House of Commons Transport Committee€¦ · House of Commons Transport Committee The Coastguard,...

Published on 11 December 2012 by authority of the House of Commons London: The Stationery Office Limited

House of Commons

Transport Committee

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

Sixth Report of Session 2010–12

Volume II

Additional written evidence

Ordered by the House of Commons to be published 12 September, 22 October, 12, 26 November 2012

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) Karen Lumley (Conservative, Redditch) Karl McCartney (Conservative, Lincoln) Iain Stewart (Conservative, Milton Keynes South) Graham Stringer (Labour, Blackley and Broughton) 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), Paul Maynard, (Conservative, Blackpool North and Cleveleys), Gavin Shuker (Labour/Co-operative, Luton South), Angela Smith (Labour, Penistone and Stocksbridge), Julian Sturdy (Conservative, York Outer)

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. The Reports of the Committee, the formal minutes relating to that report, oral evidence taken and some or all written evidence are available in a printed volume. Additional written evidence may be published on the internet only.

Committee staff

The current staff of the Committee are Mark Egan (Clerk), Farrah Bhatti (Second Clerk), Tony Catinella (Senior Committee Assistant), Adrian Hitchins (Committee Assistant), Stewart McIlvenna (Committee Support Assistant) and Hannah Pearce (Media Officer).

Contacts

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

List of additional written evidence

(published in Volume II on the Committee’s website www.parliament.uk/transcom)

1 Simon Dent Ev w1

2 Steve Sim Ev w1

3 Colin Tomlinson Ev w1

4 FIRE Project Ev w2

5 Clyde Branch of the PCS Ev w5

6 PCS member serving at MRCC Clyde Ev w9

7 Chris Jameson Ev w10

8 The Scottish Government Ev w13

9 National Coastguard SOS Campaign Group Ev w14

10 Ian McLean Ev w23

11 Toby Reynolds Ev w23

12 PCS Brixham Branch of the MCA Ev w24

13 Inverclyde Council Ev w25

14 Welsh Govenment Ev w27

15 Matthew Mace Ev w28

16 RNLI Ev w30

17 Louise Pooley and Mike Hillen Ev w30

18 Dennis Laird Ev w32

19 Outer Hebrides Coastguard Task Group Ev w32

20 Save Milford Haven Coastguard Campaign Ev w34

21 Murdo Macaulay Ev w36

22 Sandra Beech Ev w36

23 Martin Caton MP Ev w37

24 Richard Drax MP Ev w38

25 Dr Ian Mew Ev w42

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Transport Committee: Evidence Ev w1

Written evidence

Written evidence from Simon Dent (CFU 01)

As a member of the public I am concerned that areas of the UK are going to be left without an adequatecoastguard service by the governments proposed changes. The closure of 9 coastguard centres in my opinioncould cause a delay in existing stations reaching emergencies putting lives at risk. Also news that these centreswill close before the new facility is trialled and set up completely is quite alarming and will only add topeople’s fears. People want to feel safe when around the UK coastline and knowing there is a local coastguardwith knowledge of local tide information and the local area is vital to public confidence. I urge the committeeto review the closure plans in the interest of public safety and review all reports again.

August 2012

Written evidence from Steve Sim (CFU 02)

As a volunteer CG for almost 38 years (20 as Station Officer) I feel I must comment on the changes whichare happening to HMCG. We were told that the new CG would not effect the Rescue Service but after a shortspace of time it would seem the effects are already happening.

In our area our training has been cut from 40 hours per year to 24 with a new line management systemwhich is remote an inexperienced. CSM’s areas have become much larger, the decision making process hasbecome less involved with the troops and I have to say communication between the front line and themanagement team is becoming less and less.

I received an email to myself from our previous CSM of the smaller Liverpool District, explaining the hoursallowed for training which was in answer to a question I placed. The answer was honest and I feel appropriate.It can be seen that this senior manager felt at the time that training hours were still not enough but had secured31 hours nationally and an extra 10 hours for the area. Only this week we are told that the hours are now 24per year, not enough to secure the safe health and safety of CRO’s who’s competencies get more arduous anddetailed as the years go on. CRO’s undertake coastal rescue, with cliff mud and water rescue implications, theCRO and the casualty safety seem to be compromised with the cut in training.

The agency has being shouting from the roof tops that extra full time staff will increase the skills of theCRO but less training hours and poor communication need to be addressed before the increased costs in thenew management system of the CR Service.

HMCG has been in my blood since I was 16 and as a volunteer have seen many changes, but it would seemthat the present management are even more remote and listen even less. Perhaps you should take verbalevidence from some of the volunteers as the great Mrs Dunwoody did at Liverpool many years ago. A numberof us gave evidence at the MRSC she listened to the coal face and was a delight to meet.

August 2012

Written evidence from Colin Tomlinson (CFU 03)

As a serving Coastguard Officer of more than 39 years I have witnessed many changes in the Service, andthe closure of MRCCs has always been with us.

In my time we have gone from over 300 coastguard stations to 28 Rescue centres down to 18 before thereorganization proposals. These proposals are a long time coming and the reorganisation should have been putinto progress earlier rather than later.

I am not sure I agree with the location of all those stations which are to remain open nor those that are setto close, nor do I agree with all of the closure proposals.

However as the Manager of Yarmouth MRCC, I can honestly state that the work stream has indicated overthe years a slowdown of coastal incidents to such an extent that we are running 50% less then we were fiveyears ago. A large proportion of these incidents are now being dealt with by RNLI Lifeguards , a service thatis saving lives each day.

My view is that the closures are taking to long, staff at my station are now leaving to find new jobs, orremaining for the payout depending on their outlook and status. I have now the unenviable task of trying tokeep morale high, with low staffing levels and staff that unless they move with the job will be out of work thistime next year.

It is my view that HMCG should strive to move forward as quickly as possible to ensure we retain as manystaff as we can with the skills required for the new roles that they face.

The world has moved on and the service needs to move on or stagnate.

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Ev w2 Transport Committee: Evidence

The CEO should be given full support from Government with a message that finance is available andprovided to ensure we end up with a service for the future.

August 2012

Written evidence from FIRE Project (CFU 04)

1. The maritime safety coverage of the British Isles and further waters is unusually rich but, changes, to anyone part of that coverage, have the capacity to make a significant impact on the other organizations involvedin saving life and increasing safety on water. In looking at a reduction of Coastguard Stations to save costs,there is need to consider how this service interacts with all of the other available SAR services, most of whichare funded by the public and by corporate sponsorship and gifts.

2. The British Isles are fortunate in having the RNLI as an independent organization funded by donationsand free of short-term political interference. The RNLI provides coverage for the entire British Isles, includingthe Republic of Ireland, with a range of maritime and flood rescue skills and equipment. It is therefore atrans-national service that can also be considered international, because of its relationships with other rescueorganizations around the world and the help it offers many of these services in training and equipment. TheRNLI is enthusiastically and loyally supported by the British public, forming a potentially powerful lobby.

3. The military also provide a very capable SAR support in the form of FAA and RAF SAR helicopters andthe ability of warships, with their embarked helicopters, to respond to maritime incidents. Even if the militaryis relieved of civil helicopter SAR responsibilities, there remains the need for those services in support ofmilitary operations. It is difficult to conceive a situation where a SAR contractor would provide helicopters torescue a British serviceman in some distant corner of the globe in time of war. Military aviators not onlyprovide a very highly skilled service to civilians in the British Isles, but they receive constant training in theprocess to equip them for a military rescue.

4. There are a number of independent lifeboat services that have been created to fill perceived gaps in safetycoverage, including independent hovercraft. This demonstrates that even the RNLI is unable to provide for alllocal needs, proving that small can be beautiful and efficient. However, there is a need to be able to integratethe independent services into the wider SAR community during incidents.

5. The growth in the number of Air Ambulance services equipped with helicopters and funded by donationshas added a further dimension to maritime safety coverage by providing the means to rush casualties to hospitalfrom the beach or from shore recovery locations after other rescue providers have effected the initial rescue atsea. These aircraft are also loyally and enthusiastically supported by the public and corporate sponsorshiprather than from the public purse.

6. The Coastguard service provides a range of services including shore rescue and SAR helicopters. Someof these services duplicate the services of other organizations and although British SAR organizations have anexcellent record of working together, it raises the question of whether Coastguard funding is being best spentin all of its areas of operation. There is a limit to how far an intelligent geographic information system canprovide local knowledge. In police experience there have been incidents where a police officer has had to dealwith a serious incident unaided because the centralized force geo information system has sent thereinforcements to a very different location, when a local controller would have avoided that potentially lethalerror.

7. In addition to all of the hard working and capable SAR organizations, there are many rescue organizationsthat may concentrate on non-maritime rescue but have some capability to support maritime rescuers, and thisincludes water rescue dogs, in much the same way that maritime SAR services have been deployed inlandduring major flooding.

8. This very diverse range of rescue services is largely free of political involvement because it depends onfunds donated by the public and by company sponsorship, where most of these organizations receive noGovernment funding in any form. However, they do require a professional command and control system toenable them to deploy efficiently to deal with incidents. The real question is not how to shave Governmentcosts, but how to best provide each of the elements, that make up this composite safety and rescue service, inthe most cost effective manner.

9. The current starting point for a review of Coastguard services appears to be a very crude political andeconomic need to cut public spending. Looking from the outside there is very little evidence that the currentGovernment intentions, to eviscerate the Coast Guard stations and personnel, has any operational merit and infact creates a serious threat to all SAR services. Added to this is an intention to further cut costs by removingthe SAR role from the FAA and RAF. It demonstrates an accountant’s approach without the benefit of asensible operational review. In view of the relatively trivial amount of money involved, when compared to theforeign aid that is lavished on countries that can afford nuclear weapons and space exploration programmes,or where democracy is absent and the money goes into Swiss bank accounts, there seems little need to rush tojudgement on such an important British issue that represents a relatively modest funding requirement, directlyaffecting British lives and welfare.

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10. There is also the question of whether the responsibility for a review should be conducted by aGovernment Department or Committee when there is inevitably the suspicion that the department andpoliticians will simply find a form of words to justify a political act in an area where public donation hasalready taken responsibility for a significant percentage of overall cost, and at a time when budget cut backsare forcing a priority for premature actions.

11. Key to published plans is the belief that a central command and control system removes the need forCoastguard stations and personnel. This is surprising in view of the costly failed attempts to replace FireService control rooms with regional centres, leading to very expensive buildings that have never been used. InPolice service similar centralization has presented many problems that have been inadequately dealt with. Itgives our group no satisfaction to have made submissions to Government in respect of police and fire costcutting on control systems and been proved correct in our observations, rather that we are deeply saddenedthat our suggestions, and similar suggestions from others, have been ignored in favour of what were perceivedas political advantages. It is questionable that the political advantages were real, but it is certain that peoplesuffered injury and death as a result of poorly thought out and badly managed changes to first responderservices.

12. Technically, a single system introduced by the IMO, to cover the entire European Atlantic seaboard ispossible, completely removing the need for the UK to provide this service through the Coastguard. Howeverthere is a wealth of difference between what is technically possible and what is functionally desirable. Thereare, each year, examples where Falmouth Coastguard co-ordinate rescues on the other side of the world, wherethe IMO already has co-ordination centres. The more intelligent approach is to build local command modulesthat can interface with other modules. This means that each module is designed to serve a local need, but becapable of forming an element of a larger system that proportionally responds to a larger, or moregeographically complex, need. This makes each module manageable, affordable, flexible and appropriate. Ineffect the complete opposite of huge systems that inevitably fail spectacularly and expensively.

13. The US Coast Guard is implementing the Rescue 21 system to cover the entire US coastlines (includingcoastlines beyond CONUS). The FIRE Project offers this as an example of methods that can be employedfrom a range of potential options. The US situation differs from the UK in a number of respects, but USpoliticians have made as much of a mess of the US economy as British politicians have achieved for the UKeconomy and have as much need to desperately cut public spending.

14. When the previous UK Coastguard cutbacks were implemented to save costs, the public responded bysetting up and supporting financially a number of Coast Watch stations to replace those closed Coastguardstations. It can be argued that both the Government cuts and the public response were not the most efficientway to approach the situation. There is potential for any new cuts to be met by a charitable response to takeover former Coastguard watch stations, or to establish new and, possibly, better-sited CoastWatch stations.Such a move would add to confusion in a SAR service that demands clarity and could end up producing tworival services in an environment where co-operation is essential.

15. This comes back to the central issue of how SAR coverage in the UK needs, and demands, a carefulconsideration that is non-political and conducted at a speed that ensures each issue is addressed within acomplex mix of inter dependent services and resources. To avoid political decisions costing lives and movingthe costs elsewhere more rapidly than alternative funding can be set up, the review must be, and seen to be,wide-ranging, thorough and impartial.

16. There are issues already surrounding existing charitable SAR. If the number of launches are reviewedover a short period for RNLI lifeboats and hovercraft, it will be seen that today there are relatively few launchesto larger commercial vessels, where this was once a major part of RNLI activity. Of those that do take place,most are to fishing vessels and, if carefully analysed, it can be seen that the reasons for the incidents arefrequently the result of inadequate maintenance that is a consequence of the decimation of the British fishingindustry in favour of fishing fleets from other countries. Another frequent call on RNLI services is to supportpolice where a distressed person is threatening to jump into the water or has already jumped, requiring rescueor, more frequently, recovery of the body. Although the RNLI has demonstrated a desire to remain free ofinterference by accepting public funds, it does seem grossly unfair that a charitable organization is so frequentlyrequired to fill a gap caused by political cost cutting. There is now a new expanding underwater rescue service,outside both the RNLI and the public services, that in part is necessary because police underwater search teamshave suffered from cutbacks. Unfortunately, these cuts are frequently the result of placing other matters at ahigher priority. One example is the situation where a police force decided that it had a duty to fly gay prideflags from its police stations and health and safety required the involvement of three police officers to raiseeach flag. It does not seem to have occurred to the Chief Constable that the first priority should have been thedelivery of public order and safety services.

17. The real starting point for a review of Coastguard services should have been a review of theappropriateness of the current range of services. The UK now has a collection of organizations paid from thepublic purse and which overlap and sometimes compete with the services of their sister organizations. Today,it might be more appropriate for sections of Coastguard services to be taken over by the charitable sector. Thismight not involve the services being allocated to any existing organization, such as the RNLI, but require theformation of a new charity that can then focus its fundraising and efforts to best executing the duties passed



to it. At present, there is an active campaign conducted by Coastguard personnel against the cuts, whichinevitably and reasonably is partly prompted by their fears for their future employment. That can mask somevery valid opposition from a group of people who have years of experience in dealing with maritime incidents.

18. Coastguard stations provide experienced eyes to look for local emergencies and local Coastguard radioprovides coverage in VHF within the range of relatively small vessels that may be in distress. That coveragecan of course be provided at least as effectively and perhaps in greater coverage density by a charitableorganization, but it would be a serious mistake to close down a publicly funded coastwatch station in the hopethat any local need will prompt either an existing charity to take on the duties, or for a new charity to befounded. The RNLI already has a very large network of lifeboat stations and beach watch towers, so that thereis some potential for those structures to be developed to provide a very high grade coastwatch for safetypurposes and provide shore radio points. Whether it is in the best interests of the RNLI to take on thisresponsibility is another matter and the complete coverage would need to involve independent services, someof which have been set up to fill holes left by RNLI cutbacks and restructuring. The fact remains that, evenwhere coverage extends to seaward, mobile phones are not the best communications devices for craft andVHF radio is a very important safety aid, but one which has a limited radius of coverage from any singleradio transceiver.

19. Looking just at how many Coastguard stations to cut ignores what could be much greater saving thatwould also result in improved safety services. Looking only at the Coastguard provision ignores theopportunities and needs that would be deeply affected by changes in Coastguard capabilities.

20. Careful study of the Coastguard might indicate that it should not be responsible for providing any SARhelicopter coverage at significant public purse saving, although the cost must be carried somewhere. Whoeverprovides SAR helicopter coverage would benefit from the availability of FAA and RAF military SARhelicopters, just as those services would benefit from the continuing training that comes from being involvedin SAR incidents.. There is equally the argument that British military SAR helicopters should be significantlyupgraded for combat rescue to include in-flight refuelling capability and that this would provide a specialistSAR capability for incidents beyond the range of existing British shore-based SAR helicopters. Currently,British rescue capability depends on the USAF to offer the services of their SOG teams at RAF Mildenhallwho do have suitable helicopters and tankers but might be moved out of Britain in the near future as the USFederal Government attempts to cut costs and respond to an increasingly serious situation in the Pacific andSeas of South East Asia.

21. There are potentially great opportunities for expanding the range of services provided by Air Ambulancecharities. They currently hire helicopters and crew from commercial operators and then manage the resourcetogether with volunteer paramedics and doctors. The contractor providing the helicopter usually has experienceof providing SAR capabilities on other contracts. In the same way, police helicopters have been provided bycontractors supplying the aircraft and crews, and may conduct a SAR mission in addition to the obvious dutyof providing a policing service.

22. What seems to have been completely overlooked are the new opportunities provided by newcommunications and information technology. Today it is entirely practical to create a national EmergencyOperations Service that uses the Internet, with or without private networks alongside, to link a host of localcontrol centres that use a common interface. To work, the new environment would need to establish thebackbone system that might be funded from the public purse. Provided that the operational protocols andinterfaces were carefully drawn, any first responder organization could provide its own local equipment at itsown costand use its own choice of supplier. The local organization could be any first responder and includeencryption and compartmentalization technologies to provide essential separation of some functions. Thisflexibility addresses all the political desires to cut public expenses, provides a vastly greater capability, respectsthe differences of each first responder organization, but allows all to work together in any one of many agreedcombinations to best tackle each specific incident.

23. To an extent this happens imperfectly in the case of maritime incidents. An emergency telephone call orradio call is made available to the Coastguard. The Coastguard then decides which of the resources availableshould be launched and these resources may include no Coastguard resources beyond incident coordination. Inthe same way, a call to police may result in the police asking an Air Ambulance charity, or the RNLI, to launcha response unit. The method of communication is most frequently by public telephone services.

24. If the principle of a national communications and information environment is accepted, the review ofthe Coastguard service takes on a completely different approach. Coastguard duties might be reduced toproviding maritime incident response co-ordination. The actual responders may no longer include Coastguardpersonnel. That frees the national incident response to become an Emergency Operations Centre system whereany incident can escalate from very local control to a single co-ordinating centre that can call on many specialservices including military personnel, decontamination capabilities, medical support from hospitals or CDCservices, etc.

25. There are dangers in this approach. Politicians have the inclination to turn this into a huge, single, micro-managed mess that places a single massive contract that inevitably becomes a costly failure, as demonstratedby contracts already placed by HMG during the last seventeen years. Even more unproductively, there can bea desire to take over control with a massive bureaucracy. However, these serious risks can be avoided. Provided



that each first responder organization is free to control its own destiny and fund its own operations, massivedemand on the public purse is avoided and the level of capability is increased significantly. In the same way itis important to provide the flexibility for new local services and organizations to come into the system to addto the local capabilities most efficiently.

26. In responding to this Committee, the FIRE Project has avoided discussion of specific technologies orsuppliers because an adequate discussion would have been beyond the space available and because the criticaldecisions now are of whether the Coastguard service is to be butchered without adequate consideration of howits current capabilities are replaced. However, the FIRE Project volunteers have extensive experience ofmilitary, intelligence and civil command, control and EOC systems and of technologies that are only recentlyavailable that would provide great flexibility and resilience at relatively low costs.

August 2012

Written evidence from the Clyde Branch of the PCS (CFU 05)

1. Background

1.1 The Maritime & Coastguard Agency (MCA) currently has five Maritime Rescue Co-ordination Centres(MRCC) in Scotland, Shetland, Stornoway, Forth, Aberdeen and Clyde. Under government proposals MRCCClyde will close by the end of 2012 with a loss of 28 coastguard jobs.

1.2 The Public and Commercial services Union (PCS) believes that the coastline of the west of Scotland isdifferent to that of that of the rest of the UK and the loss of this key station will result in a danger toScottish shipping and the general public. We believe that the Transport Select Committee should investigatethe government’s proposals on search and rescue in Scotland and the concerns of Coastguard Officers andtheir Union.

2. Maritime Incident Response Group

2.1 The Maritime Incident Response Group (MIRG) was a partnership formed between the MCA and Fireand Rescue Service in 2006, the purpose of which was to tackle incidents involving fire, chemical or rescueteams at sea. Fifteen Fire and Rescue Services were training to provide a response.

2.2 The majority of MRCC Clyde’s area was covered by Strathclyde Fire and Rescue Service and jointexercises were undertaken to rehearse the procedures for calling out and deploying the Strathclyde MIRG team.However there has only been one instance which could have required the attendance of MIRG. This was thefire on the Yeoman Bontrup at Glensanda Quarry on 2 July 2010. This was in the area covered by Highlandsand Islands Fire and Rescue. As the incident happened alongside and not at sea. MIRG would have beenmobilised by the Highlands and Islands Fire and Rescue.

2.3 Official statistics indicate that there were only a further 6 incidents requiring the intervention of MIRG,but the extent of the MIRG’s involvement in these incidents is not known to the staff at Clyde. It would appearthat a lot of funding was allocated for little benefit. Should these funds have been better spent?

3. Emergency Towing Vessels

3.1 As this submission is from MRCC Clyde we will restrict our comments to the ETVs based on theScottish coast.

3.2 The provision of Emergency Towing Vessels was recommended by Lord Donaldson following the breakdown, subsequent grounding and spilling of 85,000 tonnes of crude oil by the M.V. Braer on the Shetland Islesin 1993.

3.3 Since then, there have been significant improvements in construction and technology eg the introductionof double hulled tankers and the ability to track vessels using Automatic Identification of Ships (AIS). Whathas not changed is the weather and the remoteness of the waters around the west and north of Scotland.

3.4 The three main centres from which tugs would be dispatched to incidents in the north and west ofScotland are Aberdeen, Sullom Voe and Greenock, but suitable tugs are not always available.

3.5 The recommended deep water route for laden tankers off the Western Isles runs between five and 20nautical miles from the coast. Any vessel breaking down in this route would be pushed towards the Islands bythe prevailing winds. An estimate of the drift rate due to the wind would be 3% of the wind speed, Gale forcewinds, which are common in this area, are up to 40 knots, giving a drift rate of 1.2 knots, and tidal flow mayincrease this rate. This would mean that a vessel may be driven ashore in less than five hours.

3.6 Sollum Voe and Greenock are, respectively closer to the north and south ends of the deep water routeand would take 13 hours by a vessel doing 15 knots to reach these positions. The deep water route runs for120 nautical mile. An additional eight hours steaming therefore would be required to reach the other end ofthe route. The maths make it unlikely that a tug for either place would be able to reach a drifting vessel beforeit goes ashore.



3.7 Aberdeen, the main centre for vessels capable of carrying out towing operations on large tankers, is evenfurther away and would take longer to reach the Western Isles deep water Route.

3.8 The Scottish Government has retained an ETV, which is based at present, in Kirkwall. This is eighthours steaming to the north end of the deep water route, but again, would be unlikely to reach a drifting vesselbefore it goes ashore.

3.9 The retention of an emergency towing vessel off the west coast of Scotland may save the nation millionsof pounds by avoiding the need to clean up millions of barrels of crude oil from our beautiful coasts and savethe jobs of fishermen and fish farmers who contribute to the local and national economy.

4. Staffing

4.1 At present the risk assessed levels during the summer months at Clyde, Stornoway and Belfast are asfollows: Clyde: six day and five night staff, Stornoway: four staff on duty, Belfast: four staff on duty.

4.2 The reasons given for this are as follows:

— The predicted workload at each station, emergency calls and routine work.

— The ability to be able to handle any major search and rescue operation at the outset within presentstaffing levels.

— Number of radio channels which have to be monitored and the amount of traffic on those channels.

4.3 After 31 December, both Rescue Co-ordination Centre Managers (RCCM) at Belfast and Stornowayhave indicated that they would wish 12 staff from Clyde to transfer to either station. This is to provideexperienced coastguard officers with knowledge of the Clyde district to help support the staff at these stations.

4.4 The minister has said in letters to MPs that there will be no degradation in the service during thetransitional period. Indications are that no member of staff from Clyde is volunteering to do detached duty atStornoway and only 3 at Belfast, one of whom will only be there for a few months.

4.5 The Coastguards Integrated Command and Control System (ICCS) has capacity for 15 aerial sites all ofwhich are currently used by Clyde Coastguard, 14 by Stornoway Coastguard and seven by Belfast Coastguard.In order for Stornoway to have radio coverage of the new area an additional 6 aerial sites will have to be madeavailable. The remaining nine aerial sites will go to Belfast. To facilitate this an additional system will have tobe introduced at each station. While this system will be related to ICCS, it will have reduced functionality andcapability. The additional system will not be able to display vital details such as names and addresses of callerson landlines nor numbers and geographic locations of mobile calls when 999 calls come in. These details arevital to identify both locations of casualties and origins of hoax calls.

4.6 Mr Penning has repeatedly stated that Local Knowledge lies with the paired station. Stornoway has neverbeen paired with Clyde and therefore has no Local Knowledge of that area. Local Knowledge will be gained,perhaps tragically, over a number of years but in the meantime there will be a severe degradation of the service.

4.7 The Chief Executive Officer and the Chief Coastguard have said on at least two occasions, that it isundesirable to close MRCC Clyde down in the timeframe imposed on them.

4.8 Most MRCCs are not closing until the maritime operations centre is up and running.

5. Clyde Coastguard Station

5.1 The Maritime Rescue and Coastguard Centre (MRCC) in Clyde currently has 27 posts. Three posts havealready been transferred to Belfast. At present, there are 19.5 posts occupied with one member of staff onsecondment to the coastal side of the service, four others are on maternity or sick leave.

5.2 Clyde MRCC operational area runs from the Mull of Galloway in the south to Ardnamurchan Pointincluding the River Clyde to the centre of Glasgow, numerous sea lochs and the Caledonian Canal as far eastas Fort Augustus. This is 360,000 square nautical miles of sea and 2,500 miles of coastline, approximately thesame as France.

5.3 The indications from MCA management are that on 18 November work from Clyde MRCC will betransferred to Belfast and Stornoway and the station will cease to function as a MRCC on the 31 December2012. Despite the memorandum of temporary occupation (MOTO) with the MoD expiring in March 2013. Webelieve the MoD have given indications that the MCA can remain if they are willing to pay costs to run thebuilding. MCA do not seem to be willing to take up this offer.

5.4 It is our opinion the MCA do not wish to explore this option, believing that closing the station will savemoney. However, the cost of transferring Clyde to Belfast and Stornoway for the time it takes to get the newNational Maritime Operations Centre (NMOC) operational is likely to be more than retaining the centre at|Clyde for the next two years.



6. Local Knowledge

6.1 The Minister has quite clearly stated that Local Knowledge is held by the paired station. This is untrueas there have been very few occasions either Clyde or Belfast has taken over the area of the other. SeniorManagement and Coastguard Officers at both stations have been calling for Local Knowledge training having,initially denied that it was needed.

6.2 Clyde district has the highest percentage of ferry routes within the UK. These routes are essential to theisland communities that lie off the west coast. Good liaison has been built up with both Strathclyde Police andFire Services and the experience gained working together is going to be lost and will take many years toregain. Technology cannot replace experience.

6.3 Stornoway MRCC has not been linked to any other station and therefore has had no local knowledgetraining or exposure to incidents. Clyde Coastguard is the busiest coastguard station in Scotland with incidentnumbers peaking during the summer months mainly from the leisure user.

6.4 The MCA’s proposals do not meet the needs of the leisure user, as relatively few have purchasedautomatic identification systems which are compulsory on large vessels. In many areas of the west coast thesesystems do not work due to the topography. Mobile phone information from 999 calls can give false locationsdue again to the remoteness and lack of infrastructure.

6.5 The minister Mike Penning has again stated this in Parliament when asked the following by AngusRobertson: To ask the Secretary of State for Transport on how many occasions each maritime coastguardstation has taken over complete operational control of its paired station for a period of more than two hours;and during times of pairing how many rescue incidents were dealt with successfully, in each of the last fiveyears. [114542].

Mike Penning: The current pairing arrangements—the Area Operations concept where two MRCC aretechnically and operationally capable of mutual support—were introduced in 2005. These arrangements are aninnate aspect of current HM Coastguard operations and happen on a regular basis and therefore the Maritimeand Coastguard Agency does not keep records of instances where pairing is undertaken on operational grounds.

6.6 What the figures say is that since 2005 Clyde has taken over from Belfast on 11 occasions for 28.8 hoursand dealt with five incidents. Belfast has taken over Clyde on 14 occasions for 31.85 hours and dealt with fourincidents. (Figures correct as of June 2012).

6.7 In 6.5 years this means that Belfast have taken over Clyde an average of once every seven months, I amsure you will agree that this is inadequate. Belfast have taken control of Clyde’s area only on one occasionsince June 2010. This can hardly be seen as a “regular basis”. (Figures correct as of June 2012).

6.8 Mike Penning has also sought to give reassurances in response to questioning by stating that the newMaritime Operation Centre in Fareham will open before the closures happen. However, Fareham will not beoperational until 2014 at the earliest by which time Clyde and Forth will have closed.

22 Nov 2011 : Column 162

Mike Penning: I thank my hon. Friend for her important question. One point in having Fareham open soearly is that we will be able to trial the new system early, which will mean that no centres will close beforethe robustness of the system is demonstrated. Should there be any blips in the system, I can assure my hon.Friend that no station will close until we have the level of resilience that we do not have today.

7. PCS Concerns about the Closure

7.1 The only risk assessment completed has been the generic risk assessment covering the whole of themodernisation of the coastguard service. No individual risk assessment has been completed for the closure, orthe transition period, of MRCC Clyde.

7.2 There is no back up from a national network during the transitional phase.

7.3 Assurances have been given that the quality of the service will not be affected. However, the MCAcannot assure PCS that adequate staff will be available at Belfast and Stornoway. The number of staff, even ifstaffing levels are achieved at Stornoway and Belfast, will be below the present levels within the north westquadrant (the geographical area that covers Belfast, Clyde and Stornoway area of operation). At present therecommended levels of staffing are Clyde five/six staff, Belfast and Stornoway four staff on watch so for thequadrant that would be 13. Under current MCA plans, the best they could achieve taking into account leave,sickness and training would be 10. Therefore during the transitional phase there would be an overall reductionin staffing levels.

7.4 Belfast and Stornoway are requesting seven staff on watch—however, at present they only have fivework stations each.

7.5 To date no responses have been forthcoming to the thousands of letters sent by members of the publicto both Phillip Hammond, the then Secretary of State for Transport, and more recently Justine Greening, askingfor reassurances that the closure of Clyde coastguard would not put people’s lives at risk.



7.6 It appears that the MCA are spending more on the transitional period with taking equipment to Belfastand Stornoway than it would cost to retain Clyde MRCC. New infrastructure will then have to be put in againonce the national network is up and running.

7.7 The first piece of equipment to be transferred from Clyde to Belfast was the MF radio on the 21December 2011. The first fault with the equipment was raised on the 22 December 2011. Further faults wereraised 23 December, 6 January 2012, 25 January, 16 February, 20 February, 15 March, 11 April, 13 April, 26April, 31 May and the 30 July. On the 7 June a Navigational Warning was issued by the Hydrographer (WZ764) stating MF services from Tiree site inoperative. This was replaced by WZ 952 on 19 July and remainedin force until 15 August. This is clearly a degradation of the service to the mariner.

7.8 This follows on from the removal of Very High Frequency Direction Finding (VHF DF) which wasremoved from all stations in December 2010. This was a useful asset removed without any consultation withoperational staff.

7.9 Clyde district is the largest district, coast wise, and the second largest area wise. Staff at both Stornowayand Belfast will be given six weeks of training on the new area. This is not adequate to learn the most complexdistrict with regard to topography in the UK and build up liaison arrangements with other authorities.

7.10 No trials of the proposed structure have been carried out over any length of time and there are noassurances that either Stornoway or Belfast MRCC would be able to cope with the demand unless resourcesare increased. The early indications are that only three people will move to Belfast from Clyde ranging for afew months until retirement, to one person possibly moving permanently during the transitional period.

7.11 The Minister for Shipping gave assurances that no station would close until the new system was upand running for at least six months. However, this does not apply to Clyde or Forth coastguard stations. Theonly reason given for Clyde is that the MOTO will have expired. Our contention is that the building is ownedby the government so there is no reason why the building cannot be retained until the new national networkhas at least been tested.

7.12 The cost of staff going on detached duty from MRCC Clyde will be approx £750 per week. MCArequire additional staff during the transitional phase. We believe retaining Clyde would be the most costeffective option.

7.13 It appears that the MOD has not put the building up for sale at present. There is no demand for propertyat present within Inverclyde where many sites are unoccupied. A failure at either or Belfast or Stornowayduring the transitional phase will mean that even larger areas would be without effective radio coverage.

8. Transition Period

8.1 This period is without doubt the most dangerous time of all. The area of MRCC Clyde, the largest, andthird busiest, in the country, is to be divided between MRCC Belfast the smallest area in the country andMRCC Stornoway, one of the quietest in the country.

8.2 The majority of staff at Clyde is unconvinced of the MCA’s arguments for the closure of the MRCC andas such shows little appetite to assist in the closure program. It is thought that the decision is entirely politicaland makes no consideration for the operational requirements for the people of the west of Scotland.

8.3 One irrefutably consequence of transferring Clyde’s northern aerials to Stornoway is that they will bemore vulnerable to outages as the communications link to the Western Isles have over the years suffered manymore major failures than those to the MRCC Clyde. If this happens in the transitional period many more peoplewill suffer from a reduced service.

9. Conclusion

9.1 We are far from being alone in believing that closing Clyde is the wrong decision. PCS’s public meetingin June was well attended by both the public and politicians. There is cross party support for our campaign.Shipping authorities and fellow maritime unions are against the closure and all the councils within the westand south west of Scotland have pledged their support to campaign against the closure.

9.2 PCS would welcome moves by the Transport Select Committee to scrutinise the coastguard stationclosures. If the closure of Clyde is allowed to go ahead it will seriously undermine attempts to ensure publicsafety in the waters around Scotland.

9.3 In Scotland there is cross party political support from MPs, MSPs and Councilors against the MCA aproposal all citing that political decisions should not override operational ones.

9.4 Both consultation documents were flawed as neither considered the retention of Clyde Coastguard.

9.5 The building is owned by the government. Will lives be put at risk because one department wants toasset strip a site and the other does not want to look at alternatives?

September 2012



Written evidence from a PCS member serving at MRCC Clyde (CFU 06)

1. On 1 June 2012, I was informed by e-mail that the responsibility for coastguard operations at MRCCClyde would be transferred to MRCC Belfast from 1000–1600 on the 7 and from 0900–1300 on the 8.

Following consultation with the union, I was informed that, as this was an exercise, it was subject to industrialaction. This was confirmed to me on the evening of 6 June. On the morning of 7 June, I informed the RescueCoordination Centre Managers (RCCM) at both Clyde and Belfast, that, due to industrial action, I would notbe handing over coordination to MRCC Belfast. The reaction from the RCCM at Belfast was bordering onhysterical. Subsequently, at an interview, with the Coastal Safety Manager, I expressed my disappointment withthe reaction of the RCCM from Belfast, who is himself a union member.

2. On 22 June, I was once again informed by email that control of Clyde Coastguard would be transferredto Belfast on the 9 and 10 July again from 1000–1600 on day 1 and 0830–1330 on day 2. As the nominatedofficer in charge of the Operations Room at MRCC Clyde, at no time was I included in discussions as towhether I would be in agreement with this, nor was I privy to any contingency plans, if things went wrong.

3. On the morning of the 9, I was approached by my line manager to remind me that the handover wouldtake place. At 0900 my line manager appeared for the morning briefing, soon followed by his line manager.This was interpreted by me and my staff, who were all present, that we were being subjected to intimidationif we refused. After a discussion with my watch we decided to accede under protest, as we suspected that analternative strategy had been prepared and that any refusal would be held against those who would wish tocontinue their career with the MCA. I and my watch have not been requested to take part in any more exercises.

4. For these two days there were no alternative tasks allocated to myself or my staff. When I suggested thatsomething should have been put in place the transitional planning manager suggested it would be a goodopportunity for the staff at Clyde to visit the Job Centre. This response was deemed by everyone to be crass,uncaring and downright insensitive.

5. The MCA have since solicited the wishes of the staff with regard to their future wishes, which were:

1. Transfer to another MRCC/MOC.

2. Transfer to Coastal Operations.

3. Transfer to another part of the MCA.

4. Transfer to another part of DfT or the Civil Service.

5. Redundancy.

6. Redundancy following a period of detached duty.

7. Detached duty then join the new structure.

6 As you would expect a variety of, and multiple, answers were given and I cannot give categoricalanswers to personal responses, but it appears that no one chose options 1 or 7.

7 Most people gave a number of options between 2 and 6. One particular member of staff gave options2, 3, 4 and 5. However, when confirmation was returned from Human Resources the person was putdown as wishing to do detached duty at Belfast. When they confronted HR on this, they were toldthat “anyone who had not chosen a station was given Belfast to make the figures look better.

8 The MCA are therefore attempting to massage numbers which will give a false expectation of whatwill eventually happen. The following is a more accurate picture:

— At present there is 26 watch keeping staff at Clyde.

— Of those, 15 will leave the service by retiring or taking redundancy.

— One person is on secondment to the coastal side and would hope to gain permanent employmentin that sector, failing that they will take redundancy.

— One would like to remain in the service but is unable to move to another location and may beforced to take redundancy.

— This leaves nine staff who will take up detached duty post at other stations, four at Aberdeen,two at Liverpool and three at Belfast.

— Of the three going to Belfast 1 intends to retire three months into the New Year. A second ofthe trio is now looking at an opportunity to do detached duty in London which leaves oneperson from Clyde at Belfast and no one at Stornoway.

9 After almost 25 years as a Coastguard Officer and having spent time at each of the stations serving theWest of Scotland I had hoped to complete my remaining years doing the same. However, I have taken thedecision to spend my final two years at Aberdeen because I consider that the decision to close MRCC Clydeand divide the work load between Belfast and Stornoway to be seriously and fatefully flawed.

10 The increased workload, I believe, will cause excessive stress, resulting in increased pressure to doovertime to cover the shortfall created by a lack of qualified staff from Clyde refusing to transfer; longer hoursmean tired staff and the increased probability of making mistakes. In a profession that requires the initial



decision, in any incident, to be the right decision. I fear that the closure of MRCC Clyde, before the NationalMaritime Operations Centre is fully operational, will lead to loss of life.

September 2012

Written evidence from Chris Jameson (CC 07)

1. Executive Summary

1.1. This is the submission from a “coastal resident” raising issues that are of concern to the average personand as such; be of profound importance as we are ultimately the “customer” and the main funding source.

1.2. Many of the large organisations involved with the consultation appear to be focused on politics andtheir working relationships with Maritime and Coastguard Agency, in so doing, failing to comment objectivelyon the future of HM Coastguard.

1.3. Assurances on safety have been made about the changes to HMCG which are repeatedly being ignoredor abandoned.

1.4. Promised technical capabilities do not ring true or have a “real world” basis, too much reliance onunproven systems.

1.5. Confidence in the MCA to modernise HMCG is at an all time low with expectance that tragedy willoccur as a direct result.

2. Introduction

2.1. I have lived all my live (50+years) in a coastal town and been involved with coastal activities at anearly age. I consider that I have respect for the sea and the dangers it can offer, my involvements in coastalsafety matters are: as a shoreline supporter of the RNLI & raising funds/donations for them, working as aDesign Engineer on water safety products, and since September 2011 involved with the Coastguard SOScampaign.

2.2. I fear that the core objectives that HMCG need to meet has been failed, that is why I have taken issuewith the current plan both as an individual and a campaigner with the Coastguard SOS group.

2.3. My aim is to put a simple common sense perspective on the areas I feel that the plan fails me and thecoastal community I live in.

2.4. Some of the observations I make are from the research I have done into the public records of the MCA.

2.5. I was asked to make a formal submission to this committee after sending a list of 10 Concerns to PaulMaynard MP. As those concerns were on a national basis, I have submitted them via the campaign groupCoastguard SOS, of which I am a member.

3. Factual Information

3.1. Consultation response

3.1.1. On 28 September 2011 I emailed my response to the second part of consultation on the modernisationof HM Coastguard. I ensured that my responses were shared (cc) to my local MP; Paul Maynard, LouiseEllman MP and Dennis O’Connor (Coastguard SOS Campaign).

3.1.2. This response was my first interaction with the consultation process, as I had been unaware of theproposals until shortly before this date.

3.1.3. I found the online consultation response form too restrictive in input and therefore sent my input byemail via the one supplied on the website ([email protected]).

3.1.4. The acknowledgement email received (29 September 2011) from the MCA assured that “everyresponse form with comments made will receive equal consideration”.

3.1.5. A keyword search on consultation responses fails to find any that match my input, therefore althoughacknowledged, my response has been ignored.

3.2. No Impact Assessments done for any stations due to be axed

3.2.1. Existing needs or future changes have not been considered, the MCA have failed to safeguard thosecommunities affected.

3.2.2. Blackpool attracts around 10million visitors each year however, this figure is set to grow to anestimated 85 million by 2016 (source Lancashire/Blackpool tourism). 8.5 times more visitors will add aconsiderable amount of workload for Liverpool MRCC or it’s replacement.



3.2.3. The town has invested heavily on regeneration with a new seafront and tramway. The style of themain seafront is open access to the sea, at high tide and in stormy weather this gives rise to extra risk regardlessof actual visitor numbers.

3.2.4. Visitors to the Fylde coast can get disorientated and confused about location as there are 3 piers, theseawall is high in places making only certain local references visible eg “The Glitter Ball”, some referenceschange frequently like the illuminations. It is impossible to understand how any other Coastguard station/system/officer would recognise any of these reference points in an emergency within an adequate timescale,when the informant is panicking and disorientated.

3.2.5. Our local Coroner has noted an increase in the number of visitors coming to Blackpool with theintention of taking their own lives through drowning, this is now easier (as 3.2.3) and adds greater burden onrescue services along with added risk of members of the public trying to save lives.

3.2.6. Nationally there were 167 coastal deaths and 55 suicides in 2010 according to WAID Report1 withfour reported deaths on the Fylde coast during that time period, however there are indications that this figureis growing as there have been six in last eight months. The real impact is on the families and communitiesaffected by these deaths.

3.2.7. If Blackpool starts to get a reputation for being unsafe, then the town’s prospects will suffer and itmay even a greater number of people coming to the resort to commit suicide.

3.2.8. The Blackpool Annual Beach Patrol Report for 2011 states “The impending closure of LiverpoolCoastguard Rescue Co-ordination Centre, is anticipated to have a significant effect on beach/sea safety atBlackpool”. (copies available from Blackpool Council)

3.3. Rescue volunteers will be forced to make up for HMCG tasking errors

3.3.1. One of my main concerns is the safety of rescue volunteers, if mistakes are made on casualty location,then invariable a lifeboat or rescue asset would be tasked that is not required. This will have a twofold effectof placing assets in danger when not required and increasing pressure on those assets that are correctly taskedbut at a later time. Given that this is likely during bad weather and the risks increase again.

3.3.2. An additional burden for any rescue assets that are tasked in error, will be wasted time, fuel andpotentially earnings for the volunteers involved.

3.3.3. The above two points cannot be acceptable to anyone, therefore it is imperative that HMCG operationshave a zero tolerance to tasking errors.

3.3.4. Loss of Emergency Towing Vessels for the UK will add risk to the volunteer rescue services as wasthe case in the Penlee Lifeboat Disaster where all the crew of a modern lifeboat were lost. This was as a directresult of the Union Star failing to negotiate a commercial tow and founding on rocks.

3.4. Lack of RNLI comment on changes ether to MCA or 1st TSC Inquiry

3.4.1. As a charity dedicated to saving lives, the RNLI should put that goal above every other consideration.The changes envisaged by the MCA cannot fail to have an impact on their mission; therefore they need todemonstrate their commitment with a comprehensive response to changes.

3.4.2. Many RNLI volunteers I have spoken to have voiced deep concerns about changes to HMCG.

3.4.3. RNLI neutrality regarding HMCG has been broken, as a direct response to my dialogue with themregarding the station closures, Hugh Foggerty, Head of Fleet operations, RNLI, said “In reality, LocalKnowledge resides with Lifeboat crew and HMCG Coast Rescue Service volunteers” and further added “Veryfew if any Coastguard Watch Officers have true local knowledge of their operating areas”. This statement isinsulting to say the least for any Coastguard Officer and is contrary to views held by most local & regionalRNLI members.

3.4.4. A stark contrast to the above view of Coastguards from regional RNLI spokesperson making thefollowing statement to press (11/08/2012) “The guys at Malin Head have an excellent local knowledge. Thatstretch of water around the top of Ireland is notorious and they know how the currents are going to behave.”http://www.irishtimes.com/newspaper/ireland/2012/0811/1224321995972.html#.UCgOEyrDc9M.facebook

3.5. Loss of Military involvement when all helicopter search & rescue services are sold off

3.5.1. Our coast has witnessed the finest service in Helicopter Rescues by RN/RAF pilots when theRiverdance ran aground at Cleveleys. The public have no confidence that a private company will show thesame dedication in a situation similar to this.

3.5.2. Again if SAR Helicopters cannot be tasked due to “operational parameters”, then it will be left up tothe volunteer rescue crews to go and save lives, I do not know of any incident where a lifeboat has refusedto launch.1 UK water related fatalities 2010 WAID database report.



3.5.3. The whole SAR helicopter operation should be turned over to the military to run as one cohesive unitas the military will still need to train pilots in this role for military purposes. There cannot be any costjustification for having 2 organisations doing exactly the same role but with less training.

3.5.4. Aircraft type and availability should not be an issue, as military SAR training is already done withcommercial type aircraft and MOD already has ability to lease.

3.6. No faith in current plan for HMCG

3.6.1. I have yet to meet anyone in our coast community that has any confidence in the published changes.Many are involved with coastal safety and rescue volunteers.

3.6.2. Removal of the existing stations before there is a proven replacement is extremely unnerving for many.

3.6.3. It has not gone unnoticed that the Manx Government is investing in their Coastguard service as adirect result of the plan to close Liverpool MRCC, reducing their reliance on HMCG except for only the largestof maritime incidents. They cited the need for “they have the local knowledge”2 as a reason.

3.6.4. Changing climate conditions have already demonstrated the effect that this can have on our costalcommunities and shipping with more sever conditions than ever experienced, this threat will continue toendanger us.

3.6.5. Inland flooding is increasing placing extra co-ordination demands on the service, often in areas notpreviously considered as threatened making regional centres extremely valuable in knowledge and on theground response and management.

3.6.6. Many small craft do not have any radio identification beacons and are therefore invisible to remotemonitoring systems, yet they form a significant proportion of incident management.

3.6.7. Regional Coastguard stations are situated in areas of high maritime activities which require a physicalpresence as well as local knowledge. On the spot intelligent observations are key to excellent safety in thesehigh traffic areas and can often lead to incident avoidance.

3.6.8. MCA Consultation Question responses were very condescending and many did not answer specificallythe question. Example “Q How secure are the future of the Coastguard Centres? “ reply was “The MCA willalways keep its operational structure under review to ensure that it is fit for purpose to meet the operationalrequirements of the day. The new structure for HM Coastguard is is fit for purpose for the present and upcomingrequirements of civil maritime search and rescue in the UK.” this reply is copied exactly (including errors) andfails to answer specifically the question with no substantive facts like current plan timeframe or reviewtimescales.

4. Questions

4.1. Ref. 3.1.5 above, Why are my consultation responses not included in the published ones?

4.2. Ref. 3.1.5 above, Are any other consultation responses missing from those published?

4.3. Ref. 3.2 above, How can MCA not do any impact assessment on current and future requirements?

4.4. Ref. 3.4 above, Why have the RNLI failed to reflect genuine fears that front line volunteers express?

4.5. Ref. 3.5.3 above, How can having two separate organisations doing virtually same thing be costeffective?

4.6. How can MCA make such large sweeping changes to all aspects of coastal safety without proof that itis safe to do so? (closing stations, SAR sell off, EVT scrapping, ending MIRG)

5. Recommendations

5.1. Immediate stop to all closures.

5.2. As the UK public are at risk with these changes and foot the bill for the service, I would like the TSCto give the greatest priority to their concerns.

5.3. That the public have a greater say in the future of HMCG with an independent voice.

5.4. Public confidence is restored by acting swiftly and firmly to provide a fully risk assessed plan forHMCG.

Abbreviations

VT Emergency Vessel Towing.

HMCG HM Coastguard.2 http://www.bbc.co.uk/news/world-europe-isle-of-man-12830678.



MCA Maritime and Coastguard Agency.

MIRG Maritime Incident Response Group.

TSC Transport Select Committee.

August 2012

Written evidence from the Scottish Government (CFU 09)

Thank you for the opportunity to submit further evidence on the impacts of the Coastguard closures andchanges to the provision of Emergency Towing Vessels.

The Scottish Government remains extremely concerned about the plans to close the Maritime Rescue Co-ordination Centres (MRCCs) on the Clyde and the Forth and are unconvinced that adequate cover can beprovided from other MRCCs, particularly where those stations have not seen a significant increase in staffinglevels or had sufficient time allocated for training.

Although we welcomed the change in the modernisation plans and the retention of the Shetland andStornoway stations operating around the clock, our concerns about the current closures remain. Our primaryconcern is the loss of critical local knowledge relating to particularly large and complex stretches of ourcoastline. As stated in our previous submissions on this Scotland has some 60% of UK seas and it isunacceptable that we would be left with only a third of the total MRCCs.

Clyde MRCC is the busiest in Scotland and regularly shown to be the third busiest in the UK and, althoughsmaller, the Forth station covers an equally complex area of our coastline. The waters covered by the stationsto be lost host a range of activities including ferry traffic, naval vessels, cargo operations and leisure users, notto mention increased activity in relation to offshore renewable energy and significant oil related traffic onthe Forth.

Furthermore, we are very concerned about the timetable for closures that will see Scotland be the first tolose any stations with the Clyde set to close later this year. This is contrary to assurances made by MikePenning MP, who stated that no stations would close until the new structures were in place and had beenrobustly tested—which certainly does not appear to be the case. I have written to Mr Penning to highlightour concerns and we are to meet to discuss this matter in the near future. I attach a copy of my letter foryour information.

I would also highlight that we have raised concerns about the proposed reduction in staffing levels at theAberdeen MRCC as well as a suggestion in the “Concept of Operations” paper drafted by the MCA thatmanagement of any major oil and gas incident could transfer to an MOC hundreds of miles away. Staff atAberdeen already have tried and tested links with the Oil and Gas industry as well as having the advantage ofbeing located close to a large number of the other key players that would be involved in handling any incidentthat occurred. Again we have urged the UK Government to retain the current staffing levels and not to departfrom current procedures in relation to management of major incidents.

Your committee also looked at the proposal to remove the two Emergency Towing Vessels based in Scotlandalong with the other two vessels covering the rest of the UK. As you will be aware, following a long periodof uncertainty, the UK Government has agreed to fund one ETV until 2015.

We welcome that the UK Government has accepted that there is not a commercial alternative to the provisionof this service, although we question whether or not this understanding could have been reached earlier,avoiding the long period of uncertainty the industry has faced. However, we remain concerned that this is stilla 50% cut in provision of a service that could prevent a major incident around our coastline, and we wouldurge UK Ministers to continue to explore the options for additional provision—including restoring funding forthe second vessel.

I hope that the committee finds this summary of our ongoing concerns helpful in its further consideration ofthese important issues. As indicated above, the Scottish Government remains extremely concerned about theclosures of the Clyde and Forth MRCCs and the possible downgrading of Aberdeen. We will continue to urgethe UK Government to revisit this decision.

Finally, I feel it is important to note the professionalism demonstrated by the Coastguard Officers in theaffected stations in undertaking their duties throughout this period of uncertainty.

September 2012



LETTER TO MIKE PENNING MP FROM KEITH BROWN MSPDATED 28 JUNE 2012

Dear Mike

Thank you for your letter of 19 April to Richard Lochhead, Cabinet Secretary for Rural Affairs and theEnvironment, regarding the UK Government’s proposals for Coastguard modernisation and the impact of theseproposals in Scotland.

We have written to you previously to make clear our concerns about your proposal to close the Clyde andForth MRCCs, concerns which we know are shared across parties and which also reflect continued strength offeeling in the local communities and amongst seafarers and others affected.

We remain unconvinced that your decision to press ahead with these closures was the right one and we areextremely concerned about the potential impact of these closures. As you know, Clyde Coastguard is the busiestMRCC in Scotland and the third busiest in the UK. Considerable questions remain over whether sufficientcover can be provided from other MRCCs. It is also vitally important that adequate training for staff taking onadditional roles has been carried out in advance of closing the Clyde MRCC.

We have particular concerns relating to the transitional period when Clyde and Forth are proposed to closeand before the national network is able to provide back up. You gave assurances to Parliament that no stationwould close until the Maritime Operations Centre was operational and the new system was fully tested, andyet now the two Scottish stations are proposed to close prior to the national network being up and running. Atthe very least, the Clyde and Forth MRCCs need to stay open until robust arrangements have been put inplace—and thoroughly tested.

I am writing to request an urgent meeting with you to discuss the implementation of the closures in moredetail and to seek assurances that the new arrangements will be robustly demonstrated.

On a related issue, Clyde coastguard currently work closely with the SAR Helicopter service which operatesfrom HMS Gannet at Prestwick airport. I would appreciate an indication of whether it is still intended for thisservice to continue operating from RAF Gannet, any assurances you can provide that existing SAR coveragewill be maintained or improved under the UK-wide search and rescue helicopter contract that will come intoeffect in 2017, and an update on the current position around the procurement process for that contract.

Kind regards

Keith Brown

Written evidence from the National Coastguard SOS Campaign Group (CFU 10)

Introduction

Despite two public consultations into the future of HM Coastguard, members of the national CoastguardSOS Campaign group remain concerned at the plan to close 50% of UK Maritime Rescue Coordination Centresand the way that this has been presented to Members of Parliament, Coastguard Officers and the general publicby the MCA and responsible Ministers.

It is our opinion that the blueprint to close stations is not based upon operational reasons and this has led toa plan which remains dangerously flawed and offers no assurances that sufficient consideration has been givento the significant risks associated with station closures.

We appreciate the opportunity to contribute the group’s submission in response to the Transport SelectCommittee request for further evidence and detail our concerns as follows.

1. Key ConcernsLoss of Local Knowledge

1.1. There is no evidence that the “National Gazetteer” will be in place prior to any MRCC being closed.The majority of knowledge which is held by the staff, will therefore be lost before this system is in place orproven to be resilient in “real world” incidents.

1.1.1 Risk Overview table Ref. 6 Risk Mitigation states “No national standard gazetteer” exists forlocal knowledge (document dated February 2011). http://www.dft.gov.uk/mca/2.risk_overview_table.pdf

1.1.2 MCA response to Independent Review of 2nd Consultation “Local knowledge will becontinuously gathered, stored and shared across MCA systems. This information will includealternative and multiple place names, including phonetic spelling and will be available, in astandard format, to all watch-keepers across the whole UK network.” http://www.dft.gov.uk/mca/irt_response_table_v3.3.pdf

1.1.3 See also pairing in respect to “retaining additional centres with one from each of the existingpairs and increasing to 24 hour coverage at all remaining stations will enable the current levels



of local knowledge, local intelligence and familiarity with local languages, dialect and placenames, to be transitioned into the new structure.” (Refer to pdf document referenced in 1b).

1.2 MCA documents (above) acknowledge the lack of a national database for local knowledge and promisesto deliver such a system.

1.3 Given the timeframe for station closures it will be impossible to implement a purpose written programme.Any commercial system would need a full quality controlled and verified customisation by trained experiencedstaff. With the imminent closure of MRCC’s, much of this local knowledge will be lost before it can be addedto the “National Gazetteer”, even if staff would be willing to add data prior to redundancy.

1.4 Please refer to Ref.7 Local Knowledge—the Operational Context: http://www.dft.gov.uk/mca/7.local_knowledge_the_operational_context.pdf

1.5 “Coastguard officers can still draw on detailed local knowledge by contacting a wide selection of coastalcommunity based resources (CRS, RNLI, NCI, Harbour and port authorities etc.) for advice.” In an emergencysituation this is hardly practical due to availability of such volunteer sources and will waste valuable time inany incident.

1.6 MCA Final Consultation Q&A’s (question bridging page 7&8) stated that HMCG Sector Managers wouldhave no involvement or training with the MOC. http://www.dft.gov.uk/mca/q_a_final_v6_external_web.pdf.

1.7 Justification for not keeping all MRCC’s open was the additional cost of computer links/equipment forthe MOC, this prevents future updating of National Gazetteer and its interface with master mapping data.

1.8 Without a regional MRCC to audit any database (place names or maps/charts) how will it be properlyaudited? Any system depends on the quality of data to be effective.

1.9 HMCG has recognised the need for MRCC’s at strategic places to provide an on-scene local servicebecause of local risks, like the introduction of the London station after the Marchioness disaster.

1.10 Where is the proof that technology or working practices mitigate past requirements? (see also Concern10; lack of individual risk assessments.

2. Loss of Expertise and Experience

2.1 Many of the MRCC’s that are to be closed have the highest incident rates. There is no evidence tosuggest that the majority of experienced staff will remain in the service.

2.2 The historical Incident data shown in the table (right) clearly demonstrates that MRCC’s scheduled toclose are the busiest with extremely competent and highly experienced staff.

2.3 Latest incident figures show that closing stations are experiencing increases of up to 12% for 2011.

2.4 MCA Annual Canoe & Kayak Report for 2010 (issued Jun 2011):

http://www.dft.gov.uk/mca/2010_canoe_and_kayak_incident_report_kp_rev_1–2.pdf

2.5 MCA 2010 Diving Incident Annual Report (issued Jun 2011):

http://www.dft.gov.uk/mca/2010_diving_report.pdf

2.6 These reports clearly indicate the closing stations have the highest number of this type of incident.

2.7 The Diving report contains this statement; “the district with the highest individual total is Portland havingthe single highest recorded number of diving incidents totalling 41, not surprising when you consider thatPortland is one of the most popular diving areas in the country”.



2.8 MCA data gives irrifutable evidence of incident knowledge and experience that will be lost when thesestations close:

AberdeenBelfastBrixhamClydeDoverFalmouthForthHolyheadHumberLiverpoolLondonM-HavenPortlandShetlandSolentStornowaySwanseaThamesYarmouth

1,0825721,3241,4919682,3805089871,5741,2957417701,4473422,3764421,8361,3041,008

9946471,3551,3958112,2755328571,5811,2039457841,3193922,3104181,7661,217975

1,086678

1,3451,558

8542,634

4561,0251,7371,451

7121,367

3932,511

4171,6381,257

869

CG Station 2009 2010* 2011

Total 22,447 21,776Due to CLOSE

3. Early Closure of MRCC’s

3.1 On 22 November 2011 in the House of Commons, Mike Penning MP stated in reply to Sheryl MurrayMP “no centres will close before the robustness of the system is demonstrated. Should there be any blips inthe system, I can assure my Hon. friend that no station will close until we have the level of resilience that wedo not have today”.

3.2 Link to transcript/formal record:

Commons Hansard: Statement on coastguard modernisation.

http://www.publications.parliament.uk/pa/cm201011/cmhansrd/cm111122/debtext/111122–0001.htm#11112278000001.

3.3 Link to official TV recording of HoC session:

http://www.parliamentlive.tv/Main/Player.aspx?meetingId=9416&st=15:34:40.

3.4 Consultation final Questions & Answers confirm that MCA intend to close HMCG Stations after MOCapproval, quote from page 4 of link: http://www.dft.gov.uk/mca/q_a_final_v6_external_web.pdf.

3.5 Question; When will the Maritime Operations Centre be ready?

Answer (part); MOC’s areas of operational responsibility will gradually increase as MRCCsincrementally close or become Coastguard Centres within the national network.

3.6 Forth Coastguard is due to be closed on 28th September 2012 followed by Clyde Coastguard inDecember. This will have an impact on the gathering of local knowledge for the database and leave inadequatetime for remaining stations to become acquainted with the areas they are going to be responsible for. (SeePairing)

3.7 At the same HoC session, both Charles Kennedy MP and Richard Drax MP requested assurancesregarding the MOC’s ability to be proven and Paul Maynard MP requested that there was not a “cliff edgechangeover” between existing MRCC’s closing and the MOC becoming fully operational.

3.8 In a recent communication from the Prime Minister, he stated in the letter that “No MRCC would closebefore 2015”. The statement was later withdrawn, after the Coastguard SOS team made the contents of theletter public and the error was attributed to a researcher. The MCA stated “closures were to be as planned”.This statement from the MCA is extremely contradictory to all the assurances and documentation previouslygiven by the Prime Minister.



Language & Dialect Issues

4. In response to FOIA request F0001014, the following reply was received from the MCA: “In respect ofthe use of the Welsh language during distress calls the Maritime and Coastguard Agency does not hold theinformation you have requested as In response to FOIA request F0001014, the following reply was receivedfrom the MCA: “In respect of the use of the Welsh language during distress calls the Maritime and CoastguardAgency does not hold the information you have requested as HM Coastguard does not record which languagewas used by a caller during a distress call. In respect of the tasking of RNLI Lifeboats, I can advise thatEnglish is used as it is the International language for all Search and Rescue missions; and Standard MarineCommunications Phrases are used”.

4.1 Similarly, a response by the RNLI Press Office (Roger Aldham):

“I had a quick chat this morning with some colleagues in Wales, however no one can think of anyparticular incidents where the pronunciation of place names was a problem. I suggest you alsocontact the coastguard in Wales as they co-ordinate almost all of the incidents we launch to and maybe able to better answer your query”.

4.2 It is clear that language and dialect are a consideration, familiarity with place names is important forevery station.

4.3 Local names can be mis-pronounced by anyone not familiar to the area, underlining the importance ofall stations.

4.4 If the MCA seriously accepts that the pronunciation of Welsh is a primary factor in keeping any MRCCopen, then it must attribute equal importance for other British languages such as Gaelic and Kernowek togetherwith local dialects such as Doric. Due to the high level of tourism in the UK, it should be of equal importancefor every MRCC to recognise dialect and local phraseology for places, names and topography references.

5. Pairing Fiction

5.1 The following statement can be found in the document.... “Future Coastguard Consultation ExerciseEquality Impact Assessment” (EqIA):

“Each MRCC operates as the coordination centre for a defined geographical area. A measure ofresilience is provided by the organisation of the 19 centres into 9 pairings (with Dover/Thames alsobeing linked to London). This resilience is however limited to providing cover for a proportion ofresources across the pairing. With the exception of Aberdeen, MRCCs are neither staffed norequipped to provide full cover across a pairing.” http://www.google.co.uk/url?sa=t&rct=j&q=pairing%20site%3Ahttp%3A%2F%2Fwww.dft.gov.uk%2Fmca%2F%20&source=web&cd= 1&ved=0CEwQFjAA&url=http%3A%2F%2Fwww.dft.gov.uk%2Fmca%2Feqia_ consultation_exercise-2.doc&ei=F-3iT8zFIsjA0QXE7NSgAw&usg= AFQjCNFDpUXePHebDY0oM8K0NdJrzfgCRw.

5.2 The above public document is further backed up by leaked minutes of a Maritime Operations (MarOps)CSMs Maritime Meeting which was held at Spring Place on the 25 January 2012. This is an extract fromthe document:

Operations

First step is to get all Coastguard operators practised and confident with the current concept ofoperations for pairing at all locations. This should focus on practicing business continuity plans,and the use of mutual support by taking over specific activities such as routine monitoring of Channel16 or routine telephone calls to relieve load on paired MRCC:

— Area Operations are better described as Pairing Operations.

— Any barriers to pairing operations be they procedural or technical should be brought to theattention of HQ MarOps.

Once the standard of the current concept of operations is achievable at all locations, thenconsideration will be given to employing the operational design requirement of the radio equipmentreplacement (RER) programme. Work can begin here with the integration of Stornoway and Shetlandinto the NW and NE quadrants respectively. Work in developing the quadrant concept will beexamined and standardised prior to deployment to other quadrants after September 2012 (postOlympics).

5.3 It would appear that the current plan is based on a dangerous assumption that pairing of stations is anoperational reality. Coastguard officers and MCA documents confirm that this is not the case.

6. Unreasonable Workloads

6.1 With reference to both Ref.2 (Loss of Expertise & Experience) and Ref.7 below, staffing levels arecurrently at the lowest for quite some time but workloads are increasing.



6.2 Incident numbers are rising by up to 12% from the 2011 figures released under MCA FOIA responseF0001010. Figures for the current year indicate the probability of another sharp rise in incidents as one closingMRCC experienced 54 separate incidents in one weekend where the monthly average was 100.

6.3 Contributing factors cited are an increase in severe weather and more people utilising UK holiday/leisurethan before.

7. Staff Morale

7.1 In the Second Consultation document entitled “Protecting our Seas and Shores in the 21st Century”, thequoted number of HM Coastguard staff at all MRCC’s in Section 2 (Original consultation Proposals) wasquoted as 491.http://www.dft.gov.uk/mca/110722_condoc2_v11_2_url.pdf.

7.2 The 2011 total was 79 staff short of the 491.

7.3 Figures in table (right) were extracted from the parliament publication linked below:

Organisa�on 2011 Aberdeen MRCC 25.5

Belfast MRCC 21.14 Brixham MRCC 20.5

Clyde MRCC 27.57 Dover MRCC 26

Falmouth MRCC 25 Forth MRCC 14

Holyhead MRCC 23 Humber MRCC 25

Liverpool MRCC 20.5 London Coastguard 11

Milford MRCC 23 Portland MRCC 22.14 Shetland MRCC 18.14

Solent MRCC 25.65 StornowayMRCC 23.15

Swansea MRCC 22 Thames MRCC 19

Yarmouth MRCC 19.78 Total 412.07

http://www.publications.parliament.uk/pa/cm201011/cmhansrd/cm111124/text/111124w0001.htm

7.4 There are media reports covering the dire staff shortages within HM Coastguard service, which isextremely worrying, with one source quoting 163 Operational Coastguard Officers short across the service.(June 2012)

7.5 Shetland Coastguard struggling before additional responsibilities:

http://www.shetlandtimes.co.uk/2012/07/23/under-pressure-coastguard-station-may-have-to-cover-much-larger-area.

7.6 Forth Coastguard now down to 13 staff:

http://www.thecourier.co.uk/News/Fife/article/23391/fife-ness-coastguard-station-continues-life-or-death-work-as-closure-approaches.html.

7.7 Staff at closing MRCC’s have publicly expressed that many will not transfer to remaining stations dueto a variety of reasons like distance and loss of faith in the service.

7.8 We are concerned that this will lead to a “cliff edge” once stations start closing and may render theservice incapable of dealing with multiple incidents of any kind.



8. Real Flaws

8.1 According to one consultation FOI answer, there were nearly 2 instances a month in 2010 where MRCC’slost communications or systems. Average downtime was five hours 10 minutes:

http://www.dft.gov.uk/mca/question_45_network_availability_centralised_coastguard_comm_grade_as_2010_to_date.pdf.

8.2 With a similar picture from the 2009 report:

http://www.dft.gov.uk/mca/question_45_network_availability_centralised_coastguard_comm_grade_as_2009.pdf.

8.3 A worrying trend is that average downtime is increasing. The technology infrastructure is shown to havean average of 17 faults per month for the 2010 BT wide area network log found in the following link:

http://www.dft.gov.uk/mca/question_45_network_availability_centralised_coastguard_comm_grade_as_2009.pdf.

8.4 Press article showing blackouts can be caused by crime—in this case 3 hours lost due to a problem withBT exchange:

http://www.cable.co.uk/news/bt-outage-causes-communications-blackout-for-shetland-coastguards-801390143/

8.5 The key word for the modernisation plan has been “resilience” (an ability to recover readily from illness,depression, adversity, or the like; buoyancy.), it is a major concern that the reduction (by 50%) of MRCC’sactually removes resilience from the system as the greater number of centres means that it is less likely thatsystem failures will have an adverse effect on the emergency response.

8.6 Lower numbers of control centres equates to less resilience in the system, as failure points become morecritical having larger impact on the whole system.

8.7 All technology depends upon infrastructure integrity, which has power supply as the biggest weakness.

8.8 It is well known that National Grid supply failures are on the increase as demand rises, reserve capacityis at an all time low and severe weather events are more frequent.

8.9 There will be more system failures like the one reported recently in the press, it’s only a matter of timebefore it coincides with an incident where lives are at risk:

http://www.shetnews.co.uk/news/2663-coastguards-lose.

9. Incident Handovers

9.1 On the 20 July 2009 the Fishing Vessel MV Aquila capsized with the loss of three crew.

9.2 The Fatal Accident Inquiry by the Sherriff concluded that although there was nothing that could haveprevented the tragedy, there were lessons to be learnt by Maritime Coastguard Agency (MCA) & HMCoastguard (HMCG) in respect of delays and mistakes that were made:

http://www.scotcourts.gov.uk/opinions/2012FAI22.html.

9.3 Assessment and summary of the Sherriff’s report:

9.3.1 There was initial doubt over the incident location due to duplicate place names even thoughthe 999 caller gave precise location details.

9.3.2 The original MRCC taking the 999 call and initiating the response assumed responsibility forthe incident but then decided to pass to a nearer MRCC.

9.3.3 The original MRCC failed to follow through with vital information when handing over toanother MRCC due to high workload.

9.3.4 Mayday protocol was broken which failed to ensure all vessels in the area were properlyupdated and therefore may not have been aware of the need to respond.

9.3.5 There were inadequate staffing levels at the nearest MRCC who assumed responsibility, andthey failed to advise of the shortages before incident handover.

9.3.6 The experience and training of staff at the nearest MRCC were inadequate through lack oftraining in vital areas such as risk assessing incidents.

9.3.7 The assuming MRCC staff were overstretched and unable to fulfil the requirement of a SearchPlan (this danger has increased significantly with current staff losses).

9.4 The current modernisation plan requires frequent passing of incidents from MOC to MRCC with localknowledge or specialism in incident type, which according to the Inquiry recommendation should not happen,as mistakes are made as in (b & c).

9.5 There is a national variation in Coastal Safety signage and contact advice, in one small location; onesign said “ring 999 & ask for Police” whereas the next sign said “ask for Coastguard”. This will add to therisk of delays if calllers mistakenly ask for Police, resulting in the call being transferred to the MOC.



10. Lack of Risk Assessments

10.1 The Maritime and Coastguard Agency made some attempt to evaluate risk by producing a generalisedassessment.

10.2 However, we believe the risk assessment to be poorly documented, disjointed and difficult to follow.In particular solutions failed to adequately justify the mitigation and lost sight of the fact that failure (howeverlow the percentage of risk) could result in loss of life. http://www.dft.gov.uk/mca/supporting_documentation_final.pdf

10.3 The process of risk assessment should be straight forward, by breaking down into simple understoodhazards and risk with proper solutions with the emphasis on risk removal as a primary aim, followed byrisk reduction.

10.4 Risk analysis to the letter of the law means that the “requirement is to reduce risk using reasonablypractical measures”.

10.5 UK law requires that individual risk assessments are done on the basis that each MRCC will havealready done local risk assessments. These risks remain in place regardless of the station staying open or not.

10.6 It is therefore incumbent on MCA to evaluate each of these risks against closing stations, as eachMRCC may have differing risk profiles.

10.7 Additionally, each closing station should be considered on known future impacts to risk.

10.8 Note: The Health & Safety at Work Act was further strengthened by a Management of H&S Regs1999report; which covers the explicit need consider changes made to practices that affect the public.

10.9 Failure to meet the requirement for comprehensive risk assessment of MRCC closures has been thesubject of much debate within many areas including Welsh & Scottish Governments, where there have beencalls for devolved responsibility for Coastguard activities & SOLAS commitment.

11. MCA Management Concerns

11.1 The first proposal for the Modernisation of HM Coastguard was unacceptable to maritime stakeholders.This raises concerns that the senior decision makers at the MCA did not fully appreciate or consider the impactof the proposals on the industry, stakeholder partners and the communities they serve.

11.2 The evidence in the Aquila Fatal Accident Inquiry (see sect.9 of this document) concluded that therewere lessons to be learnt, the MCA have failed to show consideration of the findings.

11.3 Concerns of the competency of MCA management and planners can be found in the followingreferenced report.

11.4 Oil/Gas Field Incident: Exercise SULA National Contingency Plan Exercise 18th and 19th May 2011.Section 10.7 Maritime and Coastguard Agency (MCA) Marine Response Centre (MRC):

http://www.dft.gov.uk/mca/exercise_sula_-_18–19_may_2011_-_final_report.pdf

11.5 This is a direct quote of how the MCA faired in the exercise that they had a primary role in planning:

11.5.1 “There did not appear to be a clear command and control structure.

11.5.2 Agencies outside the MCA were confused as to the command and control structure withinthe MRC.

11.5.3 This resulted in similar confusion in the identification of the roles and responsibilities withinthe team.

11.5.4 In some cases it was felt the role given to certain members of the cell was inappropriate anddid not play to their strengths.

11.5.5 This was due to the insufficient number of people available for the exercise.

11.5.6 The lack of command and control led many of the team members to work in isolation, onindividual work streams and with little team focus.

11.5.7 They worked as professional individuals rather than a team.

11.5.8 Briefings were identified as being laborious and deflecting individual team members from theirprimary task”.

11.6 MCA assessors concluded that Management failed to learn from past lessons and that their own policiesgave rise to severe communication problems. Both this issues have a profound effect on the currentmodernisation plan for HMCG:

11.6.1 “Due to the MCA IT security policy, cell members found it extremely difficult to shareinformation effectively between themselves and with other responders”.

11.7 Planning for this exercise began in August 2010 but “following a strategic refocus specific planningcommenced in January 2011” which implies major planning problems all along.



11.8 Out of the 13 lessons identified, 10 were for the MCA to look at and make improvements.

11.9 Recently a container ship was reported as drifting in the Atlantic some 200 miles off the UK coast afteran explosion and fire that claimed two lives. Until recently, there would have been a Maritime IncidentResponse Group (MIRG), tasked to assist this incident; however this group has been axed. This is in directconflict with the report commissioned by the MCA which concluded that such a group was necessary on ascale of probability and was in-line with what all other EU coastal countries offered.

12. Current Technology

12.1 There are significant local variations to the national computer simulation software and planning. Thereare reports that prediction models do not fully cater for manmade influences on tide movement patterns. Theseare issues that staff at regional co-ordination centres would be aware of and better equipped to manage.

12.2 A recent high profile hoax 999 telephone call of 33 minutes to a regional emergency call centre wassubject to a lengthy police investigation as the call could not be traced within 24hours. The MCA insist thatthey can establish accurate caller location on a national basis using the same system.

Questions— With reference to Para. 1.5; Without access to the National Gazetteer, how can contributors (local

CRT’s etc) ensure that the data is correctly entered?

— Why are MRCC closures being rushed ahead before the “resilience and “robustness” of the MOChas been fully tested and approved?

— Ref. Para 3.7 Why has the MCA allowed staff levels at Forth Coastguard to drop to dangerous levelsand then stated that it is forced to close early due to safety?

— Why is it that Freedom of Information requests get answered for some and not others on exactly thesame subject?

— See para 8.1, 8.2 FOI requests prove network/VHF loss is logged but FOI request by campaigner istold “No Records held” see MCA FOI F0001019 (refused) & link: http://www.whatdotheyknow.com/request/marine_vhf_coverage_loss_2010_20_2#incoming-301077.

Conclusion

There is a considerable amount of evidence that the current modernisation plan for HM Coastguard isunworkable, unsafe and fails its primary objectives.

The service has reached crisis level and there exists an overwhelming sense of urgency that; issues mentionedneed addressing before failures occur.

Recommendation

On the basis of evidence of on-going concerns, the recommendation of the group is the immediate suspensionof station closure plans.

Further, we believe that this should be followed by a full review of the process that has been employed byMCA Management and responsible Ministers throughout the process which has resulted in considerableconcerns being raised.

We recommend an Independent Group, work towards finding acceptable resolution to the concerns raised inthis submission.



Referenced Data

September 2012



Written evidence from Ian McLean (CFU 11)

Proposed Reorganisation of Coastguard Stations

The waters covered by Clyde Coastguard include a shoreline approximately the same length as that ofFrance. They vary from tranquil isolated sea lochs to wild headlands and ferocious tidal streams. They areplied by tankers, explosives carriers, nuclear powered and armed submarines, freighters, ferries, fishing vesselsand a myriad of pleasure craft. Are the Committee truly aware of the complexity of this area?

I am a frequent user of these waters on ferries and pleasure craft and have frequently listened to andoccasionally helped in rescue/assistance communications on VHF 16. On one occasion I had to request theevacuation of a casualty from my vessel, which was flawlessly executed.

Some of the small craft I have helped search for have not been equipped with GPS or VHF and haveonly been able to give sketchy information on their position relative to local landmarks, yet the coastguardcommunications were able to translate this into coherent search areas for nearby vessels.

Many of the hazardous features of the area are identified by Gaelic names and a many such names areubiquitous eg Eilean Dubh.

Are the committee confident that sufficient local knowledge of these waters will be available in the BelfastCentre which will take over?

Who will they blame when there is a tragedy?

September 2012

Written evidence from Toby Reynolds (CFU 12)

1. Implementation of Government’s Changes to the Coastguard service

1.1 Work is now progressing on the implementation of the new UK Coastguard service. The necessarychanges are being delivered according to a series of “work packages”.

1.2 It is encouraging that the Maritime and Coastguard Agency (MCA) are now utilising the knowledge andexperience of serving officers in this process, who have been invited to “get involved” by volunteering for theFuture Coastguard Programme. However, the number of volunteers that have currently been engaged in theprogramme stands at around 40 out of a total of over 160, and it remains to be seen whether serving Coastguardswill be included (and, more importantly, listened to) in decisions relating to the real nitty-gritty of operatingprocedures.

1.3 It is also extremely positive that, based on feedback received during the consultation and from theTransport Committee, the MCA decided to rethink their original proposals, reducing the number of stationclosures and maintaining 24-hour stations around the coast.

1.4 It is difficult to comment at this time on the possible impact on service delivery arising from the changesto the Coastguard service. There is plenty of information on the Future Coastguard microsite giving broad-scale overviews of the technology that will form the basis of the national network, and how incidents androutine work might be managed across the network. However, we are still very much in the dark regardingday-to-day incident working within a station, especially from an individual point of view: how incidents andresources will be managed; how much involvement (or “poking their nose in”) the Maritime Operations Centre(MOC) will have; exactly how the technology will be utilised to full advantage. Until we see and use thistechnology—which we are told is already within the capability of the current systems—it is impossible to saywhether it will work as described, be effective and represent an improvement over the current system.

1.5 Of particular concern is the impact station closures will have on service provision during the interimperiod, before the MOC and national network are up and running. At Stornoway Coastguard we are faced withthe imminent closure (before the end of the year) of MRCC Clyde. We will assume responsibility for thenorthern part of their current area of operations, while Belfast Coastguard take the southern part. However, atthis time neither station has been allocated any additional staff to cope with the additional workload during theperiod until the national network is able to effectively support us (estimated to be two–three years).Furthermore, while the technology to support the handover should be ready on time, the fact this has not yetbeen completed leaves us very little time to gain any useful experience of the running of Clyde’s current districtbefore they close. Combined with the reluctance of most staff at Clyde to engage with us on the sharing ofinformation (understandably, given their situation), this presents us with a very steep learning curve comehandover of operations in November.

1.6 I still fail to see where the personnel are going to come from to staff the MOC up to its proposedcomplement of 96 watch keepers. The MCA have done little to gauge opinion from current serving Coastguardson their level of interest to relocate to the MOC (with the exception of “expressions of interest” obtained fromClyde and Forth—the first two stations to close). According to what we hear from around the coast, there arefew among those staff from stations scheduled for closure who are willing to relocate to another station, andeven fewer who wish to work at the MOC. (Between 10 and 11 Coastguards from each of the nine closing



stations would be needed to fully staff the MOC.) Another concern is therefore that the MOC will be largelystaffed by inexperienced new recruits, with the inevitable resulting negative impact on service delivery.

2. Changes to Emergency Towing Vessel Provision

2.1 We no longer have a dedicated Coastguard Emergency Towing Vessel (ETV) for the Minches, whichwas scrapped along with the Dover Straits and Western Approaches ETVs earlier this year.

2.2 The remaining Northern Isles ETV has now been replaced by a Scottish ETV to work “around Scotland’scoast as required” (according to the BBC News website). We believe this ETV to be stationed somewhere inthe Pentland Firth area. This is still a considerable distance from the Minch and there are no other suitablecommercial alternatives in the area.

2.3 The need for an ETV in the Minches was highlighted just days after the departure of the previous tugwhen the laden cargo vessel Flinterspirit grounded on North Uist. The nearest available suitable tug was morethan 30 hours sailing time (with the exception of the former Northern Isles ETV, which proceeded to the scenein around 15 hours), so it was fortunate in this instance that the vessel managed to refloat on the rising tidewith no major damage to herself or the environment.

September 2012

Written evidence from PCS Brixham Branch of the MCA (CFU 13)

HM COASTGUARD WATCH OFFICERS THOUGHT FOR THE MARITIME CASUALTY

1. A political decision kicked the Senior Management of the Maritime and Coastguard Agency in andlooking for savings in cost of running the agency with less and they called it Modernisation.

2. A day or so before the consultation document was released by the Coalition Government. The MCAdecided, without consultation, to remove the Direction Finding Equipment, linked to the Very High Frequencymarine band radio, which gives a bearing of the transmission from a vessel/station transmitting on VHF channel16 (distress urgency and safety channel) received at the coast station. Used by Maritime Rescue Centre tolocate the Casualty Vessel in the first instance and routinely daily decide which VHF aerial to use to establishcommunications with the transmitting station. HM Coastguard remains responsible for the Integrity of channel16 and DF did assist to locate persons abusing the channel or have faulty equipment, giving false transmissionswhich block the channel. If it was not for the goodwill of the RNLI in non distress situations, these issueswould not be resolved. Cost saving not lifesaving.

3. Brixham Coastguard channel 16 operator (Distress, Urgency, Safety and Calling) monitors nine VHFradio sites. International requirement is to maintain a speaker watch only and at the discretion of the WatchManager when busy revert to headset watch. four of which are situated near Rivers and Estuaries in Brixham’scurrent domain. The issue here is capture effect. It is common in that the receiver on the VHF radio willreceive the stronger signal. The mariner in a small craft, with only a hand held VHF radio, at sea level (rangeup to five miles) and no VHF DSC has little chance of being heard at moment. The operator’s knowledge ofcapability of each radio site assists in locating the caller. Increase the number radio sites per operator, withlittle or no knowledge of the site and no VHFDF to assist in locating the caller. The safety of the maritimecasualty is compromised further.

4. Brixham Coastguard had co-ordinated 1,300 Incidents for the year 2010, where 1,900 persons wereassisted and 358 rescued. 80% of which were on or near to the shoreline. These statistics were kept locally,because of the action short of strike. The high percentage of incidents that occurred, close or near to shore,gives an indication that situated knowledge (explained later) is required.

5. We will have even more Remote Radio Sites to monitor, per person, than the French authorities in theEnglish Channel. At least they can back up a transmission on VHF CH 16 with a DF bearing. eight of these17 semaphore (signal) station, Naval lookout station or a CROSS are manned 24 hours and the rest daytimeonly. What will the MCA do? Reduce the number of VHF aerials or call on the services of the National Coastwatch Institution. A Voluntary Organisation with no Search and Rescue Co-ordination experience.

6. That brings us to Local Knowledge. Mike Penning said (when in post) “the level/standard of LocalKnowledge “Will remain the same, assisted by technology and contacting RNLI crews and Coastguard RescueService Volunteers local to the area.

7. Currently, the Coastline of United Kingdom Search and Rescue Region (UKSRR), approximately 10,500miles is divided into manageable chunks (locally 18 Stations). Brixham Coastguard have around 200 miles andother stations more.

8. The future management of these 10,500 miles will be down the Maritime Operations Centre on a dailybasis depending on the workload of the remaining Stations. Likening it to a large cake with many slices anddividing it up accordingly. The testing of this new facility has yet to be conducted, a guarantee given beforeany station closures. If a SAR incident occurs at sea and a considerable distance off shore, its said that any ofthe remaining Stations could co-ordinate it, agree.



9. So what is the Minister saying? The standard of Local Knowledge will be the same, you had 200 milesand now I’m giving you 10,500 to learn. We have already seen that the Local Knowledge Test has beensuperseded. The knowledge required seems to be general basis now. Take one for example from the previouslearning, the Coastguard Officer on joining a Maritime Rescue Centre, had to visit every SAR resource withinthe district inside three months.

10. Our Local Knowledge is “situated knowledge” to a particular area of the UK. Some methods ofgenerating knowledge, such as trial and error, or learning from experience, tend to create highly situationalknowledge. Situational is often embedded in language, culture or traditions. Knowledge generated through thisexperience is called knowledge “posteriori”, meaning afterwards. This knowledge is not knowledge that onecan forget. MCA has not taken expressions of interest from all Coastguard personnel yet, therefore has noinformation on how many will be moving and taking this knowledge with them. If new staff are recruited, itwould be a further nine—12 months for them to be fully operational. Under current training practice.

11. Knowledge for the whole UKSRR is: Partial knowledge and it is not possible to have an exhaustiveunderstanding of whole UKSRR like a District has. So then MCA management have to live with the fact thatour knowledge is always not complete, that is, partial. In real life situations people have to make decisionswith limited amount of information accordingly. MCA have already admitted in operational risk assessmentthat the Local Knowledge will not be to the same standard and intend using the Coastguard Rescue Service(CRS) to improve the Local Knowledge based on an on call basis. This will cause a delay to the responsegiven by the MCA and also have some implications on the employment status of CRS.

12. Brixham Coastguard Incident statistics show us the majority, 80%, occur on or near the coastline. Morereason to have Coastguards with situated knowledge in place. An Increase in small craft activity in thefollowing areas, prompted the RNLI to place Inshore Lifeboats in those locations.

13. Looe 2002 A new D class lifeboat, D-574 Regina Mary, was placed on service on 5 March.

A B class lifeboat, the Atlantic 75 B-793 Alan & Margaret, was co-located with the D class.

14. Salcombe 2003 An inshore lifeboat (ILB) station was established and the new B class Atlantic 75lifeboat, B-794 Joan Bate, was placed on service on 7 November.

15. Plymouth 2004 An inshore lifeboat station was established on 31 March with the B class Atlantic 75lifeboat, B-775 Millennium Forrester.

16. 2010 Dartmouth Lifeboat Station was formally established by the Trustees Committee on 7 November.Subsequently a D class placed on service.

17. If a casualty risk assessment were to be conducted amongst all mariners and coastal users.

18. Vessels: We would come to the conclusion that mechanical defects were the most common for poweredwatercraft, followed by carrying and use of radios, lifesaving apparatus, seaworthiness, navigation, boathandling and the registration there of.

19. Persons: Unaware of the dangers when visiting the coast ie: Tides, cliffs, beach, weather, heat(environment).

20. All these issues need to be addressed by the Government and MCA as a category 1 responder, havingcompleted an impact assessment, in the form of Voluntary Code of Conduct and registration for Pleasure Craftusers to start, followed by a Compulsory Code, which covers licensing of the Boat Handler and Craft whichcould by recorded at DVLA and self financing. It would create more work, creating new roles within HMCoastguard, Survey and Inspection branch, also self financing.

21. Campaigns in educating persons visiting the coast. HM Coastguard would be more proactive thanreactive. Enhancing the work in the public domain would increase the public’s awareness of HM Coastguard.

22. This current Modernising of the Coastguard plan will just diminish the service and duty to the public.

September 2012

Written evidence from Inverclyde Council (CFU 14)

I refer to your invitation for written evidence and write on behalf of the Council to make representations tothe Transport Committee relative to the impact on service delivery arising from proposed changes to theCoastguard service.

Inverclyde Council and the ten neighbouring Local Authorities within the area of Clyde Coastguard haveconsidered and agreed a Concordat to oppose the proposed closure of Clyde Coastguard. A copy of the signedConcordat is enclosed for your reference.

Throughout the consultation processes undertaken in 2011, Inverclyde Council and its neighbouring LocalAuthorities have confirmed their concern at the proposal by the Maritime & Coastguard Agency to close theClyde Maritime Rescue Co-ordination Centre at Greenock. The Council, and the other Councils within the



Concordat, believe these cuts to an essential frontline emergency service will put the lives of all those usingthe seas off the West Coast of Scotland at risk. The Concordat Authorities believe that the proposals withinthe consultation documents rely too heavily on new technology that has not yet been developed or tested andthat the replacing of years of local knowledge by untried systems is fundamentally wrong. The ConcordatAuthorities believe that the proposals will cause inherent delays in the emergency response operationalprocedures with consequences for the dispatch of search and rescue helicopters and lifeboats to people introuble on the seas.

Inverclyde Council has two fundamental issues of concern. First and foremost is the continuation andstrengthening of the quality of the service provided by the Maritime & Coastguard Agency for the Clyde andWest of Scotland. It is thought that the proposals do not strengthen the service for the future. Secondly,Inverclyde Council is committed to a process of area regeneration and the loss of crucial, high quality jobsfrom this area has a detrimental impact on Inverclyde as a location with consequential impacts on its populationand associated and vulnerable demographic changes.

The existing MRCC Clyde has a very extensive and varied operational area from the Mull of Galloway toArdnamurchan Point with one of the longest coastlines of any Coastguard watch. There is a significant risk ofthe widest range of emergency incidents and it is the busiest search and rescue station in Scotland and the fifthbusiest in the UK. The operational area is diverse and complex and is contained within an area of 50% ofScotland’s population and this is just as relevant for issues of commerce and industry as leisure sailing anddiving and other developing recreational pursuits.

The MRCC Clyde plays an important role in existing and developing industry, trade and leisure and theCouncil cannot support proposals which may lead to a reduction in priority or a diminution of quality orservice. The available statistics reveal the large number and diverse nature of incidents dealt with in the existingoperational area and a continued focus on the Clyde and West of Scotland is vital. The closure of ClydeCoastguard is being proposed at a time when the number of major cruise ships, some carrying as many as fivethousand persons, has been increasing on the Clyde. Since, for example, the year 2007, there are as many asover four times the amount of passengers forecast for arrival at Greenock Ocean Terminal by 2013 and thatcorresponds with approximately four times the total Gross Registered Tonnage. Additionally, as part of ourarea’s regeneration plans there is much focused work to increase the numbers of leisure craft on the Clydewith new marinas and this has been well received to date with substantial public interest. These issues are twostraightforward examples to show that the Clyde and the West of Scotland will be used by many more peopleover the next few years and thereby increasing risks at a time when the Clyde Coastguard is projected to close.

The proposed closure of Clyde Coastguard would result in a weakness in the Coastguard structure throughthe loss of key frontline personnel with substantial and important local knowledge, experience andprofessionalism.

There is no existing evidence to show that the use of untried modern technologies will in itself produce anintegrated network that can respond quickly in emergency situations. The risks, particularly the technologicalrisks, that are involved in increased networking and geographical remote sites require to be fully assessed andunderstood in order to address the impact of problems or failure in managing the emergency response. Thetransitional period from the intended closure of Clyde Coastguard on 31 December 2012 onwards means therewill be significant operational risks which will continue, at the very least, until the new technology and systemsare fully in place and operationally tried and tested. The Council and other local authorities have expressedtheir very serious safety concerns on the transitional period to the relevant Minister. Furthermore, to ensureresilience and to provide a more resilient response for future needs, it is essential that the service be proficientin local knowledge and continues to have key staff with local knowledge available, trained and equipped forlocal and potentially complex rescue situations.

Inverclyde Council can appreciate the issues of available resources and budgets for the future along withany wishes for review and modernisation. However, the proposed closure of Clyde Coastguard must beconsidered against the increased risk to safety at sea and there is no evidence to support the closure andmanagement of emergency response through modern technologies from distant locations. Instead, the volumeand nature and extent of incidents show that the Clyde and its approaches are exceptionally busy and requirededicated and locally-based resource.

The present location of Clyde Coastguard is within Navy Buildings, Greenock. This building is government-owned through, it is understood, the Ministry of Defence and the occupation of the building is regulatedbetween the MOD and the Navy through a lease or “memorandum of temporary occupation”. It appears thatthe building continues to be owned by the government and there is no reason known to Inverclyde Councilwhy the building cannot be retained in the long term, or, at least, until any new national network has beensuitably tested and risk assessments completed. Associated with this point, it does appear to Inverclyde Councilthat the retention of Clyde Coastguard has not been fully considered as an option and that the lease oroccupational requirements may have obscured issues of operational delivery of services. However, and in anycase, the Council has previously undertaken to assist in any feasible way the retention of Clyde Coastguardthrough provision of alternative properties in Inverclyde with suitable lease covenants for competitive marketrates in respect of any other available properties from within the Council’s portfolio or the portfolios of its



partners. Inverclyde Council would assist insofar as possible in relation to any alternative accommodation andfinancial packages required for a continuation of the service within the West of Scotland.

In short, Inverclyde Council is not convinced that the breadth and nature of the emergency response whichis necessary for the Clyde area can be adequately managed without Clyde Coastguard and for that reasonit would support an evidence-based approach to the retention of Greenock Centre for Clyde and West ofScotland operations.

In Inverclyde Council’s opinion, the removal of the service from Greenock is not supported by evidence andwill have adverse implications for the quality of service and for public safety within the area.

As incremental step in the review—with the continuation of Clyde Coastguard at Greenock being securedfor the future—would provide the focus for the operational area that is deserved and which would, in itself,support the MCA’s drive for savings and modernisation.

Closure of the Greenock Centre is not seen as a viable or productive option in relation to the future serviceand there are strong arguments for the merits of continuing and improving the Clyde Coastguard at Greenockboth in respect of a quality of service basis focused on public safety and also in respect of the local impacton jobs.

It is the Concordat Authorities’ conclusion that Clyde Coastguard should be retained. The importance oflocal knowledge and the professionalism as held by the current workforce cannot be underestimated. Anyrevision of the existing structure must take into account the need to maintain and enhance a safety culture thatmeets the needs and demands of the local operational area.

Inverclyde Council would be pleased to clarify or expand on any issue above.

It would assist if you would kindly acknowledge receipt of these representations.

September 2012

Written evidence from the Welsh Government (CFU 16)

The Welsh Government has taken an active interest in the UK Government’s proposals for change in theCoastguard Service.

It is acknowledged that UK waters are becoming increasingly busy with commercial and leisure vessels.This increase in activity will continue to put pressure on the emergency services around the UK. The WelshGovernment recognises that the Coastguard Service needs to modernise and become more resilient to enableit to respond effectively to increasing demands and to reflect new working practices and embrace newtechnologies.

However, the Welsh Government has real concerns about the plans set out in the UK Government’s Blueprintfor Future Coastguard Organisation in the UK published in November 2011 and the process that led up to thedecisions set out in that document. We set out our concerns about the potential impact of the proposed changesto the Coastguard Service in Wales in responding to the UK Government’s consultation process and insubsequent correspondence with UK Ministers.

The Committee’s previous report was a helpful contribution to the debate about the UK Government’sproposals for change in the Coastguard Service and we welcome the recognition that was given in yourrecommendations to the lack of engagement with the devolved administrations on the proposed changes.

The Welsh Government shared the concerns expressed in the Committee’s recommendations about theevidence base and data used to justify the changes proposed and the value in ensuring that there was greateruse of location specific data about likely risks and the previous pattern of incidents. Similarly we also sharedthe Committee’s concerns about whether the proposals gave adequate consideration of the value of localknowledge, for example familiarity with the geography, features and language of an area, and the value of aservice firmly connected to the communities it serves.

We recognise that the UK Government made some changes to its proposals in the light of these issues butremain to be convinced that the changes now being implemented adequately address these points.

The Welsh Government is aware that the UK Government is pressing ahead with the plans set out in theBlueprint for Future Coastguard Organisation in the UK, but we have limited access to information on progress.The Committee’s current inquiry will provide an invaluable insight into progress with implementation and theissues that are emerging.

We have continued to seek to work with the UK Government on understanding the implications of theirproposals for Wales and, given the significance of the issue and despite the non-devolved nature of this, wehave gone so far as to offer to contribute towards the cost of further risk assessment of their decisions inrelation to Coastguard stations in Wales. The UK Government has so far declined to undertake any furtherwork and restated their view that the assessments that they have already carried out are sufficient.



The Welsh Government believes that further risk and impact assessment is justified and that this should besite specific and consider the issues specific to each station. The outcome of such an assessment would bothenable a review of the current proposal to close Swansea Coastguard Station and inform the implementationof wider change. Our offer to work with the UK Government on these issues and to contribute to the cost offurther assessment work in relation to Wales remains and we hope that the UK Government will adopt a morecollaborative approach going forward.

We do not believe that there is a case to close Swansea Coastguard station and support the retention of allthree stations in Wales on a 24/7 basis.

September 2012

Written evidence from Matthew Mace (CFU 20)

I am concerned how the changes, which are really only just starting, are being implemented. I believe therewill be a significant, adverse impact on service delivery unless some current agreements are maintained. Thechanges are proceeding without the employment terms and conditions of the future service being known. I donot know how much of the detail below MCA HQ is aware of but this is my view from the cliff face.

Background

Forth Coastguard will be the first MRCC to close (28 September 2012) and the entire coast and sea areathey are responsible for will be absorbed by Aberdeen MRCC. Part of the northeast mainland of Scotland has,meanwhile (from 6 September 2012), been transferred from the control of Aberdeen MRCC to Shetland MRCC.There will in future be similar adjustments of which station is responsible for which part of the coast as otherstations close and we move towards the Future Coastguard arrangements. Major technical work is currentlyhappening on the west coast of Scotland in preparation for the closure of Clyde MRCC and the splitting ofClyde’s current responsibilities between Stornoway and Belfast MRCCs.

The technical issues that need to be resolved to enable Forth to close are very straightforward as the vastmajority of the equipment they use are housed at Aberdeen MRCC anyway. From a purely technical point ofview only, Forth could close tomorrow.

The transfer of part of the northeast mainland of Scotland to Shetland MRCC has already occurred, and staffat Shetland are using those aerial sites on the mainland remotely via a dial-up link into Aberdeen MRCC’sequipment. This link does drop out occasionally, and when it does, Aberdeen MRCC will cover that part ofcoast until the link can be re-established. The aerial sites affected will be rewired directly to Shetland in thecoming months and they will then no longer need to use a dial-up link.

A lot of effort needs to be put into the technical side and this is happening. What is being forgottensomewhat, it seems to me, are the operators, the Coastguards working at the MRCCs.

Concerns

For many years we have risk-assessed the manning required at each station for each day or night shift basedon historical routine and incident workload for that time of year, together with any significant events or weatherforecast for that shift. The data behind these risk-assessments have not been updated to reflect increases inroutine working that have occurred since they were originally formulated but they have been updated to reflectthe increases in incident workload. For those stations that could pair with another there are two levels ofmanning. The first level is the manning needed if they are covering their normal area, the second is the manningneeded if they were covering their normal area AND the normal area of their paired station. This second levelis higher than the first level.

For instance at Aberdeen the normal manning level for day and nightshifts is five qualified persons on watch.If we take over Forth as well the manning level increases to five plus (which we take to mean six) qualifiedpersons on watch.

Currently we at Aberdeen and Forth are chronically understaffed. This is the same at all MRCCs Iunderstand. Part of the reason is the low pay which makes it difficult to recruit. Due to the changes to comeabout in Future Coastguard we can also only currently recruit on two year fixed term contracts which are notattractive. The terms and conditions that will apply to staff in the Future Coastguard are also completelyunknown. Many existing staff are looking for other work, prompted by the uncertainty of Future Coastguard,and leaving if they get some other reasonable employment. The current staffing at Aberdeen is 18.5 out of 30(62%) and at Forth it is 12 out of 19 (63%). Watches at Aberdeen and Forth frequently run at one or twobelow the required level and high levels of overtime are required to get the manning up to even this reducedlevel. For instance as I type this, for the month of September, for Aberdeen only, to try and maintain a manninglevel of five persons on watch, there are 89 x 12 hour overtime slots of which 31 remain unfilled. Some ofthese slots remain unfilled because of restrictions following pressure from senior management to reduce theovertime costs. The top grade, Watch Managers, are currently banned from filling an empty 5th slot if the otherfour slots are filled at the required grade. Were we fully manned there would be little, if any, need for overtime.



The overtime bill is huge, but so are the savings being made on salaries not paid due to the fact that we are sounderstaffed. Money saved on salaries needs to be transferred to the operational overtime budget to keep usgoing until Future Coastguard.

From the 28 September when Forth close, the manning required at Aberdeen by the risk-assessment,increases to six. Unfortunately it looks like only two watchkeeping members of staff from Forth are going toremain in the Coastguard and only one is going to transfer to Aberdeen MRCC, so there will be a positive butmarginal impact on the staffing level at Aberdeen. We have requested that the current agreed risk-assessmentprocess be respected and that we endeavour to obtain six persons on watch. This request has been passed toMCA HQ and we are awaiting the outcome of discussions, but as I write this no answer has been forthcoming.This is less than two weeks before Forth closes.

The general feeling of staff at Aberdeen MRCC is that we should follow the risk-assessment and makereasonable efforts to achieve a manning of six persons on watch once Forth closes. This includes trying to fillslots with the grade appropriate first, but also then trying to fill the still vacant slots if possible, with any grade.If after going through this process we do not achieve that manning, we will continue to act professionally andrun with whatever the manning is. Running short is stressful enough but running short when you know thereare staff who could come in and do the overtime is more stressful and also demoralising. If we do not try andfollow an already agreed process then I can only see increased stress and negative morale, more effort to findother work and an increased willingness to take part in industrial action. All of these will have a negativeimpact on service delivery.

Aberdeen and Forth are the first stations to go through this process. All other MRCCs except London willalso go through it. We need to get it right. Now. If we do not the likelihood of retaining good staff for nowand for Future Coastguard will severely diminish.

MCA report on the 2nd Consultation Responses, dated October 2011 reflects some of the above concerns:

Concept of Operations

Finding 1

That the MOC should be commissioned and declared fully operational at the earliest opportunity, otherwiseif station closures go ahead before the MOC is ready, then other stations (possibly with reduced staffing levels)would have to absorb the workload from the closed stations. This would increase the risks to successfulSAR operations.

Resourcing and People

Finding 13

The inability of staff to relocate and the potential loss of those staff and their experience and expertiseremained a major concern among respondents.

Finding 14

That staff leaving the service ahead of planned station closures could lead to staffing difficulties andjeopardise MCA’s ability to effectively manage and co-ordinate SAR operations.

After all, if I can quote from the title page of the same document:

PROTECTING OUR SEAS AND SHORES IN THE 21ST CENTURY

REPORT ON THE 2nd CONSULTATION RESPONSES

October 2011

“The backbone of the Coastguard will always be the men and women who know the shores, love the seaand will do their utmost to save lives at sea and around our coast”

Presentation of Her Majesty’s Colour to HM Coastguard 20 July 2005

Matthew MaceWatch ManagerMRCC Aberdeen

September 2012



Written evidence from the RNLI (CFU 21)

Changes to the Coastguard Service

Further to the Transport Committee’s invitation to submit written evidence on how the Government’s changesto the Coastguard service are being implemented I am responding on behalf of the Royal National LifeboatInstitution. In putting together this response I have consulted with all our operational lifeboat stations in theUnited Kingdom and have only received one item of feedback, and that in itself was an expression of regretbut understanding about the need for the proposed changes.

1. Further to the Committee’s report of 2011 the original proposals to provide 24/7 cover from a singleMaritime Operations centre supported by a second MRCC and a number of “day light only” sub-centres havebeen modified to provide a number of 24/7 MRCCs with one Maritime Operations Centre, to be established inFareham, Hants, with a back-up facility at the existing Dover coordination centre, both operating on a 24 hourbasis. There will be eight further Coastguard Centres, all operated on a 24 hour basis, located at Falmouth,Milford Haven, Holyhead, Belfast, Stornoway, Shetland, Aberdeen and Humber. The station at London isalso retained.

2. So how will all this affect the RNLI? In truth the manner in which rescues are co-ordinated by theCoastguard has changed little over the past forty years. Currently, operations are coordinated from 19 dispersedcentres with no network of national integration. This is inefficient and there is very limited resilience in theevent of high demand or technical problems.

3. Broadly we welcome the plans, which should create a resilient and nationally networked system ofCoastguard coordination centres, enabling our lifeboats and lifeguards to respond to emergencies at least asfast and effectively as they do today if not more so. In particular the plans to provide better leadership andsome additional resource to the Coastguard Rescue Service around the coast are a major step forward.

4. To date minimal actual changes have been made to the existing network of MRCCs although plans havebeen finalised for the closure of Clyde and Forth later this year. At the time of writing only the change of theboundary between Shetland and Aberdeen regions has been instigated. Appropriate information has been madeavailable to the lifeboat stations directly affected through local liaison, and a site visit and briefing meetingarranged for those stations transferring to Belfast MRCC’s area of co-ordination. However the timing of theprovision of some of the information to our central Headquarters has been a little tight if not late which hasleft little or no time to disseminate the information to the lifeboat stations before implementation. Hopefullythis will improve as further changes come to fruition

5. However, we would note that the closure of Forth and Clyde do predate the commissioning of the MOCwhich goes against assurances previously given on 22 November 2011 in the House of Commons, when MikePenning stated in reply to Sheryll Murray MP “no centres will close before the robustness of the system isdemonstrated. Should there be any blips in the system, I can assure my Hon. Friend that no station will closeuntil we have the level of resilience that we do not have today”.

Emergency Towing vessels

6. To date there have been no incidents where the absence of an ETV has particularly increased the risk tolifeboat crew but there have been examples where the lifeboat has had to stand by as the casualty vessels havefoundered before any alternative towing arrangements could be made in the absence of the ETV (eg F/V ChloeT on Saturday 01 September).

7. As an organisation we broadly agree with the findings of the previous Committee report.

Maritime Incident Response Group

As an organisation we broadly agree with the findings of the previous Committee report.

September 2012

Written evidence from Louise Pooley and Mike Hillen (CFU 22)

We are writing in response to the request for new evidence in regard to the changes to H.M Coastguard.

1. We are both coastal residents and as regular users of the coast not only locally but elsewhere in the UKthe impact of closing MRCC’s around the coast concern us greatly. We are both part of the Coastguard soscampaign group and have been from the beginning and have responded to the MCA on both of theirconsultations but feel that any responses to the 2nd one were ignored.

2. We have concern about the very real effect of the importance of local knowledge and the locally availablehelp, and knowing these “partners” well enough as having worked with them many times before.

We personally know the response time of seconds after a recent 999 call to the coastguard. We watched avery drunk man walk down the beach (Gelliswick Bay) and walk into the sea and decide to go swimming after



watching him for a couple of mins it was apparent that he wasn’t capable of staying afloat and because he wasdrunk he wouldn’t feel the cold of the water. We called 999 and asked for the coastguard as soon as we saidthe location (which wouldn’t always be known by the caller) I was asked to wait a couple of seconds whilethe coastguard officer requested the assistance of a local port authority boat as it was just around the corner togo and assess the situation from the water. The call didn’t last too much longer but before the end of that callthe Port Authority boat had arrived at the scene and was updating the MRCC with the situation. We feelresponse times as quick as this will be lost with the initial call going to the MOC.

3. After assurances that no station will close before the new system has been fully tested, it seems that plansare going ahead to close Forth MRCC in three weeks time, and Clyde MRCC before the end of the year.

4. The importance of an MRCC spread regularly throughout the UK, during the last year there has beenrescues of vessels which have only been actioned because the MRCC nearest to the vessel has picked up avery faint radio call for help, and if the MRCC had closed it stands to reason that the call would not of beenheard and the situation could have ended with the deaths of the crew.

5. No full risk assessment has been carried out with station specific risk assessments, this is importantbecause each station has its own risks associated with it such as geographical location, the topography of thearea, the extent of type of uses of the coastal area it covers and also the risks that can be experienced whichcan be completely different to users in another part of the uk. We believe for a proper risk assessment thereneeds to be individual in depth assessments for each station facing closure.

6. The lack of proper response from organisations involved in Search and Rescue such as RNLI, when theRNLI gave evidence to you at the last inquiry it was said they didn’t know they could respond. We would sayas these are one of the major SAR groups in the UK each RNLI member should be asked for their opinion onthe closures, Some RNLI staff have said that if the local MRCC closes it’s going to be harder to carry out aSAR operation as they know how the staff in the MRCC works and have a very good working relationship,These volunteers have very good local knowledge but unless the MRCC co-ordinating (which can be over 100miles away) know the area well enough the wrong team could get sent out increasing the time before a casualtyis located and rescued.

7. We believe the Isle of man is increasing is coastguard service because of concerns over safety onceLiverpool MRCC is closed, the reason they give is because of concerns over loss of local knowledge.

8. We find it difficult to get to grips with the fact in many situations when the Government has been quizzedover the closures when asked a direct question they seem to skirt around the answer, leaving us as the generalpublic to think that they don’t have the answers and are more concerned with saving money than improvingthe coastguard service (which we are for) improvement is good, but not at the expense of peoples lives.Numbers of SAR operations are already up this year on this is only set to increase with the greater use of thesea and coasts buy many groups of people.

9. It may seem strange but there are still a significant number of people in the public who are very unawarewhat is planned for the coastguard service in the UK and are very shocked when told about it, there was asmall amount of air time at the start of the process but since then not much has been said, we believe that ifthere was more public knowledge then there would be a considerably larger number of people against theclosures, but not against the modernisation of our coastguard service, it’s a public service, the public need itto be reliable and there for if and when they need it.

Main Points

1. Background.

2. Local knowledge and personal experience.

3. Closures before full testing of system.

4. Need for nearby local radio reception.

5. No full risk assessment.

6. Lack of response from SAR organizations.

7. Increase in Isle of Man Coastguard cover.

8. Avoidance of Direct questions.

9. Small amount of public knowledge of future of coastguard service.

September 2012



Written evidence from Dennis Laird CFU 23)

1. As a volunteer Coastguard with over 31 years service, I have serious concerns at the impact the changesto the service are having.

2. Taskings for Coast Rescue Teams (CRTs) are normally routed via Operations Rooms at Maritime RescueCoordination Centres (MRCCs).

3. With the proposed changes to the service, and the consequent planned closure of the MRCC at Liverpool,there is difficulty in recruiting suitably qualified personnel for the Ops Room at that location.

4. As a consequence, the local knowledge and level of experience by some of the watchkeeping staff isbeing diluted. This is not a criticism of the staff, but a reflection of the reality of the impact of the plannedchanges to the service.

5. Staff are being appointed, either temporarily or permanently, to positions for which they do not haveenough relevant qualifications or experience. In practice, this means that decisions that they would normallybe expected to make are referred upwards through the chain of command for approval or ratification. This canhave a serious impact on service delivery, and introduces an unnecessary “dogleg” in the chain of command.

6. Financial pressures are having a direct impact on the ability of Coastguard Rescue Officers (CROs) tocarry out the duties which are expected of them. Training hours have been reduced in the Liverpool District toonly 24 hrs PER YEAR, to maintain the competences and skills required to safely deliver water rescue, mudrescue, boat operations, and the core skills required of any Coastguard.

7. Preventive maintenance of key equipment is now being replaced by reactive or breakdown maintenance.In other words, equipment failure is not pre-empted, but dealt with as it occurs. Whilst this may be acceptablefor some equipment, it is felt by CROs to be an ill judged decision, and one which will inevitably havepotentially very serious consequences.

8. Changes to well established safe procedures are being unilaterally introduced with no consultation withCROs, and no evidence of, or involvement in, pre change risk assessments to identify and quantify the impactof those changes.

September 2012

Written evidence from the Outer Hebrides Coastguard Task Group (CFU 24)

1.1 The Outer Hebrides (OHCTG) is an inter-agency group who came together in 2010, to jointly campaignagainst the proposals brought forward by the Maritime and Coastguard Agency (MCA) for the modernisationof the Coastguard Service and to bring forward alternative proposals to those proposed by the MCA. TheOHCTG also campaigned against the decision by the UK Government to withdraw Emergency Towing Vessel(ETV) provision. Membership of the Task Group includes the Member of UK Parliament; the Member of theScottish Parliament; Coastguard representatives; Comhairle nan Eilean Siar (Western Isles Council); StornowayPort Authority and Western Isles Fishermen’s Association.

1.2 The OHCTG welcomes the Transport Committee’s continued interest in the modernisation of theCoastguard Service and how the UK Government’s changes to the service are being implemented.Representatives of the OHCTG would be happy to provide oral evidence to the Committee if asked

1.3 The OHCTG carefully considered the proposals presented in the MCA document: “Protecting Our Seasand Shores in the 21st Century: Consultation on Proposals for Modernising the Coastguard 2010” as presentedin late 2010. Following extensive local consultation and detailed independent research, the OHCTG took theview that the MCA proposals were fundamentally flawed and would not enhance the Coastguard service.Indeed, the OHCTG took the view that the proposals, if implemented, would have increased risk and wouldhave compromised the safety of shipping and mariners around the UK in general and around the north andwest of Scotland in particular.

1.4 The OHCTG was pleased that the Transport Committee generally agreed with this analysis and that theCommittee, in June 2011, called for the Government to withdraw their proposals.

1.5 The OHCTG was equally pleased that the UK Government listened to concerns and that the Secretaryof State announced in Parliament, in July 2011, changes to the original proposals. In response to theconsultation on the Secretary of State’s amended proposals, the OHCTG took the view that the retention ofStornoway, Lerwick and Aberdeen as 24-hour Maritime Rescue Sub-Centres, was the right way forward andprovided that there was a well-planned, well-managed and adequately resourced approach to the introductionof the “new concept of operations” and related technology, that the new proposals adequately addressed theconcerns raised by the OHCTG in the initial consultation.

1.6 From an Outer Hebrides perspective the OHCTG is satisfied that the strategic solution is broadly theright one. The OHCTG understands that the implementation of changes is going reasonably well and that thereare no issues giving rise to significant concern. There will always, however, be issues when new changes arebeing implemented that will require close monitoring and scrutiny. At this stage goodwill is required from the



MCA to give the Service confidence in the way forward after a period of considerable turmoil. Sensiblecooperation is required between management and staff to ensure that any changes are appropriately managedand introduced. With these broad caveats, OHCTG is reasonably content with implementation at this stage

Withdrawal of The Emergency Towing Vessel

2.1 The OHCTG views the withdrawal of the ETVs as an entirely retrograde step. From the OHCTGperspective the case for a public-funded ETV service in the north and west of Scotland remains. That case ismost eloquently stated within the MCA’s own documents, particularly the “Emergency Towing VesselsAssessment of Requirements”, report complied by Marico Marine. That document states in its synopsis:

“The United Kingdom appears to have little option but to continue its involvement in the contractingof Emergency Towing Vessels (ETV). Lack of capability within the commercial tug and towagesector (in effect market failure), European Union obligations, and societal expectations (zerotolerance of major marine environmental incidents) combine to dictate the need for this contingentcapability. In cost benefit terms, averting one major shipping disaster and environmental incident ofthe scale of the Prestige would justify a contract price far in excess of that currently being paid untilits expiry in 2011 and beyond.”

2.2 The Executive Summary is equally unambiguous. It states:

“The present contract, which operates until the end of September 2011, deploys four relatively largetugs sourced from the offshore oil sector on permanent stand-by at four strategic locations (DoverStrait, the Western Approaches, the Fair Isle Strait and The Minch). They represent a major resourcecapability in seeking to avert a major merchant-shipping casualty (grounding, foundering, sinkingetc) and, in particular, a subsequent marine environmental pollution (oil and/or other hazardoussubstances) 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 controlto prevent catastrophic event escalation. The ETV may also be required to tow the casualty to alocation of safety, generally known as a place of refuge. This must often be achieved in a limitedtime frame, or window of opportunity, prior to the vessel incurring significant damage and losingstructural integrity, such as might follow being driven ashore, as seen in the loss of the tankersAmoco Cadiz and Braer, or simply succumbing to the elements, as was the case for the tankerPrestige. “

2.3 The ETVs were put in place following the recommendations of Lord Donaldson subsequent to the Braerdisaster. Shipping movements and tonnages have greatly increased since the Braer. Given increased activity, itis the view of the OHCTG that the loss of the ETV will inevitably lead to an incident, which will result indevastating impacts. The costs of any such incident will be significantly greater than any savings to be realisedthrough the ETVs’ withdrawal.

2.4 The 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 reportstates that is clear market failure.

2.5 The OHCTG is highly concerned that the Department for Transport and MCA remains of the view thatETV’s are in place as a ship salvage measure. In the view of the OHCTG this is a dangerous and fundamentalmisunderstanding of the reasons behind provision of the ETV. The primary function of the ETV is as outlinedat paragraphs 2.2 above.

2.5 The OHCTG was pleased that the UK Government appeared to accept these arguments with the settingup of the Scottish ETV Working Group to seek resolution to ETV provision issues. The OHCTG also welcomedthe announcement in June 2012 that the Government will continue funding one ETV for the duration of thepresent spending round.

2.6 The contracted vessel is the “Herakles”, a specialist anchor handling and towing vessel with a bollardpull of 160 tonnes. It is stationed on a day-to-day basis in Orkney and its operational area will be from thenorth of Shetland to the south of the Outer Hebrides.

2.7 Although the OHCTG is pleased that this vessel has been secured there is serious and widespreadconcern that one vessel is not adequate to cover the area involved. From an operational perspective it is difficultto see how the ETV could cover the distance between Orkney and south of Barra in heavy seas and weatherconditions, particularly if the weather is against the direction of travel. If the vessel happened to be in watersnorth of Shetland when an incident occurred in the southern Minch, there is little prospect of it being able toreach the scene of the incident in sufficient time to make a meaningful intervention.

2.8 OHCTG is therefore clearly of the view that a two-vessel solution remains essential for the north andwest of Scotland.

2.9 The OHCTG appreciates (but does not agree with) the Government’s position that a market solution isrequired for ETV provision. The OHCTG also understands that the Scottish ETV Working Group is in



discussion with Oil and Gas UK in regard to putting in place a “Framework Agreement” that will potentiallyallow commercial ETV provision in the north of Scotland.

2.10 In the west of Scotland, a market solution will emerge in due course as the off-shore renewablesindustry moves to maturity. Although there are a number of dependencies in regard to industry maturity, presentmarket intelligence suggests that a reasonably strong industry could be in place around 2018—20. Industryrequirements have to be explored and fully scoped, but it is believed that there is potential, in due course, toput in place a second “Framework Agreement”, with the renewables industry.

2.11 Through both the Oil & Gas and the renewables sectors there are good prospects for a market solutionto emerge in the medium to longer term. The OHCTG takes the view that the UK Government has to fully faceits responsibilities in the meantime and ensure a two ETV solution during the present period of market failure.

2.12 The OHCTG believes that The Crown Estate (TCE) may have a significant role to play here and shouldbe directed by Government to make a significant contribution to the provision of an ETV during the period ofmarket failure. It is self-evident that the ETVs have historically safeguarded and will continue to safeguardTCE assets and income through fish-farm and other leases in the waters in the Highlands and Islands.Furthermore, the growth of the renewables sector will provide significant additional revenues to TCE, by wayof new leases. This new income should be diverted into supporting ETV provision, thereby effectively securingan early industry contribution towards the cost of the ETVs.

2.13 In regard to the Maritime Incident Response Group (MIRG), the OHCTG remains of the view that thewithdrawal of the MIRG is a detrimental step that significantly lessens capacity to react to and appropriatehandle marine incidents. The present arrangements are no real substitute for a specialised, well-trained, highlymobile, dedicated response group.

2.12 In summary the OHCTG takes the view that:

— The withdrawal of ETV provision is an entirely retrograde step. ETV provision is essential inorder to protect mariners, the local community, the local environment and the local economyin the north and west of Scotland.

— There is clear market failure in the area, with the commercial sector unable to provide ETVprovision at this time. With market failure clearly demonstrated there is a fundamental duty andresponsibility on the UK Government to act.

— The OHCTG has welcomed the provision of one ETV for the rest of the spending roundperiod, but do not believe that this one vessel will be able to provide adequate cover. Thisleaves the area exposed to both human and environmental dangers.

— The OHCTG recognises (but does not agree) with the approach of the UK Government.Nevertheless representatives of the OHCTG have sought to fully engage with the process overthe past period in order to assist the UK Government reach its goal of an industry-led solution.

— An industry-led solution may exist. This solution, however, is a medium to long term prospectthat will require the renewables industry to reach maturity. A clear, industry-led ETV exitstrategy therefore exists for the UK Government.

— Near-term Government action and intervention is required to provide adequate cover throughthe provision of a two ETV solution, while the exit strategy is developed and executed.

— TCE, through present and future revenues being extracted from the Highlands and Islandsshould provide a financial contribution to the near-term provision of two ETVs. Given that TCErevenues are collected via lease revenues on industry, this contribution should be viewed as aprivate-sector, market contribution.

— Representatives of the OHTCG are willing and able to work closely with the UK Governmentto fully implement this type of approach.

— The OHCTG views the withdrawal of the MIRG as a highly detrimental step that significantlylessens the capacity to react to an incident at sea.

September 2012

Written evidence from Save Milford Haven Coastguard Campaign (CFU 25)

In February 2012, The National Assembly of Wales Petitions Committee published its’ report into theMaritime & Coastguard Agency in Wales with its particular emphasis on the MCA Modernisation Proposals.

The Report made two specific recommendations;

Recommendation 1. The Committee therefore recommends that the Welsh Government carry out a riskassessment that will both identify and seek to mitigate any risks to tourists and others who visit the coast forleisure purposes that might result if the Maritime and Coastguard Agency (MCA) proposals go ahead. Theproposed changes to the MCA is a matter for the UK Government but given the potential effects of thosechanges for people working on and visiting the shores around Wales, an independent risk assessment might go



some way to either alleviate some of the fears highlighted in this report or give the Welsh Government furthermeans to challenge the UK Government’s decision on this matter.

Recommendation 2. The Committee recommends that the Welsh Government continues to challenge theUK Government’s current plans to change the Maritime and Coastguard Agency, which will result in SwanseaCoastguard Station closing.

The report can be viewed in its entirety at the following link:

http://www.cynulliadcymru.org/en/cr-ld8808-e.pdf?langoption=3&ttl=CR-LD8808%20-%20Adroddiad%20y%20Pwyllgor%20Deisebau%20ar%20Asiantaeth%20y%20M%F4r%20a%20Gwylwyr%20y%20Glannau%20yng%20Nghymru

As a result of this report, the First Minister of Wales & Welsh Government issued a response:

Welsh Government response to the report of the Petitions Committee—Maritime and Coastguard Agencyin Wales

The Welsh Government has always said the proposals to close Coastguard stations in Wales were illthought-out.

The Welsh Government response to the consultation supported the retention of the Holyhead MRCC overLiverpool to address concerns over language issues in North Wales. However, the response neither supportednor opposed the proposals to close Swansea at the expense of Milford Haven.

The result of the last consultation was to retain Milford Haven & Holyhead and to close Swansea before the31 March 2015.

Detailed Responses to the report’s recommendations are set out below:

Recommendation 1

The Committee recommends that the Welsh Government carry out a risk assessment that will both identifyand seek to mitigate any risks to tourists and others who visit the coast for leisure purposes that might resultif the Maritime and Coastguard Agency (MCA) proposals go ahead. The proposed changes to the MCA is amatter for the UK Government but given the potential effects of those changes for people working on andvisiting the shores around Wales, an independent risk assessment might go some way to either alleviate someof the fears highlighted in this report or give the Welsh Government further means to challenge the UKGovernment’s.

Response: Accept

I have written to the Under Secretary of State for Transport Mike Penning MP proposing that he commissiona full and independent assessment of the risks associated with the consequences of the closure. This reviewwould look at the maritime and coastal safety provision as its first priority but would also take into accountthe related issues of tourism, employment and economic development. I have suggested that it would need tobe mindful specifically of the impact this closure could have on our future inward investment aspirations,especially the deep water harbour in Port Talbot which I hope may become a hub for commercial maritimetraffic and an additional level of consequent risk.

Financial Implications—I am prepared for the Welsh Government to jointly finance such a review given theimportance of this matter and funding will be met from existing resources.

Recommendation 2

The Committee recommends that the Welsh Government continues to challenge the UK Government’scurrent plans to change the Maritime and Coastguard Agency, which will result in Swansea CoastguardStation closing.

Response: Accept

I will continue to challenge the UK Government’s current plans

As things transpired, The First Minister of Wales wrote to Mike Penning MP offering to part-fundindependent risk assessments.

This option was refused by the UK Shipping Minster.

To date, Independent Risk Assessments have not been carried out.

September 2012



Written evidence from Murdo Macaulay (CFU 26)

I am writing this in response to your call for further evidence on your investigation regarding changes to theCoastguard service.

I am a serving officer with HM Coastguard and have thirteen years service as of April this year. I submittedevidence to the enquiry on the initial consultation which was, in common with the majority of evidencereceived highly critical of the consultation plan. I was also involved in giving evidence to the Select Committeein Stornoway as part of the Save Stornoway Coastguard campaign group as a union representative. Since thenthe original consultation was revised as a result of the overwhelming evidence presented pointing to the flawswithin it. As a service we are now in the process of implementing the revised plan for ”Future Coastguard”.

I have found it difficult to prepare this document because from my viewpoint little is certain—the workneeding done to reach the new Coastguard structure moves on, with input from serving officers at most levelsand ”work packages” identified and progressed with operational input. The MCA is listening, and indeedactively seeking input from, those with operational knowledge as this plan is implemented.

However—little has been decided regarding critical operational detail and operating procedures and at thispoint it is hard to judge whether the plans announced in November 2011 by Mike Penning in Parliament willresult in an effective service, or if they will deliver the promised improvements. The MCA must be held toensure that the ethos of the second consultation document is upheld as we move into the Future Coastguardservice and there is no ”creep” back towards the original plan.

I still find it hard to understand how the MOC will interact with the other Stations and because we are at anearly stage of implementing the plan there is little concrete information on this critical subject. Manning levelsat the remaining stations seem too low (this point is very pertinent as we prepare for the imminent closure ofMRCC Clyde with no network in place to provide support).

I remain sceptical that support can be effectively provided by a centre as remote as the MOC will be inmany cases. Much work is being done on data analysis to determine exactly what loads stations are under asthey co-ordinate incidents but it is true to say that this is hard to quantify as many processes in a co-ordinationcentre are unable to be accurately quantified.

In conclusion, it seems to be that the current management of the MCA are open and honest in their desireto work with practitioners to develop the working practices which will define the Future Coastguard model.But it is too early to judge the effect the re-organisation will have on the service provision.

Murdo Macaulay

Watch Manager

HM Coastguard

Stornoway

September 2012

Written evidence from Sandra Beech (CFU 27)

I ask that the committee investigate:

During a meeting of the MCA Executive Board in April 2012, it was stated that they should include a riskon the Corporate Risk Register that the future Coastguard programme will not achieve it’s expected benefits.

The MCA states that the closure of Clyde and Yarmouth stations are due to the expiry of their leases,however, both can be negotiated for an extension.

No stations should be closed before the new centre at Fareham and all the operational systems are fully triedand tested.

September 2012



Written evidence from Martin Caton MP (CFU 28)

I believe that the Coastguard “modernisation” exercise undertaken by the Government in 2010–2011 wasdeeply flawed, was driven by determination to reduce costs rather than improve the service and will jeopardizesafety around our coasts.

Responses to Parliamentary Questions that I put down to the Department of Transport, and Freedom ofInformation requests to the Maritime and Coastguard Agency in relation to Swansea Coastguard Station,demonstrate that the MCA failed to use its own set down criteria to establish which station to retain.Remarkably, it also became evident that the Agency had no effective method of applying its criteria in makingvital decisions.

The evidence below relates primarily to the Maritime Rescue Co-ordination Centres [MRCCs] based inMumbles in my constituency, but I believe the failures of process shown are likely to have been reflected indecisions made about Coastguards around the UK.

1. At the start of the first “Protecting our seas and shores” consultation exercise, the MCA drew up its“location matrix impact assessment and sub-centre rationale” supposedly to inform its decisions about retentionand closure of MRCCs. This should have been applied in assessing Swansea in that exercise and thencomparing Swansea and Milford Haven in the second round of consultations.

2. After the end of the first round, Ministers announced that there was “Little to choose between Swanseaand Milford Haven” and it was felt that as the DFT had already had many employees in the Swansea area atthe DVLA and Shared Services Centre, it would be more appropriate to locate the sub centre at Milford Haven.This was a perverse decision for two reasons. First, as I show below, applying the MCA’s own criteria, it isnot true to say that there was “little to choose” between the two centres. Second, the Milford Haven area hasconsiderably lower levels of unemployment than the Swansea area, so the Government was taking jobs awayfrom a relative jobless blackspot to protect jobs in an area of high employment!

3. One important factor identified in the MCA’s location matrix and impact assessment is the need to bestutilize the agency’s existing property portfolios, saying, “This is particularly the case where there are otherMCA functions currently co-located with an MRCC. MRCC Swansea is housed in a purpose built MCA ownedbuilding which also includes an aerial site, the Wales and West Regional Business Unit, the MCA CivilContingencies Manager and the South and West Wales Coastal Safety Manager. It is 574.5 square metrescompared to Milford Haven’s 418.3 square metres, including a large EPR room, large conference room andextra office space, often used by MCA surveyors. This was, in any case, the more flexible building to retain.

4. A second criterion to be employed, according to the MCA, was population. It said, “Sub-centres wouldmost sensibly be located in areas with a reasonably large population and pool of job seekers to facilitate futurerecruitment”. The population of Swansea City alone is 235,000 with a far larger employment catchment areain reasonably close proximity. The combined population of Milford Haven, Haverfordwest and Pembroke isjust 31,000. This had already caused problems. According to a Written Answer I received from the ShippingMinister, there had been a real difficulty in recruiting coastguards in Pembrokeshire. Of the most recent sixcoastguard appointments to Milford Haven, only two were from Pembrokeshire, the others coming from otherparts of Wales, including Swansea.

5. The document also stated, “It does, however, make intuitive sense to have the MOCs and sub-centresevenly spread around the coast”. Closing Swansea in order to retain Milford makes the network less evenlyspread.

6. Finally, it said, “The broad co-location of a co-ordination centre with the volunteers of the CoastguardRescue Service, other Search and Rescue partners and local regional resilience fora is a further factor to beweighed in the overall assessment of preferred sub-centre locations”. MRCC Swansea is located within a shortdrive of at least five coast rescue teams and has a strong working relationship with the CRS. Swansea hasexcellent road and rail travel links, facilitating contact with SAR partners and resilience fora. Swansea currentlymanages five sectors containing 26 CRTs and 28 RNLI and independent lifeboats, as well as liaising with 20emergency control rooms.

7. In December 2011, I made a Freedom of Information request to the MCA about how the location matrixand impact assessment criteria had been employed in both consultation rounds. This revealed that no scoringsystem of any kind had been used in the Agency’s assessment in either. This, in my view, means that thereview process could be neither properly objective nor adequately transparent. If it would be useful, I canprovide the Committee with copies of the Written Answers and Freedom of Information responses that informedthis submission.

Martin Caton MP

September 2012



Written evidence from Richard Drax MP

Introduction

1. The Portland search and rescue (SAR) helicopter operates in an area with the highest number of call outsin the UK. The base is located between Beachy Head and Dodman Point, where one quarter of all incidentsco-ordinated by HM Coastguard around the UK (including Northern Ireland) occur.

2. The helicopter is formally tasked to maritime rescues, commercial, light and military aircraft crashes,French SAR for mid Channel incidents, as well as supporting the emergency services on shore and othermajor events.

3. Maritime Coastguard Agency (MCA) accounts show that the Portland helicopter costs between £4 millionand £5 million per annum. And, despite operating for only 12 hours a day, it is tasked every year as frequentlyas the 24-hour, SAR helicopter at Lee on Solent (Solent).

4. In addition, since 2007, the Portland helicopter has never dropped below 7th out of the 12 existing baseswhen it comes to number of tasks.

5. In November 2011, Transport Secretary Justine Greening announced that the Portland SAR helicopterwould close in 2018. In her letter to South Dorset MP Richard Drax, confirming the decision, she wrote: “Idid not undertake any consultations before announcing the new basing arrangements since I am improvingthe service.”

6. I disagree and this paper argues for the retention of this vital, life-saving service.

Background

PFI

7. The PFI (The SAR-H Private Finance Initiative) arrangements, established under Labour to finance theUK’s SAR facilities, were cancelled by the Coalition in February 2011. Instead, the Department for Transport(DfT) announced it would tender for a new, 10 year, UK-wide service contract, in the Official Journal of theEuropean Union.

Criteria

8. Key user requirements (KUR) include: 98% availability; take off within 15 minutes by day and 45 minutesat night; range of 170 nm; arrival at very high and high risk areas within 60 minutes of take-off (total from callout: 75 minutes by day and 105 minutes at night); ability to hover on scene for 30 minutes, without refuelling.

Civilian contract

9. The MOD, which retires its aging fleet of Sea King helicopters by 2016, would be the first of the currentSAR providers to be replaced by civilian contractors, providing complementary services through a mixed fleetof modern helicopters.

Modern aircraft

10. DfT modelling suggests that modern helicopters operating from just 10 bases, rather than the current 12,would provide a faster and more reliable service. Consequently, operations from RAF Boulmer and MCAPortland would end.

The Case for Retention

Call outs

11. The coastal area around Portland is a focus of intense marine activity, especially during the summer. Theneed for its own helicopter cover is proven. One quarter of all coastguard callouts in the UK SAR area in 2011were within the Portland, Solent and Brixham areas.

No consultation

12. The UK SAR committee was not formally consulted over the closure of Portland. Neither was the LocalResilience Forum, which is especially concerned at future safety implications when both the Portland helicopterand the local Maritime Rescue Co-ordination Centre (MRCC) have gone.

Responsibilities

13. The Portland helicopter is requested, via the ARCC (Kinloss) or HMCG, by Dorset police, Fire Brigade,South West Ambulance Service (the air ambulance is grounded at night), French SAR authorities, commercialaircraft “Pan” and “Mayday” alerts, in addition to its SAR duties.



Air ambulance

14. In addition to no night flying, the air ambulance frequently cannot access the casualty because it is notfitted with a winch. Neither is it large enough to carry intensive care teams for hospital transfers between, forexample, Dorchester and John Radcliffe in Oxford. Consequently, the Portland helicopter is regularly taskedfor air-ambulance-style work.

Winch

15. In the support role for civil contingencies, the local coastguard helicopter is particularly effective andunique because it is equipped with a winch.

16. This capability was essential during the Boscastle and Cumbrian floods, the Dorset floods earlier thisyear, rescues on Bodmin, Exmoor and Dartmoor, the salvage of the MSC Napoli and for other operations asfar afield as the Severn, Wales, Cheltenham and the Channel Islands.

Air show

17. The Portland helicopter was also used to recover the Red Arrows’ pilot, who crashed at last year’sannual Bournemouth air show.

More recently, it attended the cliff fall at Burton Bradstock, quickly inserting a search dog and handler andthen patrolling 16 miles of coastline also thought to be at risk.

Extra time

18. Relying upon alternative helicopter bases at Solent and RNAS Culdrose (Culdrose) will add an averageof 25 minutes extra flying time from the former and 40 minutes from the latter and only then when they arenot tasked elsewhere.

Example

19. On 20 August, 2012, the Portland helicopter was tasked to search for a four-year-old boy who’d fallenoff a jetty into the River Severn at Burnham. The Solent helicopter was sent to a concurrent incident atLulworth Cove, well inside the Portland patch. Under plans proposed, the Solent helicopter would have beensent to Burnham. Who would have covered Lulworth Cove and how long would it have taken?

Water

20. With casualties often in the water, when minutes count, any extra time is unacceptable and potentiallyfatal.

National Sailing Academy (Academy)

21. The successful Olympic Sailing Games has opened up great potential for the Academy, based onPortland, which has been looking to attract major, international maritime events. In addition to advanceddiscussions on other events, the Academy has been selected as a “candidate city” for the Volvo Ocean Race,to host a stopover in both 2015 and 2018. The presence of the helicopter is clearly significant in relation to allof the current and anticipated activity at the Academy.

Divers

22. The south coast is a very popular site for divers, with an abundance of wrecks. It is estimated there aremore than 2,000 divers in the water between Swanage and Lyme Regis over a Bank Holiday weekend.

Incidents

23. There were more than 50 diving incidents in a year off Portland, with the helicopter reacting withinminutes to each emergency. Ninety per cent of divers rescued needed decompression in a hyperbaric chamberwithin the “magic hour”, after which chances of permanent injury rise sharply.

24. The Solent helicopter requires a minimum response time of 40 minutes to reach Portland. Therefore 45divers a year could be at risk if the helicopter is axed.

Portland Port

25. It is the UK’s newest and fastest growing port, with rapidly increasing cruise ship operations, anexpanding shipyard, bunkering, other marine activities and the possibility of a new cross Channel ferry service.Three hundred vessels a day pass within 20 miles of the port when they transit the English Channel, the world’sbusiest shipping lane.



26. Interestingly, Torbay Council is planning a third harbour for cruise liners, with obvious implications forSAR cover within Portland’s remit.

27. There are at least three serious incidents a year in the south western sea area, for which Portland Port isan important refuge. A recent example is the MSC Napoli which, having foundered in high seas, could onlybe approached by the Portland helicopter during the critical first phase of the rescue operation because ofcontainers in the sea.

Emergency towing vessel (ETV)

28. And with the loss of the ETV at Falmouth, a far greater reliance will be placed on Portland Port’s marineemergency response team, including the Portland helicopter.

Flaws in the Analysis

29. The DfT analysis, upon which the Transport Secretary is relying, was based upon a grid analysis on thefrequency of callouts. That is overly simplistic and inadequate for an emergency service. Some grid squareswould have had dozens of incidents in a year while others would have had none.

30. Without referring to areas with the highest number of incidents (eg, Portland), the assumption that 10bases, equally spaced, could provide cover across the UK is clearly flawed.

31. The DfT’s own “Assurance Review of Search and Rescue Helicopter Basing”, conducted by Atkins,points out a number of flaws in the analysis used to revise the current system:

(a) The report says that the use of Excel has resulted in static modelling with no representation oftime-based events within the modelling. “Therefore items such as concurrency and availabilityare not being used in factoring the overall capability to achieve the response times required.”

(b) In other words, some factors critical to this service, and which could affect the delivery of theservice, were not modelled.

(c) In addition, Atkins says that modelling “simply calculates times for helicopters to travel thedistance from a base to the centre of a risk cell based on an assumed speed.” This, they say, is“not particularly complex” and “not undertaken using established good practice”, although theyfound no “gross errors”.

(d) Atkins also point out that the data used is historic and does not take future variations in needinto account. In view of the rapid expansion of Portland Port, a proposed offshore wind farm(circa 300 turbines), a new wreck/reef diving site, and the new sailing academy, this need couldgrow exponentially.

(e) Atkins also states that 99.8% of incidents occur when five aircraft or fewer are availablenationally. A KUR is that all bases must be able to respond to multiple incidents concurrently.Cutting the number of helicopters available overall must have an impact on this.

(f) The modelling took no account of “down-time” for the both the aircraft and aircrew after andoperation. Therefore, the value of having a second airframe at high readiness is debatable if atired crew is unable to fly it. Crew fatigue grounded the Solent helicopter, Rescue 104, threetimes this year.

(g) Technically, regular maintenance will mean that a second aircraft will not be readily available,even if a crew is.

Integrity

32. Critically, helicopter coverage along the south coast is complementary, with each base frequentlycovering for the other. Removing a helicopter would destroy this integrity when demand surges.

Access

33. Dorset is one of the few counties without a motorway. Only a helicopter can guarantee speed of responseand access to remote locations. Fewer aircraft overall would undermine that capability.

34. Faster aircraft might improve reaction times, but less of them would mean fewer incidents beingattended simultaneously.

Availability

35. The odds of incidents occurring simultaneously on a summer’s day are high. For example, on 23occasions in the last year, the Solent helicopter was not available because it had been tasked. It’s logical,surely, to station a helicopter where it is needed most.



Political compromise

36. Whilst the equal spacing of assets around Britain’s coastline may appear “fair”, it smacks of a politicalcompromise and makes no sense in view of the fact that 25% of all incidents are located in one area.

37. The KUR stipulation that a helicopter should not take more than an hour to arrive on scene would notbe possible for a Portland rescue if, for example, the Solent helicopter was even 30 minutes to the east of itsbase when a call came in.

38. No matter how modern, fast and reliable a helicopter is, it can only be in one place at one time. It’s alsoworth noting that Solent will have to take over Portland’s responsibilities in the Channel Islands, thus removingit from the UK mainland for some time.

Teething problems

39. What is also forgotten is that modern or “new” aircraft are not immune to design faults. An incidentcould ground a helicopter, as was the case with the AW139.

Search time

40. It is irrefutable that helicopters at Solent and Culdrose would take longer to arrive at local emergenciesthan the Portland one. That would mean a longer search, over a wider area, at greater cost and with a lowerchance of success.

Wear & tear

41. The MCA estimates that the loss of the Portland helicopter would mean alternate machines flying anextra 8,900 nautical miles, costing £250,000 a year. And that’s without additional crew costs, refuelling timeand aircraft wear and tear.

Quantity

42. The Secretary of State wrote in her letter of 18 February, 2012, that 20 helicopters would be availableat any one time: “With more aircraft able to take off more of the time under the future contract, there will bea greater overall likelihood of helicopters being able to attend incidents where they are most needed.”

43. That cannot be correct. Only 10 crews would be available at any one time—which means 10 helicoptersflying—and even allowing for this, the analysis takes no account of rest time, refuelling and off-task time.

44. Culdrose responded to 242 callouts last year, only 14 of which were in the Portland area. Relying moreon Culdrose would inevitably place greater strain on the system.

Weather

45. Extreme weather is becoming more frequent and projected to become more significant in the future. Itis no coincidence, therefore, that in recent weeks, the Portland helicopter responded frequently to cliff fallsand floods.

Local View

No consultation

46. All those with an interest in retaining the Portland helicopter—the emergency services, medical teams,businesses, holiday organisations, neighbouring MPs and virtually all significant maritime bodies on the southcoast—are appalled at not only the decision making process, but its conclusions.

47. The complete lack of consultation, the presumption that faster, newer helicopters from further away cando the same job as one based in the immediate vicinity and the conviction that a basic grid analysis is theappropriate tool to base such an important decision, are totally unsound.

48. Unfortunately, those with an intimate knowledge of SAR operations feel constrained from speaking forfear of losing their jobs. The Select Committee should therefore consider asking understandably reluctantwitnesses to give evidence, in addition to those who are not restrained.

49. Portland is a strategically vital forward operating base for the military, Royal Flight and VIPs visitingport and Sailing Academy). Aircraft can also refuel, as they did for the recent and lengthy search for thePurbeck Isle, a small fishing boat which foundered with the loss of her three crew. If Portland had been closed,the Solent helicopter would have been off scene for at least an hour in order to refuel.



Value for money

50. Genuine savings should not be cited as a factor in closing Portland, which costs less than half of a24 hour SAR base. Using DfT figures for traffic deaths, preventing only four deaths a year would pay forthe service.

51. During the recent July floods, the Portland helicopter rescued eight people in life threatening situationson just one day. Using DfT figures, the helicopter paid for itself twice over.

Closure of the MRCC

52. The general thrust of this paper argues for retention of the helicopter, but the planned closure of theMRCC next year is equally concerning. Like the helicopter, it is local, manned by watch-keepers who live inthe area and know it intimately.

53. This knowledge enables them to best co-ordinate an incident and to task the most appropriate assetquickly and efficiently.

54. The planned new co-ordination centre in Hampshire, dealing with a far larger area, will simply not meetthe existing service, with operators becoming swamped by minutiae, especially when dealing with severalincidents simultaneously. It is no accident that army units, both large and small, have their own independentops rooms.

Conclusion

55. When examining the role and workload of the Portland helicopter, it is immediately apparent that theservice is exceptionally good value for money.

56. It is located strategically in the centre of all activity, helps to retain the integrity of all SAR cover alongthe south coast and is tasked as much as its 24 hour neighbour (Solent), despite being a 12 hour station.

57. Dorset attracts 16 million visitors a year, even without the Olympics. Many of these visitors take topleasure craft, walk on the cliff tops or enjoy the plentiful beaches.

58. Danger does not discriminate and the Portland SAR helicopter, quite apart from the professionalism andcourage of the crew, is a reassuring and vital asset for our beautiful but sometimes deadly coastline.

59. To withdraw it would be an act of sheer folly, especially when the evidence for retention is so clear. TheTransport Secretary has a duty of care to my constituents and to the millions of others who visit Dorset andthat must be a valid argument for retention.

60. Finally, before Ms Greening was moved from her post, I had invited her to the constituency to hear theviews of those intimately involved in SAR three times, but was ignored. Her decision not to consult wasbreathtaking, especially on such a serious issue, and I wonder whether it breaches any guidelines or regulations.

61. At the time of submitting this report, a Government reshuffle has seen Ms Greening replaced by PatrickMcLoughlin and Mike Penning by Stephen Hammond. I shall be writing to both ministers, asking to see them,personally, and inviting them down to meet and listen to all those involved in SAR in South Dorset.

62. Finally, a newly launched e-petition on the Government website had attracted over 10,500 signatories ina month. It can be found at: http://epetitions.direct.gov.uk/petitions/36619

September 2012

Written evidence from Dr Ian Mew

Executive Summary

1. As the leading doctor responsible for severe traumatic injuries in the area that the Portland CoastguardHelicopter is based, I have severe concerns that closing this rescue facility will lead to a significant loss oflife. Its closure will leave large areas of coastline uncovered and will hamper the ability of clinicians to receiveand transfer severely injured casualties within the timeframe required to save their lives. Using thegovernment’s own statistics, the financial cost to society from these additional deaths will in my opinion befar more than the cost of running the Helicopter base.

Myself

2. I am a consultant in Anaesthetics & Intensive Care Medicine at Dorset County Hospital. I am also theClinical Director for Major Trauma at this Hospital. I sit on the Wessex Trauma Network Board and haveadvised on both clinical and operational management of severe traumatic injuries for many years. I am alsothe Force Clinical Governance Officer for Dorset Police. In the past I have worked with many agencies in thefield of Major Incident Resilience, including sitting at Government Office South West to co-ordinate masscasualty arrangements.



3. Through my duties, I have an intimate knowledge of the operation of the Portland Coastguard Helicopter,having received many casualties from them at my hospital and through transferring critically ill patients totertiary hospitals for life-saving care, which was beyond the capabilities of our hospital.

Factual Information

Medical Perspective

4. The effective management of casualties with severe traumatic injuries requires the patient to be treated ina hospital capable of managing all of the patient’s injuries early on. This is a time dependent process if livesare to be saved and with the launch of Major Trauma Networks across the UK this year, the need for patientsto be delivered rapidly to a Major Trauma Centre has increased. Dorset County Hospital is a Major TraumaUnit and very severe, multiple or complex traumatic injuries exceed its capabilities. As such the need forpatients with severe traumatic injuries to be flown directly from the scene to the Major Trauma Centre inSouthampton has increased significantly. Southampton University Hospital has had a helipad built specificallyfor this purpose.

5. The Portland Coastguard Helicopter covers the coastline of the South of England and a high percentageof its work is retrieving casualties from cliff accidents or accidents in remote locations along the coastline.Many of these patients require direct transfer to either the Major Trauma Centre or a Major Trauma Unit by air.

6. The Portland Coastguard Helicopter is also well suited to the transfer of critically ill patients from aDistrict General Hospital to Tertiary Hospital elsewhere in the UK as the increased footprint of the helicopterallows access to the whole of the patient, as opposed to the head & torso only (tradition is for the rest of thepatient’s body to occupy the tail section of other helicopters). This allows for a safe transfer from the patient’sperspective and allows the accompanying critical care clinician to do their job more effectively with morespace for medical equipment.

Air Asset Availability

7. Use of the Police Helicopter for patient transfer requires the removal of an observer module to lose weightand make space for the patient and doctor. Because of this, the Police helicopter does not often transfercasualties, but it can if no other helicopter is available, or the number of casualties exceed available resources.With the formation of the National Police Air Support service, NPAS, (where the local police helicopter willbe relocated and serve a greater area when on duty) the availability of the local Police helicopter for patienttransfer will be reduced. Similarly, when the local Police helicopter is not on duty, Dorset will be “covered”by a helicopter from another county. The Police air assets are therefore more likely to be involved in Policeduties and will take longer to respond in the future thus further reducing the availability for the Police helicopterto be used in casualty transfer, increasing the need for the Portland Coastguard & Air Ambulance helicopters.

8. The Coastguard Helicopter is able to fly in adverse weather conditions when the local Air Ambulanceand Police Helicopters cannot. This is a very significant factor in our area of the UK. I personally transferreda critically ill eight year old girl with severe meningococcal septicaemia to the Paediatric Intensive Care Unitin Southampton by Coastguard Helicopter during the heavy snow one December. Roads were blocked and theAir Ambulance could not fly. This girl would have died had the Portland Coastguard Helicopter not beenavailable to us.

Demand

9. The South Coast of England is an extremely popular destination for tourists. Each summer we see asignificant increase in our population and with it and increase in the number of casualties from cliff accidentsand patients with medical conditions requiring evacuation from remote coastal locations where road vehicleshave difficulty gaining access. The waters of the South Coast are particularly popular for recreational divingand in the summer months, the Portland Coastguard Helicopter is frequently required to winch divers with



decompression sickness (the bends) from boats off of the South Coast and transfer them rapidly to therecompression chamber in Poole.

10. The English Channel is “the” busiest stretch of water in the world for shipping and is serviced by thePortland Coastguard Helicopter.

11. Portland Bill is a peninsular. It is notorious for its treacherous waters, but also its excellent fishing andbeautiful scenery of the Dorset Coast. The Portland Coastguard Helicopter is constantly involved in the searchand rescue of fishing boats, leisure craft and people kayaking.

12. The Portland Coastguard Helicopter is also frequently deployed in-land to transfer trauma casualtiesfrom remote locations to hospital when the air ambulance is either unavailable or due to the number ofcasualties requires assistance. The recent floods this July also saw people being plucked from the roof of a carby the Coastguard Helicopter team after their car was swept away by flood water. The Portland Helicopter hasbeen required to perform medical transfers originating in Wales which in my view demonstrates that air assetsare already thin on the ground without closing this rescue base.

13. The Portland Coastguard Helicopter base covers the stretch of the South Coast of England from StartPoint to Beechy Head. I understand that despite only operating for 12hrs a day, they are tasked to over 300jobs per year, compared to 360 jobs per year undertaken by the 24hr service at Solent. The Government’sproposal is to close the air base at Portland with the service at Solent covering the Start Point to Beechy Headarea. In view of the fact that the Solent Helicopter is already tasked to 360 incidents a year, this means thatwhilst the Solent helicopter is busy, a vast area of the South Coast of England will be unsupported and liveswill be at risk. The next available Coastguard Helicopter is at Falmouth, which if deployed East will not onlyleave the area of the Scilly Isles without Coastguard Helicopter cover, but because of the prevailing SouthWesterly winds in the UK, makes it more difficult to respond to incidents off of Lands End should it berequired to return urgently to its usual operating territory.

14. Dorset County Hospital was unusual in that despite being a district general hospital in the 1990’s, it hada fully operational helipad. This was built purely because of the local need for the Coastguard Helicopter to beable to access medical facilities in a timely manner and demonstrates the continuing demand for their presence.

Financial Implications

15. The Government’s own figures show that for every life lost due to trauma, the cost to society is in theorder of £750,000–£1.4 million. I understand that the Portland Coastguard Helicopter base costs approximately£5 million per year to run. I am fully aware that the Portland Coastguard Helicopter saves far more than fivelives per year and thus purely from a financial perspective, the cost to society will be greater should thePortland Coastguard Helicopter base be closed.

Recommendations for Action

16. Based on my working knowledge of the service delivered to the local community and beyond; theclosure of the Portland Coastguard Search & Rescue Helicopter Base will result in loss of life. I understandthat the availability of local air assets are due to reduce within the area with the formation of NPAS and thatdemand for air transfer of critically ill patients needs to increase to meet the demand of the National MajorTrauma Networks. In view of the vital service that this Coastguard Helicopter provides coupled with the factthat the financial cost to society without the helicopter would increase; I can only recommend that the PortlandCoastguard Helicopter Base be allowed to remain operational for the foreseeable future.

September 2012

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