach. The entire Coastguard network was brought down by The Sasser Worm, a virus created by an 18 year old in his bedroom, resulting in MRCC’s reverting to pen and paper and the skills of their staff in the Operations Rooms.

Maritime Operations Centres (MOC) 1. The Save Milford Haven Coastguard Campaign does not agree that the MOC Concept is the appropriate direction for HM Coastguard Rescue Co-ordination Services in the UK. 2. The proposals state that there will be one MOC in Aberdeen, and one MOC in Southampton or Portsmouth. These are to be the only 24 hour Rescue Centres in the UK. I. All three of these locations are recognised as being among the most expensive parts of the country. II. We believe that very few Coastguard Staff will be able to afford to re-locate to these places, let alone want to. HM Coastguard Staff are an important part of a Coastal Community. They, and their families are very settled in their regions, and it would seem apparent that very few of the existing staff will move to Aberdeen, Southampton, or Portsmouth. The lack of staff willing to move will undoubtedly result in a very serious skills shortage required to operate what will be a very stressful and intense, and more worryingly untested, environment. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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3. Centralising Rescue Coordination Services to two x 24 hour MOC’s will have drastic consequences. I. The lack of essential local knowledge required to coordinate many coastal incidents will undoubtedly cause delays in response times. In the hostile terrains that HM Coastguard has responsibility for; it really is SECONDS that count. II. Those staff willing to move will undoubtedly bring a degree of their own local knowledge, and may be able to cascade an element of that onto an Aberdeen, Southampton or Portsmouth workforce. However, from the outset, the level of local knowledge will be considerably diminished from that held within the current system. III. MRCC Milford Haven has responsibility for an area where both Welsh and English place names are used, there are places with combined Welsh & English names, and uncharted or un-mapped local nick-names for bays or rocks; We feel that the lack of vital local knowledge held at an MOC will be particularly life-threatening; Any delay in understanding an Incident location in an emergency, whether it’s been spoken by a “local” or a tourist attempting to pronounce a place name, Will Cost Lives! 4. Although the MCA state they wish to maintain a presence in the regions and widen the geographical pool for recruitment, future recruitment to the MOC’s will be restrictive and parochial to Aberdeen, Southampton or Portsmouth. 5. Evidence suggests that Centralising of Emergency Coordination Services is the wrong direction. On 20 December 2010, the scrapping of the FiRe RCC Project was announced after ﬁve years at a cost of some £420 million to the taxpayer, largely due to the IT element of the project. I. Prior to the election, The Prime Minister himself is quoted as saying: “One thing we would do to try and stop waste is the Regionalisation of Fire Service, the so-called ‘Fire Control Scheme’; it was going to cost £100 million, it’s now costing £420 million. We will want to stop that in its tracks.” II. We are aware of the Liberal-Democrat opposition to FiRe Control Project with the then Party Spokesperson Julia Goldsworthy quoted as saying, “The Liberal Democrats are opposed to the Government’s plans to centralise Fire Control. This project will mean vital knowledge is lost and this could risk the response time to incidents. The project has already proved to be too expensive and is likely to make the Service less rather than more responsive. WE have called for the project to be stopped and for existing Control Rooms to be upgraded as necessary to ensure the communications beneﬁts sought by Government are delivered by local Fire Brigade Control Rooms, as they will be in Scotland and are in Wales, without the need for Regionalisation.” We are also aware of the Shipping Ministers comments in 2005 with regard to the loss of local knowledge in the event of Fire Control Regionalisation. 6. On 14 March 2011, West Yorkshire Police announced the move from Centralised Control Centre’s and a return to local Control Rooms. I. Chief Inspector Mick Hanks of the Communications Division said: “This is all about local accountability, and improved front line service. Feedback from our communities contacting the force, tells us that they want to know their call will be dealt with by someone who knows and works in their patch, and understands their local issues” II. He also said: “Control room operators will be working alongside operational front line colleagues as part of the same team, rather than remotely from each other. This will enable them to work together more closely, sharing information and local knowledge to help improve the service.” 7. If after a yearlong study, West Yorkshire Police are able to recognise the importance of local knowledge and local control, and how service delivery can be improved, it is disappointing that the MCA seem keen to underplay its importance to the Rescue Co-ordination Service, its contribution to an immediate SAR response, and increasing the chances of a successful outcome to an emergency and distress situation.

Incidents 1. The MCA recognise that “Our Coastline is getting busier” and “Weather conditions are becoming more extreme”. 2. In addition to the significant volume of commercial maritime traffic within this area, there is also a dense concentration of small boat and recreational coastal users, and seasonal holidaymakers, who will frequently call upon the assistance of Milford Haven Coastguard. 3. Additionally, there has been significant increase in Coastal Adventure activities. 4. The Incident statistics in the Consultation Document show that between 2005 and 2010 there was a 24.4% increase in incidents. Therefore, it is not unreasonable to assume that there will be a similar growth rate in incidents between 2010 and 2015. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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5. The Consultation Document addresses the issue of “Loading” as a current significant weakness and identifies that emergency and routine demand varies across its current structure. It states: — 30% of all incidents happen in July and August. — 70% occur between 0900 and 1900. — The busiest Centres handle over five times as many incidents as the quietest. 6. The MCA Proposal is somewhat vague at this point. The diagrams “Typical pattern of demand by month” and “Typical pattern of demand by time” are unclear and offer no detailed information upon which to form a sound decision. 7. Given that it reports that 70% of incidents occur between 0900 and 1900, it is fair to assume that 30% of incidents occur between 1900 and 0900. 8. As previously described, significant incidents have occurred off West Wales during the hours of darkness. 9. The statement that some Centres are five times busier than the quietest is misleading. 10. We do not feel it makes it clear when the comparison is drawn between the busiest Centre at its busiest time against the quietest Centre at its quietest time. 11. A fairer comparison to offer is between the busiest Centre at its busiest time and the quietest Centre at its busiest time. 12. Equally should be shown is the comparison between busiest Centre at its quietest time and the quietest Centre at its quietest time.

MRCC Closures 1. Save Milford Haven Coastguard (SMHCG) Campaign does not support the closure of any MRCC’s. However, we understand the requirement for savings due to the current economic climate, and that no organisation is immune from any cost saving measures. 2. The MCA have made a statement that having only five Sub-Centres “would facilitate contacts between Coastguard Centres and the volunteers of the Coastguard Rescue Service, and contacts with other Search & Rescue partners”. I. It is one thing to make a statement; it is another to describe how it could possibly be achieved. The MCA have not even attempted to. II. Without question, the closure of MRCC’s will mean that the important relationships with local SAR volunteers & partners that have been built up, over many years in some cases will be lost. III. Currently, MRCC’s are able to host regular visits for Coastguard Rescue Officers (CRO). These visits are very important in allowing the CRO to understand the wider search and rescue picture, and to develop relationships with the Operations Room staff. IV. Closure of MRCC’s and centralising services will destroy these relationships, The MCA have not convinced us that the proposed changes to the Coastguard Rescue Service management structure will achieve the same level of mutual respect and confidence between the Volunteers and the Rescue Coordination Centre. V. It has been reported that closure of an MRCC could ultimately result in a number of volunteers leaving the Coastguard Rescue Service. 3. Where the property lease for a particular MRCC is due to expire, we consider that every effort must be made to re-negotiate the respective lease agreements in order for them to continue to operate in situ. If the lease agreements cannot be re-negotiated for those MRCC’s “earmarked” for closure, we believe that alternative premises in the same area must be sought. 4. Equally, if it is a case that some MRCC’s are too costly to run, then Alternative Premises for these should be investigated. These alternative premises could be in the way of: I. Co-location with other Emergency Service Control Centres. II. Local Port Authorities. III. Local Authority Buildings. (This is clearly a model the MCA have adopted with a single operator co-located with Port of London). 5. Alternative premises should then be interlinked and inter-operable with all other MRCC’s. 6. MRCC’s host PR visits to thousands of people each year. These visits are often undertaken by children and play a vital role in an “early learning” accident prevention strategy. Although the prevention of accidents is unquantifiable, we believe these visits do ultimately Save Lives. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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7. The MCA have identiﬁed MRCC Swansea as the one MRCC in Wales to remain open, albeit on a daytime basis only. However, no evidence of any detailed analysis assessing the risks in closing MRCC Milford Haven has been offered. 8. The argument for the siting of Sub-Centres as “located in areas with good communications, with a reasonably large population and with good job markets to facilitate future recruitment” can surely be countered when one of the proposed Sub-Centres is to be located at Shetland or Stornoway. We believe both MRCC Shetland & MRCC Stornoway should remain as 24 hour MRCC’s. 9. The Consultation Document states that “At the heart of our proposals is a move away from regional centres each looking after a geographically limited area”. 10. It goes on to say there is a “desirability of sustaining a regional presence for the regular Coastguard, maintaining strong linkages between the Coastguard Rescue Service and the communities it serves” and it also goes on to talk about “Preserving regional expertise while widening the geographical pool for recruiting future Coastguard Ofﬁcers”. 11. Given that the MCA proposal is to close 10 MRCC’s which are strategically spread throughout the regions of the UK, and a planned reduction of 243 Coastguard Coordination Staff, it is impossible to see how a “regional presence” can be sustained. 12. In Wales alone, with the proposed closure of MRCC Milford Haven & MRCC Holyhead, it is considered that 10 Coastguard Staff based during “daylight hours” at what would be MRSC Swansea, with the best will in the world, will not adequately preserve “regional expertise” of West Wales and North Wales.

Training and Recruitment 1. With regard to “Professional Standards and skills”, the MCA state that “Disparities in loading and the type of incidents experienced in different MRCCs means that individual Coastguard officers can have very different opportunities to practice and develop their skills. As a result it is difficult to sustain common professional standards and skills across the service, or offer the development and promotion opportunities that many Coastguard officers would relish”. 2. The document gives the impression that Coastguards do not maintain common professional standards and skills across the service. 3. Coastguard Coordination Staff are trained to a high standard at a dedicated Training Centre in Dorset, and work to an MCA Competency Based Framework and a Professional Skills for Government Framework. 4. Additionally, it is mandatory that all Operational Staff conduct and record at least 4 hours of Technical Training every four days, and Continual Professional Development is a significant part of Coastguards responsibilities. 5. This Operational Training is often undertaken during quieter shifts or at night. Incident de-briefs are often conducted during a quieter period, the results of which are frequently published nationally in the form of cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Operational Learning Reports (OLR). “Down time” also affords Coastguards the opportunity to conduct the myriad of other administrative work they are required to undertake, and to study of the vast amount of information an Operational Coastguard has to ingest, assimilate, and action. 6. One of the MCA arguments offered as a rationale for choosing between Milford Haven & Swansea for the siting of a “Sub-Centre” appears to have been rather insultingly based on recruitment. 7. Detailed evidence of recruitment within regions should be produced in order to determine the best “future prooﬁng” for HM Coastguard. It is well known that Staff Turnover is higher in areas with larger populations and increased opportunities. 8. A maritime county such as Pembrokeshire, with the British Army Signal Regiment situated nearby at Brawdy Barracks will undoubtedly provide adequate recruitment candidates for the foreseeable future.

Coastguard Rescue Service 1. The MCA Proposals state “the regular Coastguard working in Maritime Operations Centres and sub- centres will draw more heavily on the local knowledge of geography, community and coastal risk provided by the network of local volunteer HM Coastguard Rescue Teams and increased liaison with partner SAR organisations”. 2. The SAR Volunteers are not the people who are answering a 999 or Mayday call. 3. At the outset of any incident Coastguard Officer local knowledge is vital in ensuring the most appropriate SAR asset has been tasked, be it “Declared” or “Non-Declared”. Any delay in this process Will Cost Lives. 4. The Coastguard Rescue Service Volunteers have not been consulted about this increased reliance that will be placed upon them. 5. The local knowledge of the SAR Volunteers is not formally assessed. 6. Many volunteers are employed and in the current economic climate may not be able to offer any further commitments. 7. In some parts of the UK it has been reported that CRO’s may actually resign from the volunteer service if the proposals in their current form are allowed to proceed. It is considered that their safety could be jeopardised as a result of centralisation. 8. The MCA has failed to convince us that the introduction of 25 Coastguard Officers to the management structure of the CRS in an attempt to “deliver a more effective, efficient and resilient service”, will address the most significant problem of the CRS which is availability. 9. Nor has the MCA convinced us that an on call Coastal Safety Officer (CSO), and/or the use of Google Earth (where it’s always sunny and never windy) will be an adequate operational replacement to the current system, for the derivation of local knowledge at the outset of an incident. 10. The MCA are claiming that in the event of an MOC requiring local knowledge assistance, it will be obtained from a CSO or a CRT. What hasn’t been explained is what would be the consequences of one or both of these being unavailable. The obvious answer is that there will be delays in tasking appropriate resources. 11. Given the MCA agenda to close MRCC’s, we are very concerned for the future of the Coastguard Rescue Service, particularly with regard to any plans the MCA may have for the possible reduction in the number of CRT’s in the UK.

Risk Assessments 1. Much has been said of the “compendium” of Risk Assessments and the manner in which they have been offered to the Public. It causes us very serious concern to learn that some elements were hurriedly written after their publication was called for. 2. The MCA appear to have been complicit in the loading of the Risk Assessments in favour of their own proposals. 3. We do not have conﬁdence in the published “compendium” of Risk Assessments. 4. It is clear that none of the risks associated with the closure of MRCC Milford Haven have been considered.

ETV/MIRG 1. Within the Consultation Document we have not been given the opportunity to respond to the MCA with regard to the scrapping of the ETV contract, nor to the removal of funding for the MIRG. 2. On 15 February 1996 the Sea Empress ran aground at the mouth of Milford Haven. Only 2500 tonnes of oil were spilled in the initial grounding. It was during the subsequent salvage operation that another 69,000 tonnes were spilt. The ﬁnal cost to the UK was in the region of £150 million. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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3. In 2006, a report by the WWF; The Sea Empress Disaster 10 years on (An Overview of Shipping Activities in UK Waters) identified that “There are still large areas of water around the UK that are not effectively covered by the large “year round” ETVs—the north-east coastline and adjacent North Sea, and the Irish Sea (including Milford Haven)”. 4. With the installation of two LNG Terminals at Milford Haven, alongside the two existing Oil Refinery Terminals, and the increase in maritime traffic carrying extremely hazardous cargos, we consider that we remain at risk of another maritime disaster, at least equal to that of 1996. 5. The budget for the ETV’s and MIRG should be regarded as a very inexpensive insurance policy for UK Plc. 6. The previously mentioned WWF Report states that there had “been discussions with the Irish government to arrange a bilateral agreement and funding of an ETV to cover the Irish Sea, but little progress has been made. Milford Haven Port Authority is very keen to have the presence of an ETV and has offered to provide a free berth and waive all port dues if one is stationed at Milford Haven.” 7. If it is a question of achieving savings, have options such as this been further investigated? 8. At the Transport Select Committee hearing on 8 February 2011, some concern arose regarding the ETV contract. It has been suggested that re-negotiation of Terms & Conditions of the ETV contract in order that it may generate an income to the MCA would be an appropriate way forward. 9. Mid & West Wales Fire & Rescue Service have an extremely well trained MIRG, and something we consider to be a critical emergency response unit. 10. Given the possible loss of both these Critical Maritime Emergency Response assets, we hope the MCA understand our very grave concerns, particularly for the Port of Milford Haven, the Pembrokeshire Coast National Park & its offshore islands, and the Welsh Coastline.

Conclusions 1. The MCA Modernisation Proposals have failed to convince us that an improved SAR Coordination service will be achieved. 2. We believe that Local Knowledge Saves Lives. However, the MCA has failed to convince us that the same level of Coastguard Local Knowledge will be maintained by two 24-hour MOCs in Aberdeen & Southampton or Portsmouth. We therefore remain unconvinced that HM Coastguard will be able to offer the same level of service delivery it currently achieves and that Lives Will Be Lost as a result. 3. The MCA proposal to move to two 24 hour MOCs with VHF Channel 16 on a “Loud Speaker Watch” has failed to convince us that a similar level of service delivery can be maintained. 4. We are not convinced that the Modernisation proposals have given due consideration to the needs and expectations of recreational small vessels and coastal users. The Consultation Document is heavily weighted towards the Commercial Maritime Industry. 5. We remain unconvinced that the MCA proposals will improve resilience with a move to centralised Search & Rescue Coordination Services with only two 24 hour MOCs based at Aberdeen & Southampton or Portsmouth. 6. The MCA have failed to convince us that the 2 x 24 hour MOC Concept is a workable model for UK Search & Rescue Coordination Services. The Consultation Document does not adequately describe the roles of the Sub-Centres, nor the inter-face between MOC & MRSC. 7. The proposed concept is not proven, and there are no models elsewhere in the World which replicate this approach. 8. The concept has only been practiced via “Table Top” Exercise, during which it failed to replicate the real- time application of the SAR Coordination network and its associated Incident & Routine Work loading. The detailed results of this exercise have not been made public. 9. The current system is a tried, tested, and proven SAR Coordination response system. 10. The published graphs within the MCA Proposals are unclear. However it would appear that the MCA have only offered incident numbers, and no consideration seems to have been given for the severity of an incident and the level of SAR Coordination required. 11. The MCA has stated that “the maritime world has changed, with better communications and navigation aids, new reporting and routeing systems for ships, and smarter ways to monitor, track and vessel trafﬁc.” 12. However, recreational maritime and coastal users make up approximately 75% of HM Coastguard Casualty demographic. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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13. There is a great deal of suspicion felt about The Consultation Document and the “compendium” of Risk Assessments. Without question they are loaded in favour of the MCA Proposals. Alarmingly, the Call Failure Element of the RA was written subsequent to the Transport Select Committee Meeting on 8 February. 14. We have serious concerns regarding the scrapping of the Emergency Towing Vessels (ETV). Subsequent to Lord Donaldson Report and Review, these ETV’s have provided the UK with an insurance policy against another disaster. 15. We are also seriously concerned about the MCA’s withdrawal of funding for the Maritime Incident Response Group (MIRG). Any incident involving an LNG or Oil Carrier, or Irish Passenger Ferry or International Cruise ship could have catastrophic consequences if the removal of these critical Maritime SAR Response Assets is allowed to proceed. 16. It is misleading to continually describe the current system as “some 40 years old”. 17. From 1994 until 1996, the MCA conducted the “Focus for Change” review. The major review resulted in the introduction of Coastguard Watch Assistants, the closure of a number of MRCC’s, and the installation of the digital Integrated Coastguard Communications System (ICCS). In 2003–04 Vision Incident Management System (IMS) was introduced and enabled the introduction of effective Area Operations. 18. The current mandate for HM Coastguard is as follows: HM Coastguard is responsible for the initiation and co-ordination of all civilian maritime Search and Rescue (SAR) within the UK Maritime Search and Rescue Region. This includes the mobilisation, organisation and tasking of adequate resources to respond to persons either in distress at sea, or to persons at risk of injury or death on the cliffs or shoreline of the United Kingdom. 19. The MCA have stated that “The Coastguard is a vital national emergency service” so it is extremely disappointing to see the core function of Her Majesty’s Coastguard has been relegated to 3rd in a list of five roles of “The Coastguard Today” in the Consultation Document. 20. Sadly, the Coastguard MRCC Staff also appear to be losing “Her Majesty’s” prefix, which they are so rightly proud of. 21. The transcript of the MCA Public Meeting held for Milford Haven has not been correctly transcribed. The considerable applause opposing the MCA Proposals has been omitted, and therefore the document does not accurately reflect the outright opposition to the Proposals that was demonstrated that evening. 22. Alarmingly, the MCA has failed to carry out any Risk or Security Impact Assessments specifically relating to the closure of MRCC Milford Haven.

Recommendations 1. The MCA should fully network all MRCC’s in the current structure and investigate altered watch manning/ shift routines between MRCCs to cover “quieter periods”. 2. The CRS must be consulted prior to any further proposals being published in order that they can conﬁrm their availability and willingness to undertake any enhanced role. 3. The MCA recognise the need to appropriately re-numerate its staff for the job they do; Additional responsibilities such as Vessel Trafﬁc Monitoring and altered work practices in the form of increased co- operation with other Agencies would qualify. 4. The MCA Contract for ETV’s should be investigated and re-negotiated for it to afford the Agency appropriate re-numeration. 5. The MCA/HM Coastguard should investigate other options to generate revenue. eg Co-location of Agency Estates, endorsement of Maritime Safety Products. 6. MCA should investigate opportunities for closer working between HM Coastguard and UK Border Agency & Maritime Police. Possibly even co-locating of Agencies and developing a new approach to UK Coastal security. 7. We believe that before any MRCC is proposed for closure, the MCA should conduct a comprehensive study, comparable to those carried out at Strathclyde University in 2004 following the closures of MRCC’s Oban, Pentland and Tyne Tees. Subsequent reports using “Data Envelopment”29 & “Regression Analysis”30 to model the performance of UK Coastguard Centres were published. These reports are based on the development of a performance measurement framework that was considered to be more realistic and complex than the one that was used by the Government at the time. 29 Using regression analysis to model the performance of UK Coastguard centres. 30 Using data envelopment analysis to model the performance of UK coastguard centres. R B van der Meer 1*, J Quigley and J E Storbeck University of Strathclyde, Glasgow, UK; and University of Texas at Brownsville, USA. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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8. Retention of as many current MRCC’s as possible, or the re-location to alternative premises will ensure that HM Coastguard local knowledge & local expertise will remain within the region 9. It will also maintain the wider geographic recruitment pool. It will also continue to afford the Government a strong regional representation for maritime safety and security throughout the UK. 10. We would like an assurance from the MCA that there are no plans for the reduction of CRT’s in the UK. 11. Given the strategic importance of Milford Haven to the United Kingdom, any future MCA Proposal for the Modernising of HM Coastguard MUST include MRCC Milford Haven as a 24 hour Rescue Coordination Centre.

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Written evidence from Dorothy Mackinnon (MCA 147) Why must Stornoway Coastguard Remain open? — Strategic location on the West Coast of Scotland, if MCA plan goes through and Stornoway is closed there will be no West Coast station for Scotland. — This will sever all links with the communities they serve, the volunteer Coastguards that we rely on and other responders under the Civil Contingencies Act. — It is a wholly owned modern, large facility with room to adapt the layout and accommodate an increase in staff numbers to cope with a larger district or enhanced role. — Statistically not only able to recruit people with the necessary backgrounds to work in the Coastguard, but able to retain them. Average staff turnover for last three years is only 4.3% compared to Aberdeen’s 9.7%. — Co-located with a Medium Frequency aerial, Coastguard Rescue Team base, Sector Manager for the Volunteer Coastguard Rescue Service, regional support team and Coastal Safety Manager. — Critical loss of local knowledge—the geography, placenames, culture, topography, personalities and day to day maritime activity. — The Gaelic language—its home is the West coast of Scotland and the Hebrides, it is the predominant language of place names. — Databases, google earth and other GIS systems that MCA are to rely on will not recognise nicknames, colloquial place names, gaelic spelling etc. — This will force unfamiliar operators to rely on third parties. These are mostly volunteers and should they be unavailable will induce a delay into tasking a Rescue Unit. — This will be supplemented by a 24 hour on call ofﬁcer—only 16 extra in the UK! This may mean an increase of only one for the Western Isles and there is no guarantee that the on call ofﬁcer will have any knowledge of the area of the incident. — Radio black spots are everywhere, frequently quoted as spending 10–15 minutes trying to call volunteer Coastguard teams out. There is no increased infrastructure to counter this. — These will result in delays—sometimes much more than Sir Allan’s “handful of minutes” and this time cannot be got back. — People in most danger need a response measured in seconds. Delays will increase the rate of deaths for certain types of incident. April 2011

Written evidence from Highlands & Islands Fire & Rescue Service (MCA 149) 1. Introduction 1.1 Highland and Islands Fire Board welcome the opportunity to make a contribution to the Transport Select Committee inquiry into the arrangements for the Maritime Incident Response Group (MIRG). 1.2 Highland and Islands Fire Board acknowledges that the MCA does not have a statutory responsibility for providing a response for fires or other incidents at sea; that its statutory responsibilities relate to co- ordination of efforts to deal with such incidents. 1.3 The Highland and Islands Fire Board is the Fire Authority for the Highlands and Islands Fire and Rescue Service (HIFRS) which covers the Highland area of Scotland, the Orkney Islands, the Shetland Islands, and The Western Isles. 1.4 HIFRS provides Fire and Rescue services to approximately one sixth of the land mass of the United Kingdom; comprising many communities that are remote from mainland UK and which rely heavily upon the sea not only for their livelihood but also to maintain links with mainland Scotland. 1.5 Since the early 1990’s the Service has maintained an offshore fire fighting capability to respond to vessels on fire that present a life risk. With the formation of the Maritime Incident Response Group the Service has received MCA funding to support this capability. 1.6 HIFRS capability comprises of four teams based in each of the Constituent Authority areas; (Comhairle nan Eilean Siar, Shetland Islands Council, Orkney Islands Council and Highland Council), and are predominantly staffed by retained fire fighters. 1.7 Its reliance on retained fire fighters, coupled with its geography are some of the reasons that HIFRS maintains a higher number of teams and personnel than may otherwise be the case in other MIRG services. 1.8 The cost of maintaining the HIFRS capability is circa £120,000, of which approximately 25% is funded from the MCA budget. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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1.9 The Highland and Islands Fire Board acknowledges the financial strictures which have impacted upon the MCA decision to withdraw funding for MIRG. 1.10 Acknowledging these financial pressures, the Highland and Islands Fire Board is supportive of a changed approach to MIRG provided that such change is founded upon a holistic assessment that considers all contexts of risk, and includes firefighter safety, safe systems of work, the UK geography and finance and that such changes are consulted upon with all appropriate stakeholders.

2. The Benefits of MIRG 2.1 The creation of MIRG has provided significant benefits to our communities; the MCA and broader maritime community and to the fire and rescue sector. 2.2 We consider that for a relatively small investment by the MCA, the United Kingdom has been provided with a 24/7 fire fighting at sea capability for the whole of its coastline. (In the case of HIFRS, a £30,000 per annum investment delivers this capability to more than one-sixth of the UK coastline area). 2.3 The MCA vision “is to be a world-class organisation that is committed to preventing loss of life, continuously improving maritime safety, and protecting the marine environment: Safer Lives, Safer Ships, Cleaner Seas”. 2.4 We consider that MIRG provides the MCA with a cost-effective capability that assists it to achieve this vision. Moreover, MIRG intervention at a ship fire may allow the vessel to remain tenable for the ships crew and mitigate the potential for the vessel running aground and the possibility of pollution consequences. 2.5 Such a scenario will require MCA to discharge its statutory duties in dealing with marine pollution, although we note that there does not appear to have been a detailed cost/benefit analysis taking this scenario into consideration. 2.6 MIRG provides a resilient capability and proffers the ability to standardise equipment, training and operating procedures that were not in place prior to its inception. As a result MIRG has provided the basis for mutual support among fire and rescue services which may be eroded should the MCA funding be withdrawn. 2.7 The Highland and Islands Fire Board considers that collectively the benefits for the MCA, maritime and fire families derive benefits for all of our communities.

3. Civil Contingencies 3.1 Whilst we acknowledge the MCA statutory duty, we do however consider that the MCA has a broader role within the context of the Civil Contingencies Act 2004 and Civil Contingencies Act 2004 (Contingency Planning) (Scotland) Regulations 2005. 3.2 Category 1 responders are required to assess the risk of emergencies occurring and use this to inform contingency planning. We consider that this risk assessment has been conducted and this has been set out in the report commissioned by the MCA.31 3.3 We believe that the outcome of this risk assessment falls within the Civil Contingencies Act Guidance on Emergency Preparedness as a proposed reasonable worst case scenario likely to involve 10 or more fatalities 3.4 As such this is a “signiﬁcant” scenario requiring a response. We do not consider that this burden of response, (ﬁnancial or otherwise), should fall wholly on one agency, but that this burden is shared amongst appropriate responders as is currently the case with the arrangements for MIRG.

4. The Consultation Process 4.1 We acknowledge that the MCA discharged their “contractual” obligations in line with the Memorandum of Understanding32 signed by them and Scottish Fire and Rescue Services in 2006. 4.2 However, as a public authority, we consider that the MCA had a broader responsibility to consult prior to the implementation of such a significant decision given its ramifications for communities and the broader civil contingencies context. Indeed, we note that the MCA is one of the agencies that have signed up to the UK Government Code of Practice.33 4.3 The guide states: “It is important that consultation takes place when the (Government) is ready to put sufficient information into the public domain to enable an effective and informed dialogue on the issues being consulted on.” 31 Review of Requirements of the MCA in Relation to Assisting with Incidents Involving Fire, Chemical Hazards and Industrial Accidents at Sea Part 1—2010 32 Memorandum of Understanding—Framework Agreement between the Maritime & Coastguard Agency and Selected Fire Authorities—2006 33 Code of Practice on Consultation—HM Government—2008 cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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4.4 Whilst the MCA completed its review of MIRG in 2010, we consider that there has been a signiﬁcant consultation gap with regard to the future of MIRG. Indeed, it appears that MIRG is not a feature of the formal MCA consultation process on modernising the MCA initiated in late 2010.34 4.5 As stated previously, we are grateful for the opportunity to provide our perspective to the inquiry but are mindful of the further content of the consultation guide; “there is no point in consulting when everything is already settled.”

5. The MCA Review of MIRG 5.1 We note that the MCA commissioned an extensive review of its role in relation to assisting with incidents involving Fire, Chemical Hazards and Industrial Accidents at Sea. 5.2 Whilst again acknowledging the statutory duties of the MCA, Highland and Islands Fire Board is disappointed that the recommendations regarding the future of MIRG set out in this review have all been set aside and the withdrawal of all MCA funding for MIRG seen as the most efficacious decision. 5.3 As stated previously, we are mindful of the financial pressures facing all public agencies and we are supportive of changes that will assist in alleviating these pressures. However, the issue of finance is only one construct of the change argument. 5.4 Cognisance must be taken of other factors such as risk and cost benefit analyses and once this holistic appraisal has been completed, a detailed, timely process of consultation must be entered in to with all stakeholders.

6. The Removal of the Emergency Towing Vessels 6.1 The issue of the removal of the Emergency Towing Vessels (ETV) is an issue which has been commented upon by other committees and groups from within our individual constituent authorities. 6.2 However, we consider that the issue of the ETV needs also to be considered within the context of MIRG arrangements as they provide the opportunity for an integrated capability to support the delivery of MIRG operations, providing a platform from which to support fire fighting at sea and MIRG response. 6.3 Again we consider that there is an absence of information to form the basis of a robust risk assessment and cost benefit analysis in relation to removal of the ETV versus the potential for accident leading to a pollution scenario and the potential costs that may arise for the MCA to address this. April 2011

Further written evidence from Highlands & Islands Fire & Rescue Board (MCA 149a)

The Highland and Islands Fire Board, which comprises representatives of the Highland Council, Orkney islands Council, Shetland Islands Council and Western Isles Council, is the fire authority for the area covered by the Highlands and Islands Fire and Rescue Service (HIFRS), which is responsible for fire and rescue cover in around one third of the territory of Scotland, including some of the most remote and vulnerable communities in the UK. The waters within our area extend to one sixth of the coastline of the UK and include some of the most sensitive environmental areas and highest weather risks. Any decisions that impact on maritime safety are of acute interest to this authority and, above all, to the communities we represent and seek to protect. Accordingly, at its most recent meeting on 13 May 2011, the Board gave further consideration to its continuing concerns regarding the impact that a reduction in marine safety cover could have for shipping within this area, and for our communities generally. The Board strongly agreed that it should continue to lobby for the provision of marine safety cover to be protected, and that a letter therefore be sent to your Committee to reinforce the written evidence already submitted by the Board, of which I attach a further copy. The timing is particularly apposite, given your visit to Stornoway later this week to take oral evidence, and the opportunity this presents to provide some insight into the circumstances in this part of the country. The Board would hope that at least some of its concerns will be raised by those giving oral evidence to your Committee and that your visit will, as a whole, help your members to recognise and appreciate the particular needs of this area. The Board would want in particular to emphasise the following points: — The Civil Contingencies Act Guidance on Emergency Preparedness provides that significant reasonable worst-case scenarios (involving 10 or more fatalities) require a response. It is entirely foreseeable that a significant incident will occur in HIFRS waters, particularly in storm conditions, which are predicted to become more extreme as a result of global warming. 34 Protecting our Seas and Shores in the 21st Century-Consultation on proposals for modernising the Coastguard 2010 cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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— The Highlands and Islands are remote from other assistance and rely on the ready availability of facilities within the locale, to enable a prompt and effective response. Delays will have consequences for the safety of shipping personnel and for the environment, with clean-up costs likely to be considerably higher if the reaction is slower. — The capacity for the HIFRS Marine Incident Response Group (MIRG) to intervene at maritime fires reduces the risk of a ship running aground, and thus the danger of loss of life or of pollution. The removal of the £30,000 support funding that the Marine and Coastguard agency formerly provided to the HIFRS means that, of necessity, the future provision of this service is now under review. — The MIRG is staffed by retained fire-fighters, who make up the vast majority of HIFRS personnel. A reduction in MIRG provision will not only impact on marine safety, but is also likely to have a direct financial impact on vulnerable communities. This small amount of money provides a very large leverage across the social and economic spectrum. — Climate change predicts that long spells of dry weather are likely to become more frequent. Such conditions recently gave rise to more than 70 wildfires in the Highlands. The consequences included the need to airlift climbers from a mountain top by Coastguard helicopter. Incidents requiring Coastguard response are not always foreseeable; however, it can reasonably be anticipated that, given the growth in public access to the remoter parts of the countryside, these are likely to increase.

Whilst the above comments relate primarily to the impact of a reduction in the role of the HIFRS Marine Incident Response Group, the Board, as a public authority, is concerned at the potential impact of reductions across all aspects of marine safety provision, including the proposed re-structuring of the Marine and Coastguard Agency and the potential removal of towing vessels. It is vital that the risks attached to any dilution of these services are fully assessed, and that full cognisance is taken of the area’s remoteness and changing risk proﬁle, as predicted by climate change. The potential ﬁnancial, environmental and social costs arising from a delayed response to incidents must be fully assessed. The Highland and Islands Fire Board considers it vital that the provision of effective marine safety cover in its area, including that offered by helicopters, be maintained.

The Board would be grateful if the other members of your Committee could be made aware of the Board’s concerns. I trust you will ﬁnd your visit to Stornoway helpful and informative. May 2011

Written evidence from Dr Stephen Bailey (MCA 151)

Regarding the Proposed Re-organisation of the Coastguard Service

I would like to place on record my objection to the proposed closure of a substantial number of coastguard stations and the rationalisation of the service, IN PARTCULAR as it affects HOLYHEAD COASTGUARD.

The arguments regarding the loss of local knowledge if these closures go ahead are well rehearsed and will I hope receive the appropriate attention in your Inquiry.

I believe that these concerns are particularly relevant to the coastline covered by Holyhead, an area with which I am somewhat familiar. The coast of Anglesey is extremely popular for sea-based leisure pursuits. In particular it is rapidly becoming an international centre for sea kayaking, which is my particular area of interest.

It is the nature of the complex coastline and the Welsh place names (often duplicated within a few miles of each other) that gives me concern as to the ability of any emergency service that does not have detailed and intimate local knowledge, to operate an efﬁcient service.

One can only imagine the effectiveness of an operator in Liverpool or Belfast, let alone Aberdeen, when faced with a call from a victim in the water, cold, frightened and maybe unsure of their position (certainly the latitude and longitude) other than in terms of a difﬁcult-to-pronounce local place name. Or imagine a tourist (of which there are many) being faced with the same problem when reporting someone in trouble offshore.

The question of local knowledge is not of course exclusive to the area covered by Holyhead, but I believe that these are particular factors relevant to that area which would make it extremely unwise in my view to close the station.

I hope that these views, along with the many others doubtless making the same point are taken into serious consideration when making your recommendations. April 2011 cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from Tina Rogers (MCA 153) 1. I live in rural West Wales and take part in various coastal activities within the area covered by MRCC Milford Haven. I am also an active sailor frequently venturing offshore. For this reason I am interested in, and extremely concerned about, the MCA proposals to modernise the coastguard service. As a committee, you made a request for evidence and feedback from interested parties. I would like to provide one piece of evidence that emphasises a point raised in your meeting with Sir Alan Massey on 8 February 2011. In the transcript of that meeting, Mr Harris (Q100 et seq) raised the question of Gaelic language and place names. A similar situation exists with the Welsh language. 2. I attended the public meeting for Milford Haven on 17 March 2011. The following is an extract from that meeting (pages 9 and 10). The question was raised by Kevin. “Just a quick scenario and I would like you to just answer how that is going to be dealt with with the new system. A family from Nottingham, not exactly a seaside place, they have come down to Pembrokeshire, they have gone to the beach at [?? 0:21:23], it doesn’t have an English name, sorry. Their little boy is playing on an inﬂatable, there is a bit of a fresh breeze, it is a summer day, sea breeze is getting up. They look up and suddenly he is some 100 yards offshore and going, they can’t get to him. They call 999 and ask for the coastguard. I am sure people around here can put themselves in the shoes of that parent. What I would like you to do is just compare and contrast the response they will get from an operator in Southampton who if they don’t have the local knowledge I am guessing is going to be using a call centre type system to—oh, okay ﬁne, perhaps you will explain later then Peter. Compare and contrast that with somebody at Milford and I see some of my former colleagues here who I am sure know where [?? 0:22:21] is and will know exactly which lifeboat they are going for and which other resource they might well look out for. So perhaps if you could answer that question”. 3. The interesting point here is that in the scenario, the beach was at Cwm yr Eglwys. This name was mentioned twice but the transcript shows [?? 0:21:23] and [?? 0:22:21]. Despite having: — the recording; — two separate mentions of Cwm yr Eglwys; and — the opportunity to replay; the MCA were unable to identify and include this Welsh name in the transcript. 4. I believe that vital local knowledge will be lost if these proposals are approved. The problems created by this will be further compounded by language issues in the Celtic nations. April 2011

Written evidence from Jim Green (MCA 154) Below are incidents which have occurred over this last Bank Holiday weekend. The figures have been taken direct from our BOSS system. BOSS = Browser for Operational System Status. A system by which incident data, can be extracted remotely. Time span for this example: 00:01 Friday 22 April 2011 to 20:00 Monday 25 April 2011. Holyhead 50 incidents Liverpool 54 incidents Milford Haven 22 incidents Swansea 53 incidents Total 179 incidents As you can see from this brief period in time, over this last Bank Holiday weekend, the proposal just to have Swansea operating as a day time only station is totally unworkable, in fact, madness. The staffing level with which they intend to run Swansea would also be totally unworkable. Staff would certainly not be able to cope with this all to common workload. NB: The above figures do not take in to account the huge amount of non-SAR incident working, radio traffic and telephone handling. All still requiring the same high standard of local knowledge. The above data is not uncommon and as the predicted weather is set to be, yet again, hot for this up and coming Bank Holiday weekend (29/4 to 2/5), the figures show that Wales and the Irish Sea has such a regular cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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high workload that one day time only station to cover the West coast of the UK is no way enough to safely co-ordinate SAR. There has to be at least three to, again, SAFELY, co-ordinate incidents. For additional information, on a national level for the same period of time. ADU = Alert, Distress, Urgency ADUN = Alert, Distress, Urgency, NonSAR ADU 530 incidents ADUN 760 incidents As promised and in my last weeks e-mail ref the Easter Bank Holiday Incident figures. Below are incidents which have occurred over this last Bank Holiday weekend. The figures have been taken direct from our BOSS system. BOSS = Browser for Operational System Status. A system by which incident data, can be extracted remotely. Time span for this example: 00:01 Friday 29 April 2011 to 23:59 Monday 2 May 2011. Holyhead 50 incidents Liverpool 37 incidents Milford Haven 18 incidents Swansea 50 incidents Total 155 incidents As you can see from this brief period in time, over this last Bank Holiday weekend, the proposal just to have Swansea operating as a day time only station is totally unworkable, in fact, madness. The staffing level with which they intend to run Swansea would also be totally unworkable. Staff would certainly not be able to cope with this all to common workload. NB: The above figures do not take in to account the huge amount of non- SAR incident working, radio traffic and telephone handling. All still requiring the same high standard of local knowledge. The above data is not uncommon and as the predicted weather is set to be, yet again, hot for this up and coming weekend (7/5 to 8/5), the figures show that Wales and the Irish Sea has such a regular high workload that one day time only station to cover the West coast of the UK is no way enough to safely co-ordinate SAR. There has to be at least three to, again, SAFELY, co-ordinate incidents. For additional information, on a national level for the same period of time ….. ADU = Alert, Distress, Urgency ADUN = Alert, Distress, Urgency, NonSAR ADU 539 incidents ADUN 624 incidents 1,063 May 2011

Written evidence from Convener Sandy Cluness (MCA 156) Maritime and Coastguard Agency( MCA); Consultation on the Future of the Coastguard Service Shetland Islands I am writing to you as Convenor and Leader of Shetland Islands Council and on behalf of constituents as well as a number of bodies who have made representations to me on this matter. I welcome unreservedly your Select Committee’s call for an inquiry into the MCA’S proposals and confirm that I am willing to co-operate and assist with your inquiry in any way that might be appropriate. As a Local Authority Leader I am well aware of the desire to deliver ever-increasing efficiencies and to reduce cost. The difficulty with the current recommendations within the consultation document is that a number of factors have not been properly considered such as the risks to the safety of shipping and for those who use our coastal waters. Any perceived cost savings or presumptions of efficiencies will be far outweighed by the potential for a tragedy, which will be felt far beyond the Northern Isles. Moreover it has been conceded that there has been no co-ordinated or overall risk assessment of the proposals which are contained in the consultation document and I would ask that your Select Committee considers and addresses this point. You will be aware that the Northern Isles as well as the Western Isles are particularly vulnerable to the threat of shipping accidents given our location and the adverse weather conditions in which vessels are having to operate. You will be also be aware of the significant Oil & Gas Offshore industry which the government is cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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currently investing in and which brings signiﬁcant revenue to the public purse. For these reasons the loss of the Emergency Towing Vessels would be a cause for considerable alarm and at odds with Lord Donaldson’s recommendations following the grounding of the MV Braer in Shetland in 1993. I am pleased that your Select Committee has taken an interest in this matter and I would therefore invite you and your colleagues to visit the Northern Isles where they will get a much clearer impression of the environment and conditions in which the coastguard station effectively performs its functions and where the importance of local knowledge can be seen ﬁrst hand. Should your committee be unavailable to visit the Northern Isles I am of course willing to give evidence on behalf of Shetland Islands Council to your committee in London and would ask that you advise me the proposed dates. I look forward to hearing from you in early course May 2011

Written evidence from a Coastguard Rescue Service Station Officer (MCA 158) I am providing this statement to address the grave concerns that I have over the proposed closing of Maritime Rescue Co-ordination Centres across the UK. As a Station Officer with seven years and over 200 incidents worth of experience I know that ensuring a successful outcome of an incident as well as having the support and confidence of the community is essential in running an effective Coastguard Rescue Station. I feel that the centralisatration of co-ordination services will affect this detrimentally and make the position of the CRS untenable. I also firmly believe that the proposed changed will compromise the safety of the officers on my team and this is a situation that I am not prepared to tolerate. I wish to address the issues of safety that I know will be the result of the proposed changes as well as my concerns for relationship that my team will have with the community. In a number of incidents that I have been involved in I am confident in saying that the local knowledge demonstrated by the locally based MRCC has helped to ensure a positive outcome in these incidents. I am also confident that this includes situations where loss of life would have occurred had this knowledge not been there. I realise that this is a much used argument but it goes far beyond knowledge of place names. MRCC officers that I work with closely know how we best work as a team and know which assets to mobilise to support our work in a given situation. This is rooted in relationship and not just in knowledge of the coastline. Similarly the MRCC officers know that if an asset is requested it is done so purely out of necessity and as a result never question the judgement of the on scene officers. I am concerned that under the proposed changes this relationship would be lacking and the mobilisation of assets in a timely manner would not occur. The actions of the MRCC officers in mobilising multiple assets at the same time has also been a factor in the saving of life during incidents that I have been involved in during recent years. I can say with a high degree of confidence that the mortality rate of casualties in my Guard would have been much higher had the MRCC officers, with whom I have an excellent relationship, not been there. Trust is also an essential component of this relationship. I am able to trust the locally based MRCC officers as I have met with them on numerous occasions as well as worked with them over the past years. Without the high level of trust we enjoy the prosecution of incidents would be much more difficult. Whilst I am in no doubt that relationships would be built with the staff at the new MOC centres, this relationship will never evolve into the same, unquestioning trust that we have now. This will result in the compromised safety that I have previously mentioned. An integral part of the successful running of a Coastguard Rescue team is the trust that the community places in us. This trust is built through the successful execution of incident response and the continued service provided to members of the community. I am exceedingly worried that the proposed changes will result in incidents occurring that will damage the relationship that we enjoy with the community that we help to protect. I know that we are not alone in this relationship; it is one that is nurtured and required by every Coastguard Rescue team in the UK. I initially felt positive about the possibility of extra responsibility being given to me in the prosecution of incidents. However, I do not believe that this extra responsibility will be backed up with robust training and support. As a volunteer I would feel compromised in this situation. The closure of MRCC’s across the country has been interpreted as the withdrawal of all Coastguard services in that area. As a result I have been dealing with members of the public asking me “when will the station be closing” and who will be taking over. I have been asked if they should call the Fire Brigade to deal with cliff incidents and whether the RNLI Lifeguards will evacuate injured people from the coast paths. This represents cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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a huge safety concern and will result in the mobilisation of inappropriate assets to deal with an incident which could result in further injury or even death. Finally I wish to address the concerns that I have over the safety of the members of my team. That said I feel that these concerns should be extended to members of any rescue service called in to provide support in any incident. A locally based MRCC helps teams on the ground to provide an essential overview of the disposition of all resources involved in an incident. Having been involved in some large scale incidents over the years involving a number of statutory and non-statutory services I have first hand experience of how important this is. The success of this is rooted in the relationship that the officers at the local MRCC have developed with all of the emergency services and the work that they have done to foster relationships between the units on the ground. I understand that the stock reply to all of the concerns that I have raised will be that the Coastguard Service is professional and that all of the concerns I have are not founded and that I will still have the same relationship and levels of safety and in no way will my, or any team, be compromised. These responses are short sighted and patently untrue and represent the views of those who have not taken the whole picture into consideration. I would like to point out that the Coastguard Rescue Service was not initially included in any consultation about the changes to the Service. This clearly demonstrates the lack of regard in which the volunteers that allow the Coastguard to carry its role are held. I thank you for taking this statement into consideration as evidence in this review. Although this represents my concerns I feel that it highlights the concerns of a number of Station Officers across the country and especially those who fear for their continued service if they offer evidence in this matter. It has been suggested that I “keep my mouth shut” over this matter by elements of the Coastguard Service but I offer this statement in spite of this and to ensure that whatever changes are made are done so after all evidence and consideration has been taken into account. May 2011

Written evidence from Harry Edmondson (MCA 159) As an individual with no connection to any aspect of the Coastguards I appreciate you taking the time and trouble to communicate with me on this subject. In reply I would like reiterate my belief that it is the Ministers job to agree terms and conditions with the Chief Executive Officer and for the Chief Executive Office to advise his staff as he sees fit and appropriate. I believe the Minister is acting outside of his remit by trying to impose conditions on employees especially when those terms and conditions were not outlined and agreed at the start of the consultation. The Minister is attempting to impose a change of TERMS OF REFERENCE to this Consultation process AFTER the deadline for formal response and thus denying everyone else their democratic right to respond. I would be obliged if my objections could be entered into the records please, and an acknowledgement issued to that effect.

From: HARRY EDMONDSON Sent: 13 May 2011 10:40 To: ELLMAN, Louise Cc: EAGLE, Maria Subject: Fw: COASTGUARDS CONSULTATION Dear Ms Ellman. You may recall that I submitted a response document to your Transport Select Committee under the name WWW.DONTSINKTHECOASTGUARDS.CO.UK And gave my permission for this to be entered as evidence. I have become aware that Minister(s) have recently instructed that Coastguard employees should not be permitted to give evidence to you Transport Select Committee hearings and I was concerned as the evidence currently on record shows that employees have been permitted to speak from day one. I have therefore written to Sir Alan Massey for clarification on this point and the following replies from Sir Alan confirm that employees CAN ATTEND AND GIVE EVIDENCE. As Sir Alan Massey is the Chief Executive Officer of the MCA, and therefore the BOSS to all employees any Directive given by Sir Alan is a clear instruction to ALL employees. It is my contention that should a Minister wish to countermanned this instruction it must be done by instructing Sir Alan Massey and then for Sir Alan Massey to instruct employees as Sir Alan Massey decides is appropriate. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Whilst Ministers may control Government based organisations they employ Chief Executive Ofﬁcers to Manage these organisations and all instructions to employees must be issued by the C E O. In preparing my response document I paid particular attention to the TERMS OF REFERENCE under which the Consultation Document was issued and I attempted to respond to all points raised by using facts and documented evidence from the Consultation process, including the stated rule that employees could speak up and offer comment and evidence. It is my contention that any attempt to change or vary the original TERMS OF REFERENCE must be rejected absolutely and if any change is to be introduced it must be done by the full withdrawal of the existing Consultation Documentation and process and a new Consultation be introduced with new TERMS OF REFERENCE clearly stated and agreed before the consultation commences. I would be obliged if you could please enter this email and the following emails into your evidence noting that Sir Alan has given full approval for his emails to me to be entered in the public domain. Regards Harry Edmondson

— Forwarded Message— From: Alan Massey Sent: Thursday, 12 May 2011, 17:33 Subject: Re: COASTGUARDS CONSULTATION Dear Mr Edmondson Many thanks. I am very happy for you to put my email(s) on your website. Regards Alan

—Original Message— From: HARRY EDMONDSON To: HARRY EDMONDSON To: Alan Massey Sent: 12/05/2011 10:05:41 Subject: Re: COASTGUARDS CONSULTATION Dear Sir Alan. As always I am pleased with your response to my email and I appreciate you taking so much time and trouble in helping me to understand the situation. I now believe that your members will be permitted to attend Select Committee meetings and give evidence without fear of recriminations. May I please ask your permission for me to include your email to me on our web site and share the information with the organisations who have supported our campaign. Kindest Regards. Harry

From: Alan Massey To: Sent: Thursday, 12 May 2011, 8:41 Subject: Re: COASTGUARDS CONSULTATION Dear Mr Edmonson Thank you for getting in touch. You misunderstand. But it’s absolutely not your fault. This is all about a very speciﬁc and detailed matter. The Transport Select Committee are conducting an inquiry, as I’m sure you know, into our future Coastguard proposals. They have already taken written evidence from many sources, including from both salaried and volunteer Coastguards. We have not attempted to stand in their way. The TSC are shortly visiting the MRCCs at Falmouth, Clyde and Stornoway, where we are actually encouraging Coastguards (including from other MRCCs) to meet with and speak freely with the TSC members, in exactly the same way that we have been perfectly happy to enable and support other MPs in their desire to visit MRCCs around the UK and engage with our people in open forum. This all constitutes verbal evidence. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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I have never, ever tried to stiﬂe our staff’s access to Members of Parliament and have always encouraged them to speak freely—bearing in mind that our salaried employees are of course civil servants and are bound by a clear code of practice that, among other things, requires all of us to be honest, objective and impartial. You referred in your previous email to Coastguards attending our series of 20 public meetings. I made absolutely no attempt to stop that—quite the opposite. I also actively and explicitly encouraged Coastguards to contribute freely to the consultation process with written inputs: both general comments and alternative proposals. I’m afraid any accusation of our trying to stiﬂe or gag our people is completely off the mark—the evidence to the contrary is rock solid.

The very speciﬁc issue that you refer to is to do with Coastguards, as civil servants, appearing formally to give “on the record” evidence to a formal session of the TSC, in the full glare of public and media. There is very clear Cabinet Ofﬁce guidance on this matter, and that is what those letters are addressing: our Ministers are doing no more than following that very clear guidance. And, by the way, it is also very clear that it is always for Ministers to decide who represents them and their Department at such hearings. I have written a note to all of our Coastguards that makes the issue very clear: I will copy it to you.

Thanks for sharing your concerns. I hope this clariﬁes the position. Regards Alan

—Original Message— From: HARRY EDMONDSON To: HARRY EDMONDSON To: Alan Massey Sent: 11/05/2011 20:51:57 Subject: COASTGUARDS CONSULTATION

Dear Sir Alan.

I have been included in the circulation of certain information including the exchange of letters between Mike Penning and Louise Ellman in which Mr Penning instructs that Coastguard employees may not attend and give verbal comment to the enquiry.

With all due respect Sir Alan I have to express my total disgust and dis-satisfaction at this decision being taken and subsequent instructions given.

I am a member of the public with no connections to the Coastguard Service, just the concerns of a tax payer about what may happen if the wrong decisions are made, I have tried to follow the letter of the rules regarding this consultation. I have studied the various items of evidence, the transcripts of the meetings, the Safety Documents and the evidence given by those who spoke up at the meetings.

I may not be the most knowledgeable person to have made a representation to this process but I hope that the representations that I have made are at least honest and truthful and based on provable facts.

Throughout my studies of all the documentation available, and during the Liverpool hearing which I attended, members of MCA staff were assured that they could speak up and have their say without any recriminations and in total freedom. I personally have based every single word of my representations on the FACTS that were put before us and I believe that I have been honest and truthful and have avoided comments based solely on sentiment.

To be informed now, NINE WEEKS AND SIX DAYS AFTER THE PUBLIC MEETING, that employees of HM Coastguards are not permitted to voice opinions, present evidence and make representations to the consultation process and subsequent hearings and investigations is, in my opinion, a change to the terms of reference under which this entire process has been conducted.

It is my contention that attempting to change terms of reference at this stage should not be permitted and all members of staff should be afforded the freedom of speech and representation that were promised throughout the consultation process.

I trust that you will be able to over-rule this latest instruction and afford your employees the freedom of speech that you conﬁrmed prior to the hearings.

Should you not be able to over-rule this latest change of direction then I respectfully request that all evidence gathered thus far be disregarded and the entire enquiry be cancelled, the proposal withdrawn and a fresh full enquiry be commenced with terms of reference detailed in advance and not varied during the process. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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I am conﬁdent, Sir Alan, that you will give this matter your full undivided attention and remain, Yours respectfully Harry Edmondson May 2011

Written evidence from Operational Coastguard Officers from around the United Kingdom (MCA 160) Now that the consultation process on the modernisation of the Coastguard has ended, what is the way ahead? Sir Alan Massey has stated that a non-executive director will be in charge of a team led by Mr Peter Dymond to collate the responses. However, there has been: 1. No Terms of Reference for this group drawn up or published. 2. No trawl notice sent around the agency for anyone to give an “expression of interest” in being part of the team to go through the responses and help in taking H.M. Coastguard forward. 3. No explanation of what will happen to the responses or how they will be dealt with. (It is common belief that the current proposal will be modified and presented again, not discarded out of hand as it should be and a new one drawn up). 4. No indication of how the response team will be selected and from where. 5. No notification of whether a report will be published or indeed published prior to any action being taken upon it, and who will be made privy to its contents. In an issue which has stirred up such high emotions, not only across the entire United Kingdom but in the House also, would it not be prudent for the Minister and in turn the MCA to ensure that there are no mistakes this time and everything is above board and seen to be engaging due process. It would appear yet again, that the process is being driven through a desire to save face and is being used as a tick in the box exercise. May 2011

Written evidence from John Hope, ex PCS Section President (MCA 165) My name is John Hope. I am currently employed by the MCA as a Sector Manager. I began my career as a Coastguard in 1994 and progressed through the Operations Rooms at MRCC Clyde and from 1998 till 2009 was stationed at MRCC Belfast. I have an extensive knowledge of SAR co-ordination and the procedures and factors relating to this service. I achieved the position of Sar Mission Co-ordinator in 2000 and acted in this role until my departure from Belfast MRCC to the Sector in 2009. At the commencement of talks in 2007 between the PCS Union and the MCA management, I represented the PCS delegation as Section President at these meetings until my retirement from this position in mid 2010. Subsequent discussions, involving the DfT Director General of International, Strategy and Environment, were conducted as a means of resolving the PCS Industrial Action in pursuit of fair pay and grading. During these talks, it was accepted by all parties that a restructuring of sorts within HM Coastguard would have to be devised in order to address the issues. The proposals for the “new look” CG Service were presented to the PCS in the early stages of these talks and were primarily based on the MOC/5 Satellite system (which transformed into MOC/3 Sat conﬁguration— England and Wales Only) The talks progressed along the lines of the proposed idea being examined, and challenged, where necessary, by the PCS delegation, with the intention of reaching compromises which would see an improved Coastguard service with properly remunerated staff. One of these areas of challenge came in early 2010 when a proposed “table top” exercise was offered in order to demonstrate the proposed concept in a working fashion. The event took place 2010 and resulted in nothing more than a visual demonstration of the known incident statistics taken from a particular day in June 2006. These incidents were dealt with by 12 MRCC’s in England and Wales. The incident count for this day was then superimposed on a chart which had the 12 MRCC’s replaced by a MOC and three satellites conﬁguration and which resulted in the spread of work on that given day being displayed over this new layout. There was nothing tested. The outcome of this event was a geographical display, in England and Wales, of those particular days’ incidents and their locations on the proposed conceptual system and how it would have looked were all that was delivered. On the immediate post event discussions on the same day, I suggested to the management team present, consisting of Chief Coastguard, Philip Naylor, and one other, of the further need for a “real time” test of this cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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concept at the Operations Room simulator within the MCA training centre at Highcliffe in order to test the actual incident workload handling and workflow in a real time fashion. I suggested taking a two hour section of this chosen day and by utilising the known incidents by using them as interjects into the Operations Room simulator, we could analyse how the management of these incidents could be progressed. I suggested the simulator be manned by a watch consisting of an SMC and three qualified and experienced Watch Officers from anywhere in the country (hand picked by management). We all agreed this test would examine some of the critical issues surrounding the proposed concept and give us all an opportunity to evaluate the proposed benefits of the new system and how it would actually handle the workload and workflow of SAR Operations in a real time simulated environment. With this agreement, we all proceeded (later that same day) to DfT HQ and met with DfT Director General of International, Strategy and Environment, who also endorsed this idea stating along the lines of “….we need to test this concept and make sure it actually works before rolling it out” A year has now passed and the test still hasn’t taken place, and my concern is that during the public meetings, and indeed the TSC interview, the promoters of this concept are constantly stating that the plan has been tested with no major issues present. This is an extremely misleading statement and one which I raised with Sir Alan Massey personally on the 13th January at a meeting with him in Liverpool. He was surprised to learn this fact and assured me he would put my question to his “advisors” which resulted in a series of emails between Chief Coastguard and myself which have reached the point of meaningless saturation with the Chief Coastguard now appearing to expect me to design the test. I explained that the onus to prove the concept lay with him and his team. I, along with my PCS/experienced Coastguard colleagues, already believed, and still do, that the current concept is flawed and incomplete and are waiting to be convinced otherwise. The main issues which concern me now are the manner by which this proposal is being pursued and presented by the management and their complete disregard for any valid and genuine concern which challenges the outcome and aim of their concept. In order to quantify my concerns I will try and demonstrate the two fundamental areas of Search and Rescue Co-ordination by which we structure our delivery of service. I would suggest that any evolution of our service efficiency and betterment should seek to improve on these fundamental areas if possible….if not, then best it’s left alone.

1. Minimise the Errors The minimising of errors in all aspects of our work is critical to the satisfactory outcome of the rescue and by doing so also minimises the risk to loss of life. In essence, errors are the enemy of the SAR effort and as such must be eliminated or reduced to an inconsequential degree: — Minimising errors relating to initial information gathering processes ie location identification (position fixing), casualty/incident description, response required and the assurance of effective communication between casualty/first informants, resources and co-ordinators. — Minimising errors relating to the devising and compilation of appropriate search plans and actions. — Minimising errors relating to the selection and tasking of appropriate resources and the tasking instructions to them once they are deployed. — Minimising the errors in the overall co-ordination of the SAR plan and the welfare of the casualty/ ies and the rescuers at all times during the SAR effort. — Minimising the errors relating to workload distribution and general management of resources. The other fundamental area of our service delivery is managing time:

2. Chasing the Clock In every single incident the notiﬁcation received by HM Coastguard of any incident, the problem/disaster has already taken place, given that the incident is being reported after the event has begun. The race against time has started at the exact time of receiving the call. This time difference between call reception and incident commencement can be anything from a few minutes up to a matter of hours. Irrespective of the amount of time which has passed, the SAR response is already lagging behind. This is a fact and one which by deﬁnition cannot change. However it has been proven time and time again that the best way to “chase the clock” is by timely and accurate methods of appropriate response and ensuring that they are maximised in order to close the gap of time and reach the successful conclusion before time actually runs out. This process varies by degrees and also by the nature of the incident and the requirement to resolve it. This is the current practice and it has been proved to work well, given the factors involved. cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Any unnecessary insertion of time into this process is basically life threatening if you accept the above criteria. It is with the understanding of the above fundamentals of SAR Co-ordination that I am concerned with these current proposals. The national networking of stations does nothing to minimise errors relating to effective SAR co-ordination. Although it may well improve job sharing and workload handling in extremis, it is a “nice to have” option, not a crucial development by any stretch of the imagination. The remote handling of SAR co-ordination from a MOC however increases the risk of error into the process by the many added assumptions the new system would in fact employ in trying to establish area, nature and appropriate response from the initial call. This then leads to the insertion of time into the process which, as previously explained, equates to the potential loss of life. The initial call interrogation is the most important aspect of effective SAR co-ordination. It has been publicly admitted by Sir Alan Massey that the addition of “a few minutes” may well be expected in the initial call reception and response preparation under the new system. How can this be a betterment of our service given the aforementioned facts? I am appealing to your ofﬁce to put a halt to the progression of this plan and the certain risk and degeneration of service it represents. There are viable alternative options to consider and which must be considered as opposed to this ill-conceived, factually ﬂawed and risk laden venture. I am willing to provide oral evidence relating to my former position as PCS MCA Section President and a former member of the PCS/MCA/DfT proposal working group. May 2011

Written evidence from Sheryll Murray MP (MCA 166) I felt that I should write to you in connection with your recent enquiry in relation to the Coastguard Modernisation. It is both appropriate and essential to write to you to highlight some of the issues that I have personally experienced regarding the local coastguard service both in Looe through the voluntary personnel and also the Brixham Coastguard Station. I have always had real concerns about the proposed changes to the coastguard stations and have considerable expertise in this area, having been involved in various ways with sea safety for almost 30 years. After the events on 24 March 2011 when my husband suffered his fatal accident, I feel it is essential that I make you aware of additional information. I firmly believe the coastguard electronic systems need updating. However, I am surprised to hear the Minister state that coastguards agree with restructuring. They are certainly calling for modernisation of equipment and communication improvements with both neighbouring stations as opposed to the present pairing arrangements. I would also like to make it clear that my husband suffered an accident and the coastguard service in any form would not have been able to save him. As you are no doubt aware, the major advance in marine technology in recent time is AIS (automatic identification system). MFV Our Boy Andrew was fitted with a transmitter, although this was not a compulsory requirement for a vessel of this size. At present the regulations require vessels over 300 GT or passenger vessels to be fitted with this equipment. MFV Our Boy Andrew was approx 17 GT. The cost of a transmitter similar to that fitted is between £400 and £500. On the night that my husband’s vessel was reported missing, I received a call from the local volunteer coastguard in Looe informing me that his vessel was overdue and they had started a search. When I informed them that an AIS transmitter was fitted to the vessel, I was told it was either not working or has been turned off. The Coastguard equipment could not pick up a signal. My son, who had fitted the transmitter to the vessel, within minutes using the ordinary commercial website and informed the coastguard of its location. MFV Our Boy Andrew was also located by two merchant ships on their own tracking system. I believe the Minister should prioritise the upgrading of the marine tracking equipment at coastguard stations, before looking at any communication systems or indeed before closing any local stations. At present, I have not heard any talk whatsoever about the ability of a single coastguard station based in Southampton being able to better locate a vessel in distress and all the talk has been about a National Communication System. It would appear that the present coastguard AIS system is flawed and must be upgraded and tested for reliability over a reasonable a period of time before any closures take place. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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For your information, the vessel was running on auto pilot because the accident happened whilst hauling the gear. Had she not been located, she would have continued on a course that would have taken her way out into the Atlantic Ocean and may never have been found. This would have left me in a situation where I would not have been able to lay my husband to rest and been left in limbo, like so many other ﬁsherman’s wives, for seven years.

I would also ask that you consider, as a matter of urgency, the safety implications for any vessel that does has no GMDSS ( Global Maritime Distress Safety System) equipment on board such as Kayaks, Dinghies , and other leisure craft or indeed beach users.

The local knowledge at local coastguard stations, particularly where yachts in transit radio an ETA for their destination port and are subsequently overdue is essential. I would like to know what level of cover would be provided for this scenario and what process would be put in place at a single station based in Southampton.

I would refer you to Hansard of 12 October 2005 and the Minister’s own words in relation to the then proposed restructuring of Fire Control Centres.

Col 303—The Minister is, like me, a former ﬁreman, and he knows that local knowledge of topography saves lives.

col 346—We are now talking about moving to nine regional control centres. If this is all about saving money—and it is; the Minister has already said that he wants to invest it elsewhere—perhaps we could just have one control centre. Or perhaps we could do as the banks have done and have a call centre in Delhi or Bombay. If it is not about knowledge and only about technology, the proposal for nine centres does not make sense. It must therefore be about what is safe for the public and what works.

Like many other Members, I have grave concerns about IT projects. A Labour Member commented earlier from a sedentary position that IT projects went wrong under Conservative Governments, too, which is perfectly correct—they have been going wrong since time immemorial. In relation to this IT project, the key is lives being saved. That is why I fundamentally oppose the project, and why the FBU opposes it, as it understands the situation on the ground much better than any bureaucrat in Westminster.

In the same debate at Col 347 the Minister stated I take to heart the comments made about retained fire stations, and in a perfect world we would not have any retained or part-time stations. In this imperfect world, however, we have community-based fire stations that serve and are manned by their local community, and we should praise people who are willing to risk their lives for not a lot of money to be retained firemen.

Why is the Minister now introducing a system for the coastguards that he clearly opposed for the ﬁre service?

I would like to praise the volunteer coastguards in Looe and also the staff at Brixham coastguards on the evening of 24 March 2011 for the way in which they communicated with me. I do wonder how this would have been handled by a single, busy coordination centre.

Clearly every Coastguard station has its own individual expertise. In Cornwall Falmouth has its International role whilst Brixham expertly looks after the most busy shipping lanes in the world.

Many coastguard submissions to the consultation are responding to the ill thought out speciﬁcs contained in the paper rather than focusing on the much needed improvement of their equipment.

I remember when the look out posts were abolished many years ago, only to be replaced by the volunteers who now form the National Coastwatch Institution. I was part of the Sea Safety Group who worked tirelessly to set up the NCI after identifying a gap in service.

Sadly, no voluntary group could replace the expertise and knowledge provided by the 18 coastal Coastguard Stations in addition to the one based in London.

This is why I have called on the Minister to abandon his plans and start again with a blank sheet of paper consulting all coastguards working on the ground.

I really hope that you have found this letter useful and look forward to receiving the report from your Committee. May 2011 cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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Written evidence from Jim Nicholson MEP (MCA 167) I am writing to the Committee in support of the retention of the Belfast Coastguard. I am aware that the Coastguard Modernisation Consultation has been out for consultation and that the Transport Committee is continuing to take evidence on the matter. There has been widespread support across Northern Ireland for the retention of our local Coastguard based in Bangor. I believe Northern Ireland must have a Coastguard Maritime Rescue Coordination Centre presence and we must act to ensure that it remains a 24 hour, 365 day, a year station watching over our coastal areas and inland waterways. Lives will undoubtedly be put in danger or lost due to the extra time it will take to respond to incidents in and around the shores of Northern Ireland. Furthermore, if the Coastguard Coordination Centre is removed, Northern Ireland will be the only devolved region with no co-ordination centre. I ﬁrmly believe that there will be a very real loss of local knowledge and, in particular, local geographical knowledge. Place names that are duplicated and alternative local names will be confused leading to time delays. Should I be able to provide anything further or assist the Committee, please do not hesitate to contact my ofﬁce and I will endeavour to help in any way. May 2011

Written evidence from a Serving Coastguard (MCA 168) As a last effort to input to the Select Committee in view of what the minister said ref coastguards advocating 9–10 stations I have canvassed stations about how many stations they would like to see as a minimum do run a world leading coastguard rescue service. Please ﬁnd replies I have received so far.

Response from Humber Coastguards Humber agrees that we should try to retain as many (24 hour) stations as possible.

Response from Thames Coastguards Introduction: This document, submitted by PCS members of Thames Coastguard is intended to propose an alternative configuration of HM Coastguard that is different to the existing arrangements and different to the proposals outlined by the MCA in the recent consultation document. Maintain: 1. Thirteen 24/7 Maritime Rescue Co-ordination Centres (MRCCs). 2. London Coastguard. 3. CNIS/VTS/VTM station at Dover with no SAR responsibility. 4. The number of Sector Managers to remain the same. 5. Local Knowledge. Reduce: 1. The above would require the closure of four current MRCCs. The decision regarding which MRCCs stay open should be made taking into account: (a) the utilisation of existing properties which also house other MCA facilities such as radio masts, Marine Offices or where the MCA owns freehold; (b) the number of incidents handled by each MRCC per annum; and (c) the requirement to have an appropriate geographical spread of stations. 2. Remove CSM grade. 3. Remove Regional Management and centralise. Change: 1. As above, MRCC Dover to co-ordinate CNIS, VTS, VTM as required with no SAR responsibility. 2. Rescue Co-ordination Centre Manager’s role to encompass district responsibilities and to line manage Sector Managers. Job title to change to reflect this.

Response from Milford Haven Coastguards On behalf of MRCC Milford Haven, 14/15 is the bare minimum. We have arrived at this ﬁgure, possibly as a result of us all getting used to the fact that some leases are due to expire, and the very old concept of Portland & Solent merging. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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I personally believe that seperate risk & impact assessments should be carried out speciﬁc to each MRCC. Only then can the MCA & the rest of us fully understand the particular risks associated with each district.

Response from Liverpool Coastguard The watchkeepers at Liverpool agree with you. Also, we did not and would not name or condone closing other stations and save ourselves, which is something else that was stated. I would also be grateful if in the response you could mention that we are not the ﬁre service, a point which seems to be missed by the Minister. The reference he said about Crosby senior manager was not representative of Liverpool PCS union members (100%).

Response from Falmouth Coastguards I know that the Falmouth proposal says 10, but I and a number of others have had severe reservations about that, and I personally agree that 14–15 is a better ﬁgure to aim for.

Response from Holyhead Coastguards On behalf of the staff at MRCC Holyhead, I conﬁrm that our stance has always been no closures whatsoever. In our submissions to the Select Committee and the MCA we conceded that: “If tenure at any particular site is deemed utterly unsustainable, then look at relocating the service provided from that site, or spreading it between existing ones.” The Minister is adamant that the status quo is not an option—I suspect mainly because of the problems that exist with leases on some MRCCs and on that basis, the staff at Holyhead support your view that an absolute minimum of 14 or 15 full time MRCCs should remain.

Response from Stornoway and Shetland Coastguards The Stornoway / Shetland response was 12 as an absolute minimum, but the more the better. 9–10 is an absolute lie, I don’t believe there are any advocates for retention of so few. In fact I have Liverpools submission which clearly states 14.

Response from Forth Coastguards Sorry I might be a bit late with this but with regard to number of stations closing, being stationed at Forth I would say never mind 14 or 15, keep the numbers as they are.

Response from Swansea Coastguards Swansea does not advocate 9/10 stations. May 2011

Written evidence from C A Kay (MCA 169) I am writing to you as an experienced seaman, and former crew member on HM Customs Revenue Cutters, during which time I saw service at sea all around the UK. Latterly I have worked as a yacht club rescue launch driver, and during the last few years I served as safety officer for the Conway River Festival. In all of these roles I have been involved in rescues at sea, or involved in coordinating them, and directing rescue craft to various emergencies. I would like to address the proposed cuts to Holyhead coastguard station, but much of this probably applies elsewhere. Holyhead handles a great deal of rescue traffic, mostly during the summer, but the variety of callouts is huge. Around Anglesey there are many holiday beaches and yachting areas. The seas are notoriously unpredictable and the tidal currents and overcalls severe; unlike the south coast where tidal strengths are much weaker. The variety of water users in these waters is very extensive; it includes: children in rubber dinghies, divers, windsurfers, fishermen and yachtsmen. The local coastguard personel are familiar with all the-Welsh local names, some of which do not even appear on the charts of the area. The particular Welsh pronunciation differs in many cases from the spelling. The response times of the Holyhead coast guard to radio calls is always very quick. I know that I can call them even on a handheld VHF radio anywhere around Anglesey and get an immediate response. I understand cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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that calls in future would be transferred automatically to Liverpool, Belfast or Aberdeen. I do not see how this could possibly be done without lengthening response times and probably missing some mayday calls completely. I can imagine a great deal of local confusion with lifeboat crews and coast rescue services. There has been talk of the gap being filled by volunteer coastguard look outs. There are virtually none of these in north Wales. As a final point regarding Holyhead in particular, it is an area of very low employment and whilst closing a coastguard station might have no effect in Swansea, it would have a significant effect in Holyhead. The retired admiral in charge of the MCA clearly stated his intention in an article in Lloyd’s List, which was to save money. He clearly has no conception of the dangers and potential loss of life he is likely to cause around the UK, and Wales in particular. March 2011

Joint written evidence from Save Stornoway and Save Shetland Coastguard (MCA 170) TRANSPORT SELECT COMMITTEE SESSION 24 MAY INQUIRY INTO COASTGUARD (01:54:46) Mr Penning refers to the fact that during his visit Stornoway Coastguard reported “2 weeks without telephone” and “isolation”. We are unsure what he is referring to as this has certainly not happened as far as any of the staff on the station can recall. We have telephone faults fixed as soon as possible. We have robust arrangements with BT which rectifies our public access, 999 and kilostreams (the lines linking the sites to the MRCC) within high priority timescales. It is unthinkable we would be missing an operational phone line for longer than a matter of hours and during this strict contingency plans would be actioned to ensure coverage. The only exception is the dial in line whereby us and Shetland are linked (to enabling pairing and “resilience”) which has been down for a period of years and which the MCA have only recently made half hearted efforts to rectify—hardly a picture of a commitment to emergency response. Remember—our district is not purely an Island, it covers from Ardnamurchan point to Cape Wrath and “isolation” in Mr Pennings words would present a serious problem to those on the West Coast who rely on us. Feel he should clarify this point. (01:21:56) Mr Penning accuses, for want of better word, Liverpool Coastguard of proposing a nine station model for the UK. Liverpool proposal (when we asked them) is 14 full time stations, no day stations which ALL we have spoken to (national scale) are outright opposed to. In this same paragraph he alludes to a broken system that isn’t working (01:37:00). We feel he should be asked to provide evidence to back his statements up here. Also—he suggests that by submitting alternatives which still include closure we are destroying our argument, the committee were right to address him on the fact that we feel that some local knowledge can be transferred over a sufficient timescale to a station in a reasonably similar area. It will not be the same standard and certain links will be gone, this will diminish further over time. (01:18:10, 01:19:00) Sir Allan refers to pairing making use of the systematic approach to replace local knowledge—this is again either an exaggeration or an error and the fact remains that pairing has been around long enough and tends to be between stations sharing a certain “commonality” of area to ensure knowledge and links have been forged which allow pairing to go ahead. He also ignores the fact that pairing is not an everyday occurrence (although there are exceptions), rather it is done in extremis and tends to have members of staff relocate to the functional station for the period of the problem. (01:19:05, 01:35:00) Sir Allan Massey does not, even at this late stage, grasp the depth of despair in his workforce he quotes “a degree of success” at taking his people with him. What people are these he refers to? Has he not seen the written evidence on the TSC website, has he not read the consultation responses, has he not heard our arguments at each MRCC? Can he provide statistics to see who agrees with his vision of local knowledge rather laughably being available via databases, GIS systems and internet sources, because this is a strong claim to make and the evidence suggests few operational staff agree with him. (01:50:03) Sir Allan Massey brushes off the devolution argument quite lightly. There are NO operational reasons why we as a service shouldn’t devolve. Quite the opposite. He fails to address the advantages of increased ease of operational liaison and emergency planning. He also fails to identify that Scottish incident statistics are different on the whole to English statistics and the benefit of common training is not quite so correct. Mr Penning says that breaking up the Coastguard will diminish the quality, yet this is what he is doing if this proposal goes ahead! (01:40:00) Sir Allan in his answer about languages describes the training they refer to in the risk assessment document as “enhanced questioning”. So the statement in the document is actually what, a lie or simply wrong? Language aside he refers to enhanced questioning techniques (01:41:00) again no evidence of this being passed on in the operations rooms. If there is a problem with questioning techniques and the agency are currently ignoring it, we have a serious case of negligent management. Mr Naylor in the same argument (01:42:00) refers to a national service with this mythical demographic willing to be posted round the country. It is not true—since focus for change we have recruited locally and in the large case those joining an MRCC are from the area and WILL not move. Frustratingly we have tried to spell this out to them, and they don’t seem to be listening. They may recruit nationally but people who want to work in a station tend to come from the nearby cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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locality. So the statement that local knowledge does not rely on local people is false, certainly in the two islands it relies heavily on local people. (01:00:55, 02:07:07) Mr Naylor, who has NEVER been an operational coastguard, makes reference to incident statistics (again at 01:04:45—where he brushes of the extra workload of night incidents) and points to “lulls” where nothing is happening during protracted incidents. He seems to disregard the fact that all throughout an incident we are responsible for co-ordinating and monitoring the units deployed (including their safety) during these lulls he mentions other tasks that are not performed during busy periods are performed— plotting position, chartwork, updating search plans, briefing the ops room team, forward planning. Of course he wouldn’t know this, because he is not a Coastguard—and in common with the rest of the senior management has made no attempt to ACTUALLY find out what we do instead referring to long and complex incidents as a series of “short bursts of activity”. Mr Penning compounds this by referring to emergency services only comparing numbers (02:09:30), NO we don’t in this case—we are deeply concerned (nationally) that these raw statistics are misleading. Mr Naylor refers to the fact they have allowed for sufficient numbers of staff to cope—what he fails to reveal is this was modelled as a result of a pitiful table top exercise involving sheets of paper being handed out to represent start of an incident. (02:12:29, 02:16:00 and 02:11:58) Sir Allan and Mr Penning make reference to emergency service personnel’s contractual obligations and the fact we must stay behind to effect handover. We are, as he identifies earlier, not emergency services but civil servants and have no such contractual obligations. We DO currently stay behind to ensure handovers are smooth, but this is done out of professional pride in the job and no small amount of good will. Will this remain if the MCA get their way—highly unlikely. This seems a direct attempt to circumvent the committee’s questions on handover and the dangers of the MOC / day station model. Also— a day station will have a total complement of only 10 staff, this is not enough to offer any flexibility for late stay overs until the MOC is up to speed with your incidents. There is (and remains) deep suspicion in the service that day stations are a stepping stone only to soften the blow before going shortly after the MOC is able to work round the considerable problems this plan will create. (01:53:00) It seems to be getting alluded to that career progression is a major worry of the MCA. If that is the case why are they proposing this model that will establish a two tier system whereby the MOCs hold all management posts and the day stations hold only operators. We have said it all along that this will see those in day stations put out to pasture waiting to fill dead mans shoes as there is no management structure on station and should you want promotion you will have to move to MOC (something we identified wouldn’t happen). Lets be clear—the MOC is there to overrule those unfortunate enough to have to work in a day station (01:56:00, (02:13:56, 02:15:00). Something clarified by the point relating to handover of incidents “the MOC would be monitoring those incidents” and “the MOC would decide when handover would occur”. So we have all those highly trained coastguards in a MOC doing what exactly? Keeping tabs on the poor cousins in day stations, that’s what. In fact the MCA have no intention of even installing the computer system to plan searches into day stations (their technical addition to the consultation states that SARIS, the search planning system, will be able to be viewed at day stations but clearly the actual plans will be created at the MOC and transferred to the day station—clearly another route for errors and delays to creep in). (01:58:03) Mr Naylor seems to side step the question regarding the small boat operator and technology by referring to the fact that they would be able to speak to us, whether deliberately or through ignorance he avoids the thrust of the question being that small boat users will not have the positional aids to enable operators who cant be expected to really know an area to locate them quickly (AIS, DSC, GPS, EPIRB etc). If local knowledge is important (and we are told the MCA do think it is hence the desk idea for MOCs whereby an operator works a particular area) then how can work be simply shared round the entire network? Could an MOC operator in Southampton answer a weak and sketchy 999 call in West loch Tarbert from someone with an unfamiliar accent and place name and know in that 30 seconds where the casualty is in the absence of any “technology”? NO. (01:59:50) Mr Naylor implies the MCA are proactive in monitoring their radio network, we have an aerial overlooking Castlebay in Barra which in certain directions gives frankly woeful coverage. It has been known to be poor for many years and the MCA have done nothing to rectify it. If evidence required—please ask Barra Coastguard Team or better still Barra RNLI lifeboat seeing as Mr Vlasto has now publicly said that the crews can speak. (01:57:12) There is reference to the possibility of a pair of stations (Falmouth and Brixham quoted) “going down” as a result of some occurrence (lightning is quoted). This has never yet happened, and should it then the problem will be a regional one. Should a MOC go down it will be a NATIONAL problem as not all aerials are going to be linked in to the “partner” MOC. Result—more gaps. The MCA are happy to use statistics to support them, but not so happy to answer to statistics when they are opposed to their vision of the service. (01:52:00) Mr Penning goes on about how other countries do Coastguard but fails to give the full picture, when talking about MRCC or RCC he says: Australia has 1—yes it does. But then he neglects to say that the Australian service is actually a volunteer organisation much like the RNLI so it is actually impossible to make a direct comparison. Spain has 1—Factually untrue. SAR is the responsibility of Sociedad de Salvamento y Seguridad Maritima (or SASEMAR) has 20 Rescue Co-ordination Centres (something we know very well because we hear the likes of La Coruna, Palma, Finisterre etc banging away on MF!!) has a staff of 1500, a fleet of 19 vessels, 54 boats, eight helicopters & four aircraft. Norway has 2—Yes but again he fails to mention cobber Pack: U PL: CWE1 [E] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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the rest of the organisation such as the network of nine coast radio stations manned 24/7 and 27 Rescue Sub Centres. May 2011

Written evidence from Devon County Council (MCA 171) PROTECTING OUR SEAS AND SHORES IN THE 21ST CENTURY The proposals to modernise the Coastguard Service, published by the Maritime and Coastguard Agency (MCA) in 2010 have been considered by the County Council. The importance of a safe coastline and maritime waters is paramount. We have therefore submitted a response to the MCA’s consultation. A copy of this, included in a report to our Cabinet, is enclosed. We hope that the summary below clearly states our position regarding the proposals. If you agree with us on our response then we would greatly appreciate that you consider corresponding with Mike Penning MP, Minister for Transport or the Transport Select Committee, conveying your views on this important matter. If you have already supported a re-thinking of the MCA proposals than we would like to thank you and please find this letter and report for your information. Our response to the MCA proposals, in summary, is as follows: — We recognise the need to modernise the Coastguard Service. However, any new system will need to perform as well or better to warrant the relatively minor savings envisaged. — The consultation document sets out proposals to remove the existing 18 Maritime Rescue Co- ordination Centres (MRCC) and set up two “super centres” (MOCs). Our view is that to retain, network and adequately equip some of the existing centres would be an equally effective, highly resilient and flexible solution. — The two national Marine Operations Centres (MOCs) would inherit the same limited resilience that the current, paired MRCC system has but on a larger scale. In the rare but potentially catastrophic event of both MOCs being inoperable a contingency is essential. The probability of total MOC failure occurring could be reduced significantly by having more than two centres, and by providing 24-hour capacity through sub-centres to ensure a risk and demand-led service which doesn’t just operate within daylight hours. — The South West should be regarded as unique in its search and rescue (SAR) needs, due to its role as the UK’s principal summer holiday destination and the occurrence of 30% of all incidents in July and August, so there is a need to increase efficiency and resilience in this area. — We are concerned that spreading resources too thinly will result in the loss of local “knowledge”, which is often the key in ensuring-a coordinated and fast response to emergencies. — One of the most important elements of a SAR is coordination with other organisations such as the Police, RNLI, ambulance and civilian search teams. We think the “Team Leader” staff resource should be redeployed to augment the Coastal Safety Officer role such as to increase their numbers. — We would like to see a stronger role for the National Coastwatch Institution—a voluntary organisation with over 40 stations around the coast staffed by 1,700 volunteers—with more effective communication systems between shore-based teams and vessels at sea and better use of technology and communications. — Greater support for the volunteer Coastguard Rescue Service is welcome but needs strengthening if the total coordination effort and local knowledge is not to be reduced. — The County Council urges the MCA to revisit the proposals to ensure that the reductions in local services proposed will not critically affect the ability of HMCG to cope with the increasing demand for an effective search and rescue service. May 2011

Written evidence from Zoe Moore (MCA 172) I write with reference to the Committee meeting of 24 May which I took great pleasure in watching on Tuesday. Although many statements made by Mike Penning, Alan Massey and Philip Naylor were factually incorrect one speciﬁcally sticks in my mind. Therefore I would like to make you aware of it. Mike Penning said that Australia only has one MRCC for the entire country, this is correct however what he failed to tell you is that they do not deal with any inshore/shoreline incidents as this is dealt with by the police. cobber Pack: U PL: CWE1 [O] Processed: [20-06-2011 12:13] Job: 010828 Unit: PG01

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The operations room in Canberra (where I have spent a week) has no radios, or 999 calls as this is dealt with elsewhere. I do not see that UK MRCCs can be compared to the Australian setup. May 2011

Written evidence from Kevin Bird (MCA 173) Question: Mike Penning. Western Isles had a BT land line link lost to a radio mast where it was manned by Coastguard Volunteer.

PCS Members Response Resilience The ability to recover quickly (bounce back ability). To recover to the status quo communicating by radio and telephone. The proposal states it has more bounce back ability than we currently have at present here in Brixham Coastguard Rescue Centre, ﬂanked by our colleagues, at Falmouth and Portland Coastguard.

Radio If a major catastrophic BT communications failure occurred at one or all of these stations, this would result in the loss of connectivity to the remote radio site (RRS). A practiced procedure is already in place for a redundant Watch Officer + one of the watch (made thus because of the inability to use VHF radio), grabs the crash bag containing charts/maps and associated instruments. Plus the VHF DSC emergency control panel, mobile phone and an up to date contact directory of all the SAR resources in the Brixham District. Proceeds to the RRS nearest to Start Point and sets watch on Very High Frequency Digital Selective calling (VHF16/DSC) within the hour. The WO already has the local knowledge and OPS room training and maybe Search and Rescue Mission Coordinator (SMC) qualified to do the job. The intention to replace this function with an unqualified and therefore incompetent CRO, IS NOT RESILIENCE. The link between a co-ordination centre and a radio sight is an open telephone line. That’s all, in the cheapest form, that’s all it will ever be. A line routed via an exchange or two.

Telephones BT transfers the priority (999, ex directory and lines in/out) lines to another station. Mike Penning. Falmouth was hit by 2 lightning strikes in last 3 years and I have no one to take over that role.

PCS Response. What happening then? I'll tell you that MRCC Brixham looked after the GMDSS role and MRCC Humber NAVTEX. Mike Penning. With ref to comparing worldwide single MRCCs, with the UK. The majority of which do not have the responsibility of SAR on the coastline like we have in the UKSRR (United Kingdom search and rescue region) Of which 76% of our incidents are located on the shoreline. This responsibility rests with their Fire/Police service. May 2011

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