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

Written evidence from Matthew Mace (MCA 73)

Consultation on proposals for modernising the Coastguard 2010.

1) Most current Coastguard Watchkeeping Officers accept that there is need for change and some have been pushing for it. The industrial action, which has involved strikes, has still not been resolved. The main area of dispute is the low level of pay that Coastguard Watchkeepers of all grades earn for the current work they do and the responsibilities that they bear. The proposals in the consultation will do nothing to address this. The consultation leapfrogs the issue with a vague promise of better pay, but that will be for those that remain (approximately half the existing staff) and will be for jobs with even more responsibility. This is an important point of context that should be remembered.

2) The consultation document is vague on many points and is downright misleading on many others. In particular:-

· 2a) Statements such as the "system which is some 40 years old" pages 7 and 15. The only thing that is 40 years old is the change from visual lookout to radio watchkeeping using remote sites. The numbers of stations has steadily reduced over the last 40 years after previous reviews and the equipment has been upgraded or renewed several times.

· 2b) Loading. The graph used to demonstrate existing "loading", "demand" and "workload" by time, on page 17 is purely based on the time a button on a keyboard was pressed to create an incident. It does not measure the duration or severity of the incident. Yet this graph in particular is used to show how "busy" stations are and forms the basis of much of the consultation. In my experience night time incidents tend to be more complex and last longer because they are more likely to be commercial vessels that only request assistance when they really need it. They operate further offshore in deeper and rougher water, while any resources available take longer to get on scene due to the distances involved and their reduced night time readiness state. I only have access to data from MRCC Aberdeen but the graph I have produced (below) and using only SAR incidents, shows the difference that taking account of duration of incidents makes. At the "busiest" hour of the day (2 - 3pm) there are just over twice as many incidents ongoing (84) as start (38). At the "quietest" hour of the day (5 - 6am) there are 7 times as many incidents ongoing (28) as start (4). The "busiest" hour is over 9 times as "busy" (38 compared to 4 incidents) as the "quietest" hour when only accounting for start of incident. When taking into consideration the duration of incidents this difference is reduced to 3 times (84 compared to 28 incidents). I am not claiming that this measures workload (unlike the consultation document!), but it does smooth out somewhat the peaks and troughs. If the MCA wanted to accurately measure workload they could. They could take into account duration and severity of incidents as they did the last time we went through a major review - before the closure of Pentland, Oban and Tyne Tees Coastguard stations.

· 2c) Costs. Again on page 17. Quote - "Peak periods at the busiest stations are over 20 times as busy as the quietest stations at periods of lowest activity, yet the latter will have the same number of officers on duty." The consultation document measures how "busy" a station is by how often and at what time a button on a keyboard was pressed. The accuracy of that has been disputed above. The number and grade of staff on duty at any Maritime Rescue Co-ordination Centre (MRCC) over any 12h shift is currently based on a dynamic risk assessment of the staffing level required given the historical demand at that time of year and day, together with predictable events such as school holidays, programmed events and medium range forecast weather. Following these risk assessments there is no way that the "quietest" and "busiest" stations would have the same number of staff on duty and it is a lie to say so. When risk assessments allow, any staff not required to be on watch can undertake other duties such as training, liaison visits etc.

· 2d) Resilience. It is true, under the present system, that if both MRCCs in a given pair are affected by a problem then communication links cannot be transferred to another station. This would lead to no, or very limited, service provision to a significant part of the UK coast. When all the equipment is in the two MOCs as is proposed, they will effectively act as a pair. Should a problem affect both those sites then there will be no service provision to the whole UK coast. This would hopefully be a very rare event but the consequences would be dire. You do not increase overall resilience by concentrating equipment and resources into fewer sites. You do it by increasing the numbers of connections between existing sites to allow for a more distributed workload over many routes. There is also no mention in the consultation document of a third backup centre to the two MOCs but it has been mentioned in some of the public meetings.

· 2e) Connections to radio sites. It is not clear what connections each MOC will have to the coastal radio sites. If each MOC had direct access to every site throughout the country that would be great. However what is intended, I understand, is that each MOC will be connected to every site in its part of the country and a selection of key sites in the other half. Should a MOC suffer a major problem then the remaining MOC will provide a full service to one half of the country and a reduced one to the rest.

· 2f) Shift patterns. It is claimed that the current pattern is rigid. It is only as rigid as the staff working it. Many Watchkeepers already swap shifts around in order to cover the staffing levels that are required as a result of the risk assessment and consequently reduce the overtime cost. On this station the overtime is invariably caused by short notice staff sickness which any system has difficulty in coping with.

· 2g) Changes to the Coastguard Rescue Service. I am less concerned by the changes proposed here. However, it does seem to be becoming a top heavy structure. The main problems that current Sector Managers face are to do with too much paperwork and not enough paid training hours allocated to the Coastguard Rescue Officers. Neither of these are addressed in the consultation.

· 2h) Part of the changes to the Coastguard Rescue Service is that they would deliver the co-ordination function for land-based incidents. I think that this would be an improvement but it would have to be very carefully defined, particularly as to who is responsible for determining the area(s) to be searched. The new MOC or sub-centre would still be far better placed to co-ordinate the actions of any vessel or aircraft assets involved along the shoreline even if they were not responsible for determining the search area(s).

The future - assuming we go down the route proposed.

3) It would appear to me that the number and location of stations required is being driven by cost rather than need. The MCA may well admit to this if pressed. Other than being on the coast within a reasonable catchment area for future recruitment and with good telecommunication and transport links, the location does not matter. This however will be a real local issue. What does really matter is the number of sites remaining and the period they are open for. As an experienced Watch Manager who hopes to remain a watchkeeping Coastguard for quite a few years yet, I cannot stress enough how important it is that any station remaining open does so 24h a day. If stations are open for less, then there has to be a hand over to, and from, a 24h station twice a day. This cannot be face to face and cannot involve any paper information such as chart plots etc. Important information will be lost and it is so unnecessary. Make every station a 24h station. Each station retains full defined responsibility for a stretch of UK coastline. Using risk assessments (like now) adjust the manning for day/night and seasonal demand. Reduce the proposed MOC manning to account for this but keep the 24h Shift Leader and possibly all the Team Leader posts at the MOCs. Decide how much equipment is needed/can be afforded and where best to install it. Interconnect the remaining stations as much as possible to provide resilience. Two MOCs each with 3 x 24h sub-centres would be a much better arrangement than two MOCs with 2 x 24h stations and 5 x 12h stations.

4) Pay levels and details of working patterns will be crucial. The historic low pay has to go. Pay levels in the new structure will have to be increased by at least 50% for equivalent work in order to correct the long term slippage, reflect the enhanced work and encourage new employees with the right skills and attitude. We are already seeing evidence of Coastguards deserting the sinking ship, particularly at stations that are to be closed under the proposals. Ask what the current full-time staffing level is at Yarmouth or Forth MRCCs compared to what it should be if there were no vacancies.

Emergency Towing Vessels

5) They are costly but so are the consequences of a large vessel spilling oil cargo or bunkers into the sea. The reasoning behind their inception has not changed. They do other work such as civil hydrography and could do much more such as cadet training. A straight forward cost/benefit analysis should be undertaken by an independent body and the results accepted by the Government.

Maritime Incident Response Group

6) For the numbers of times these groups are used and the difficulties in deploying them, particularly in more remote areas, I would suggest that they can no longer be justified.

March 2011