David MaBrayne Ltd
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.