948 VW

House of Commons
Transport Committee
The Coastguard,
Emergency Towing
Vessels and the
Maritime Incident
Response Group
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
transcom@parliament.uk
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 archives@parliament.uk). 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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Transport Committee: Evidence Ev w1
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
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Ev w2 Transport Committee: Evidence
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.
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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
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
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
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
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
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.
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.
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
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.
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
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 co-
ordinator 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.
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?
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.
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.
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.
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.
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.
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?
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.
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.
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.
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
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.
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
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;
(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.
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”.
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 night-
time (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.
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
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
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”
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;
— 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
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
Written evidence form Karen Paradise (MCA 24)
Question 1
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.
Question 2
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
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.
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.
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
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.
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
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?
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
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.
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
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
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
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.
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
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
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.
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.”
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
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.
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
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
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.
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.
— 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
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.
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
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,
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
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.
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.
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 Chapter 2
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.
Loading
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.
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
Number of teams
30
26
25 23 23 23
20 number of teams each MRCC deals with
20
17 17
15 15 15
15
12 13 13 13
10
10
0
Falmouth
Milford Haven
Brixham
Humber
London
Holyhead
Shetland
Yarmouth
Thames
Liverpool
Forth
Portland
Aberdeen
Dover
Solent
Swansea
Clyde
Stornoway
Belfast
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
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?

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,
— 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?

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
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
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
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.
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
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.
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.
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.
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.
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.
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. The
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
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
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.
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
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.
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 37
36
34 31
32 30
30 31 30 31 28 27
28 25 25 24 23
21 21 20
18 19
20
15 15
12 13 12
10 11
9 9
10
4
0
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
01
02
03
04
05
06
07
08
09
10
11
12
13
14
15
16
17
18
19
20
21
22
23
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
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.
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
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.
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
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.
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.
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.
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 pro-
active 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.
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.”
% 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% 5.55%
5.49%
4.60%
4.37% 4.44%
3.97%
4.00% 3.72%
3.58%
2.94%
2.55%
1.81% 1.92%
2.00%
0.00%
SHET STY FOR BEL MILF DOV HYHD LON YARM ABZ LVPL THAM PORT BXM CLY HUM SWAN FAL SOL
April 2011
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”
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.
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
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.
— 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.”
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
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.
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.
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.
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.
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.
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
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
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.
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;
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.
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.
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.
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.
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
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
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
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
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.
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 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.”
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
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
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
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
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 work-
load 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
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
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.
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
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
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.
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.
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.
Part 2—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.
— 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.
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
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.
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.
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.
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.
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.
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
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
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?
(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
— 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.
(D) Network Reliability

— 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.
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
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

— 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.
— 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).
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
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.
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
— 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
Totals 1 1 0 2 3
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.
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
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.
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
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.
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.
— 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.
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?
— 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
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.
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
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
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
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
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
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 re-
active 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
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.
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—
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
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
(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
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).
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;
— 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.
(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.
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.
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;
— 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.
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.
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
27
MIRG. [Online] available from
http://www.dft.gov.uk/mca/mcga07-home/emergencyresponse/mcga-hmcgsar-firefightingatsea.htm
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
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.
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
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.
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
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.
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).
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.
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.
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
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.
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.
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.
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
— 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.
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
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.
— 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.
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.
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.
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.
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
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.
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.
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.
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.
April 2011
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.
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
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
— 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
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
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
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
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<http://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.
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—
To: HARRY EDMONDSON To: Alan Massey
Sent: 12/05/2011 10:05:41
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
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.
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—
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.
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
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.
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.
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
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.
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
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
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
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.
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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House of Commons

Ordered by the House of Commons

Published on 23 June 2011

The Transport Committee is appointed by the House of Commons to examine

Angie Bray (Conservative, Ealing Central and Acton)

List of unprinted evidence

Save Stornoway Coastguard Campaign Team

Transport Committee: Evidence Ev w1

The need for better regulation

Ev w2 Transport Committee: Evidence

Transport Committee: Evidence Ev w3

The Irish subsidy and CIL’s costs

Ev w4 Transport Committee: Evidence

Written evidence from Angus MacNeil MP (MCA 03)

Further written evidence from Angus MacNeil MP (MCA 03a)

2. Loss of Tugboat Capacity

3. Loss of Nimrod Aircraft Coverage

Transport Committee: Evidence Ev w5

5. Potential New Scottish SAR Responsibility

6. Two Base Solution

Ev w6 Transport Committee: Evidence

8. Loss of Local Knowledge Tests and the Further Implications

9. Areas for Improvement

Transport Committee: Evidence Ev w7

10. Amount of Gaelic Speakers in Scotland

11. Future of the Coastguard in Scotland

Ev w8 Transport Committee: Evidence

Transport Committee: Evidence Ev w9

Ev w10 Transport Committee: Evidence

Transport Committee: Evidence Ev w11

Ev w12 Transport Committee: Evidence

Transport Committee: Evidence Ev w13

1.4 Local knowledge

Ev w14 Transport Committee: Evidence

2. Questions and Points to be Raised

Transport Committee: Evidence Ev w15

Ev w16 Transport Committee: Evidence

Transport Committee: Evidence Ev w17

3. Critique of the MCA’s Retrospective Risk Analysis

Risk 2: Skills fade causes mission failure by delayed or incorrect response

Ev w18 Transport Committee: Evidence

Risk 4: Non-observance of procedures causes mission failure by delayed or incorrect response

Transport Committee: Evidence Ev w19

Ev w20 Transport Committee: Evidence

Coastguard Rescue Service Risk Commentary

Transport Committee: Evidence Ev w21

Ev w22 Transport Committee: Evidence

Vessel Traffic Monitoring (VTM) Risk Commentary

Counter Pollution Risk Commentary

3.2 Risk overview table

3.3 Local knowledge: managing the risk

Transport Committee: Evidence Ev w23

3.4 Location impact assessment and sub-centre rationale

Further written evidence from Save Stornoway Coastguard Campaign Team

Written evidence from Steve Sim (MCA 11)

Ev w24 Transport Committee: Evidence

Written evidence from a Coastguard Officer (MCA 12a)