BLUEMOMENT

FROM THE CHAIRMAN - Peter Timms CBE

Our ref: PKT/AR/JAS



HM Coastguard Modernisation Consultation
Maritime and Coastguard Agency
Spring Place, Bay 2/13
105 Commercial Road
SOUTHAMPTON
SO15 1EG


Dear Sirs

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;

• 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.

Yours faithfully


Peter Timms
Chairman

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, i.e. 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 tasked to assist the French fishing vessel, Jack Abry II, 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 6 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.

P K Timms
Chairman
David MacBrayne Ltd
March 2011

Border Maid wrote:So good you had to post it thrice! Thanks for putting this up Nick. We can only hope that this is treated as a voice to be listened to.