Irish Maritime Directorate Strategy - Public Consultation Submissions by Recipient 1. Commander John Jordan Received 13 November 2020 Dear Sir, From 1952 to 2000 I served on Irish and British Merchant ships, including 32 years in the Irish naval Service, and finally 8 years mainly with Commissioners of Irish Lights and some with Dundalk shipping and British and Irish Containers on MV Wicklow. I would have entered and used all Irish Ports except Wicklow, Dundalk ,Drogheda and Sligo. In Naval days I was liaison officer to the Survey and charting for Burtonport Fishery harbour and served in command of 5 naval ships. Comments Core 1. In the overall our response to Maritime safety is reactive as we have NO hands on 24/7 view, or control of maritime traffic. With the loss of manned lighthouses and reliance only on Radio channels in competition with Cell and satellite phones there has been a loss of the Surface Picture and of discipline among users. Most busy sea traffic areas, other than Ireland, are now controlled and interrogated by VTS . Recent incidences offshore and over the years has shown our weaknesses in the event of ship breakdowns that culminate in towage and/or rescue. There are no dedicated Emergency Towage vessels. Regulations will not solve or provide a solution to an actual incident. Core 2. Some of our Ports are in planned disarray. There is a certain loss of control in that traditional town based berthage is being repurposed as development lands while linear losses of berthage, are not being met at down river sites. It is commercially untidy, and unsightly, to have Bulk, Container, Timber, Miscellaneous, and passenger vessel traffic packed into the same harbour area. From a naval point of view, no harbour has suitable access berths for visiting ships especially the larger foreign vessels. In the overall harbour Boards often provide facilities for special cargos that have no longevity and impose costs to repurpose. Our biggest shame is the loss of our own flag ships and our deep sea tonnage with a consequential loss of independence. Tiering ports is a means of perpetuating the non-development of existing small ports or building new ones. We need a clear estimate of linear and depth requirements for multipurpose ports and we need to resurrect our ability to provide repair facilities for all our port users including vessels up 250/300 metres length. The Naval Service alone would need 700metres of berthage to put all their fleet alongside individual berths. Lastly in the green age it is now a necessity to provide all ships with shore power to run all services and shut down diesels in harbour. Core 3. Again effective response requires obvious assets and manpower. Their is the need for aircraft for patrol and top cover, Intervention surface craft and helicopters with ranges perhaps to 350/400nm. Vessels capable of towing up to cruise liner sizes. Vessels capable of dealing with an oil pollution, or chemical pollution incident at sea. Core 4. The initial requirement is to ensure that all vessels entering harbour have a waste handling system on board. That there is a system available in harbour to handle ballast water, waste oils, ship rubbish/dunnage, and domestic waste from ships. Fuelling ships should be notified and supervised for safety measures before and after fuelling. Inspection is key, including maritime flights looking for pollution at sea. The remaining matters are organisational, the bigger challenges are providing the infrastructure and not allowing preferences to misplace urgent needs to attract traffic, and Industry by increasing all ports capacities. regards John Jordan 2. Leslie O' Hora, Past President, Glenans Ireland sector Received 13 November 2020 Dear sirs. The idea if an island nation without a sail training vessal is appalling. It's some years now since the Asgard sunk and its subsequent insurance payout As a national training vessal, the Asgard proved in its lifetime to be a vital part of breaking down barriers amongst to youth in our society as well as teaching them maritime skills and a love of offshore nature. Surely now is the time to replace her when the youth of Ireland need to live full lives again following the pandemic. It's worth noting that Les centre nautique des Glenans was founded after the second world war to nuture French youth who had lived through those turbulent times. Your sincerely Leslie O Hora 3. Maurice Fitzgerald Received 14 November 2020 I, Maurice Fitzgerald, XXXXXXXXX, make the following submission in relation to a public consultation on the Development of a Strategy for the Irish Maritime Directorate. Core Objective 1: Enhance Maritime Safety through effective regulation, implementation and compliance. Recommendations for inclusion in Maritime Strategy: 1. Develop a roadmap which includes priority legislative requirements at international, domestic and EU level. The roadmap should be risk based on priorities having regard to deadlines for implementation of EU legislation, the configuration of the Irish fleet and an analysis of ships calling at Irish Ports. Answer: Our naval service in addition to the coast guard is only a paltry token force. Any road map would need strong enforcement – otherwise legislative improvements would be a moot progression. We would need a far bigger enforcement mechanism for any legislation to be effective. A maritime traffic control system could also be established at EU level if it hasn't already, however all vessels would have to have a transponder, like aircraft. 2. Establish a methodology to ensure effective implementation and enforcement of relevant international mandatory instruments. Answer: Again, we only have a tiny token maritime enforcement mechanism and any effectiveness would have to come about with a much larger fleet of vessels. 3. Ensure reporting requirements are met with regard to the implementation of international conventions. Answer: no answer. 4. Promote greater communication with all relevant stakeholders on legislative and regulatory developments impacting on the sector. Answer: Every vessel in our waters should have access to a Departmental website where all relevant maritime laws and regulations are available. All vessels should be registered, pleasure craft included. Registration should mean that owners of such vessels understand their obligations. The coastguard could also publish television and radio ads providing information to sea goers. 5. Provide for enhanced engagement with international organisations such as IMO, ILO, EU Commission and EMSA to ensure Ireland’s interests are represented and ensure early input into the development of legislation impacting the maritime sector. Answer: Set up an international telecommunication mechanism with audio and visual links for discussions, with language services if necessary. Core Objective 2: Facilitate Maritime Trade and Connectivity Recommendations for inclusion in Maritime Strategy: 1. Ensure the appropriate policy framework is in place so that ports are enabled to provide, in a timely manner, the necessary capacity to meet the needs of the economy. Answer: We must make sure that any port development is not conflicting with residents interests, such as Ringaskiddy in Cork, where port development has been allowed to come extremely near residents homes. Port development must also make sure that port facilities do not take precedence over recreational areas which are vital in promoting people's health. Planning must be careful in not damaging residential areas when ports are developed. New ports away from residential areas could also be built. We seem to be getting carried away with existing natural ports and not looking to build new ones, which would allow more flexibility in design and increase this country's connectivity. 2. Enhance Ireland’s maritime connectivity by exploring the development of a policy framework that supports the creation of new routes and services. Answer: There are apparently no transatlantic passenger routes by sea. We have concentrated on European connectivity; chiefly Britain and France. This very narrow position needs to change. Discussion should begin with far more countries about bringing passenger services far beyond where they are now – which is only token. We have really failed to exploit our island national which is very sea accessible. 3. Promote the adoption across the maritime transport sector and agencies of emerging technologies to improve performance, economic competitiveness and sustainability. Answer: Every maritime vessel should have an email address. Delays and uncertainty in giving and receiving information cost money. 4. Explore the options available to DOT that would further promote and facilitate the development of Offshore Renewable Energy projects. Answer: This question needs more definition and is hard to answer. Our energy needs should not be that great with a small population and we should not get caught up in inter-country rat race to provide cheaper power to the EU grid. Core Objective 3: Deliver an effective Emergency Response (SAR and maritime casualty & pollution response) Recommendations for inclusion in Maritime Strategy: 1. Ensure an efficient and effective SAR coordination and response service in the Irish Search and Rescue Region, along the coasts and cliffs of Ireland, on inland waterways for which responsibility is assigned to IRCG, and in support of An Garda Síochána on major inland lakes and remote areas. Answer: Water safety is not taken as seriously as it should in this country and we are without doubt some of the most accident prone people in the world. Fishermen are a common casualty, who risk the lives in rough and dangerous seas unnecessarily – so they can beat their rivals. Maritime law should allow the government to ban vessels from going to sea by government directive on radio and television. Prevention is better than cure. Cliffs and other remote areas should have warning signs clearly posted for those who want to take unnecessary risks. 2. Provide strategic coordination, guidance and leadership for Ireland’s National SAR system as part of the National SAR Committee (NSARC), report to the Minister for Transport on an annual basis and address specific issues that may arise.