The Coastguard, Emergency Towing Vessels and the Maritime Incident Response Group: Government Response to the Committee's Sixth Report of Session 2010-12 - Transport Committee Contents

Government response


Recommendation 1. We welcome the Minister's decision to extend the consultation on the modernisation of the Coastguard until after this Committee has reported. It is encouraging that the Department for Transport recognises that proper parliamentary scrutiny can improve the quality of ministerial decision-making. For something as important as the reorganisation of the Coastguard—where lives are potentially at risk—it is imperative that any proposals are thoroughly scrutinised before implementation. (Paragraph 4)

DfT Response: The Government, the Department for Transport and the Maritime and Coastguard Agency (MCA) have been fully committed to an open consultation process and have welcomed the opportunity to listen to the views of the public, the maritime community and staff on this important matter. The Government has also welcomed the attention paid to these issues by the Transport Select Committee and purposely awaited its formal report before making decisions about the next stage in the modernisation programme.

Recommendation 2. We were extremely disappointed that the Minister invoked rules which normally relate to senior civil servants to stop us from taking oral evidence from some of the serving and volunteer coastguards who had sent us written evidence. Regular coastguards have unique operational expertise and we wanted to hear their views on the record. The Minister's action was justified on the basis that "a formal public hearing, in the full glare of the media spotlight, risks encouraging individuals to express personal views in a way that may be at odds with their personal obligations under their terms and conditions of employment". In our view, the Minister should have shown more faith in the professionalism of the coastguards and stuck by his original commitment to the House to let them give evidence to the Committee. (Paragraph 7)

DfT Response: The Government believes that Ministers in the Department for Transport acted properly to protect junior civil servants in line with established Parliamentary protocol. Ministers consistently encouraged operational coastguards to share their views about the proposals for modernising Her Majesty's Coastguard with the Transport Select Committee, and the Committee consequently received written views. But the submission of written material is very different to junior civil servants appearing formally as witnesses before a Parliamentary Select Committee, where their role is to speak on behalf of the Government and their Ministers. That is a role properly reserved for Ministers, Permanent Secretaries, Chief Executives and other senior civil servants. However, in line with the arrangements made for all Parliamentarians during the consultation process, the Committee was given full and unhindered access to coastguards at any centre they asked to visit; the Committee visited Falmouth, Clyde and Stornoway.

The Coastguard


Recommendation 3. We recommend that any revised proposals on the future of the Coastguard should be subject to a further short period of consultation. Decisions with such significant implications for maritime safety should not be made in haste. We do not consider this decision to be sufficiently time-critical to prevent further consultation on what we expect to be substantially revised proposals from those initially put forward. (Paragraph 15)

DfT Response: The Government announced adjustments to its proposals on coastguard modernisation on 14 July 2011 and a second round of consultation on the changes will run to Thursday 6 October 2011.

Recommendation 4. We have been impressed with the quality and comprehensiveness of the alternative proposals put forward by coastguards across the country. The willingness of coastguards to engage thoughtfully and constructively with both the consultation process and our inquiry is welcomed. We expect the Government to demonstrate that the alternative proposals put forward by coastguards have been properly considered when revising its own plans for the future of the Coastguard. (Paragraph 16)

DfT Response: The Government has also welcomed the input of alternative proposals into the first round of consultation and was encouraged by the underlying acceptance for the need for modernisation. All consultation responses, including those alternative proposals, were reviewed by a team of operational coastguards independent of those who put together the proposals of 16 December 2010. The details of the 27 sets of alternative proposals were included as an annex to the Review Team's Report, published alongside the second consultation document of 14 July 2011.

The main elements of those proposals were:

  • a reduced number of Rescue Co-ordination Centres (retaining between 6 and 15 centres);
  • a geographic spread of stations to cover each devolved administration, minimise staff relocation, and maintain local knowledge;
  • 24/7 operations throughout, therefore retaining more staff;
  • support for investment in an upgraded communications network to improve national and territorial resilience;
  • limited support for the two Maritime Operations Centre (MOC) concept with concern over the lack of details about the operation of the MOCs and their relationship with other centres; and
  • limited support for the proposed changes to the Coastguard Rescue Service (CRS) and its revised management; also uncertainty around its operational interface with MOCs and sub-centres.

What was also clear however was that the status quo was not an option. With the contributions made in consultation in mind, the Government's conclusions on revised plans for a modernised Coastguard announced on 14 July 2011 are based on a single MOC and retaining 24 hour operations in a greater number of sub-centres, preserving local knowledge by retaining one station in each existing operating pair. The consultation document on the changes to the previous proposals also provides a description of the underlying national infrastructure and how this will give greater technical resilience. Supporting documents explaining how the new concept of operation will work, including arrangements for the CRS, are available on the MCA website. These explain how the enhanced availability of full time officers (rising from 80 to 105) supporting the CRS volunteers during operations and for leadership and advice during routine activities, offers additional support for the volunteers in their operational role, which remains unaltered.

Recommendation 5. By failing to involve serving coastguard officers, unions, volunteers, stakeholders or the devolved administrations in the drafting of the current proposals for the future of the Coastguard, and by failing to publish a risk assessment of the current plans or an impact assessment of the previous round of closures until prompted, the MCA management has badly miscalculated. It has mishandled the consultation and made it appear opaque rather than clear and open-minded. It has appeared arrogant, and reluctant to open itself to proper scrutiny in the process. The atmosphere of disquiet and suspicion generated by this consultation process is of the MCA's own making. (Paragraph 19)

Recommendation 6. The strength of opposition against the proposals we have encountered is such that, if, as the Minister has said, this is a genuine consultation, the proposals cannot be given approval in their current form. Decisions on the future of the Coastguard must acknowledge and draw on the wealth of expertise of frontline officers as well as others whose contributions could and should have strengthened the original consultation document. (Paragraph 20)

DfT Response: The proposals set out in December 2010 evolved from detailed discussions within the MCA over a period of at least three years. Discussions included nine meetings between management and the PCS Trade Union as part of an effort to resolve the ongoing industrial dispute with the coastguard staff. The discussions were built upon concepts first discussed with staff at MCA Staff Conferences in October 2007 and October 2008, which were attended by staff from around the MCA including many serving frontline coastguards. The concepts, including the development of a nationally resilient MOC, supported by a network of interlinked sub-centres, and the proactive monitoring of the seas around the UK, and equalising the distribution of work between centres, were further explored and tested during working group meetings throughout 2009 and into 2010 involving front line staff and PCS officials with coastguard experience. This effort culminated in the December 2010 proposals which would have included delivering better pay and progression for existing coastguards. Those proposals and the further adjustments announced on 14 July 2011 benefited from the input of staff with a wealth of operational experience over many years, from the alternative proposals put forward by staff in the first consultation and from the engagement through visits and meetings to MRCCs and with MPs by Ministers and senior MCA staff.


Recommendation 7. A geographic information system available to all watch-keepers across the UK network would be desirable, but we are not convinced that a database could replace the local knowledge of those coastguards who live and work in the communities in which they serve. The variety of place names, colloquialisms and local anomalies of the UK coast appear to us well nigh impossible to collate. We have serious concerns that insufficient local knowledge held by coastguards based in an MOC, perhaps hundreds of miles from an incident, will, in some cases, lead to the loss of crucial seconds and minutes during a rescue attempt. (Paragraph 25)

Recommendation 8. It is clear from our inquiry that 'local knowledge' has a much broader meaning than simply possessing knowledge of local coastlines, topography and geographical features. It also encompasses a Maritime Rescue Co-ordination Centre's (MRCC) intimate community ties, relationship with local emergency services and detailed knowledge of the appropriate voluntary teams to task to an incident. The current proposals would mean that operations room staff would largely lose situational awareness of this kind. We have not been persuaded that this loss would not diminish the speed and effectiveness of the Coastguard's response to some emergencies. (Paragraph 26)

DfT Response: In the first consultation we set out how the Maritime and Coastguard Agency would maintain a national memory bank and use the strengthened coastal safety management to give necessary local knowledge. However the Government recognises the strength of concern raised by both the Committee and those who responded to the first round of consultation that was launched on 16 December 2010. We made clear from the outset that we would listen carefully to all representations. To meet concerns about the removal of ties between the MRCCs and the local emergency services and the perceived loss of local knowledge, the modernisation plans announced on 14 July 2011 would see one existing centre retained in each pair of centres under the current organisational model plus both centres at Shetland and Stornoway. These centres would also remain open on a 24/7 basis. It is already standard practice that paired centres share and exchange information about situational awareness and local knowledge. The proposals to retain centres at Stornoway and at Holyhead will address concerns about the Gaelic and Welsh languages and more difficult place names. Although this would primarily be a national system, the concept of operations in the new proposals still provides as at present that distress alerts, whether from radio or the 999 system, would be routed in the first instance to the nearest coordination centre for handling.


Recommendation 9. We conclude that the MCA's current restructuring proposals, by significantly reducing the number of operations centres, risk placing too great a burden of responsibility on volunteers. It would be unreasonable to draw too heavily on volunteer coastguards for the kind of local knowledge that is currently held by operations room staff, but which would be largely lost under these proposals. There is a risk that excessive demands could diminish the willingness of people to volunteer as a rescue coastguard. (Paragraph 29)

Recommendation 10. We also conclude that the current proposals to close MRCCs have not adequately taken into consideration the role of the coastguard station as a recruiter and trainer of the network of local voluntary teams. The MCA should set out how this important function of the current MRCC structure will be maintained following any reorganisation. (Paragraph 30)

DfT Response: The Government is proud of the volunteers who give their time and energy to serve their communities in the Coastguard Rescue Service. There was never an intention that the original proposals set out on 16 December 2010 would add any burden on volunteers. In light of responses to the first consultation, we will continue with the plan to bolster significantly the leadership and training we give to our volunteers by putting an additional 25 operational staff into the Coastguard Rescue Service, organised into operational management teams that work together in professional support of the volunteers. Keeping more centres, operating them for 24 hours, and retaining 70 more operational coastguards in those centres will all offer greater reassurance to our volunteers that there is no intention to add any burden to their existing role.

The recruitment and training of CRS volunteers is not a current function of MRCCs and is carried out by a separate Sector Manager structure. Under our proposals the provision of 25 additional operational staff to carry out this function in local communities is significantly enhanced.


Recommendation 11. We are concerned that the MCA proposals regarding station closures and opening hours may be based on statistics that do not tell the whole story. The published figures show neither the seriousness nor duration of incidents. Any decision that is based on aggregated statistics may also fail to address regional differences. Robust empirical evidence should be the starting-point for any proposed restructure of an emergency service such as HM Coastguard. For the revised proposals to have greater integrity, we recommend that the MCA publish data for the number of staff hours per incident, disaggregated by region. (Paragraph 34)

Recommendation 12. The period of hand over between the sub-centre and MOC has been identified as a potential weakness in the MCA's proposals. If the MCA remains committed to the concept of daylight hour-only stations, it must demonstrate how the handover could be achieved safely. (Paragraph 37)

DfT Response: This was a strong concern from responses to the first round of consultation and the Government understands the worries about how the concept of operations would work in practice, particularly in relation to the notion of daytime only centres. The Government has now decided that all remaining centres should operate on a 24 hour basis with staffing arrangements to facilitate that. There are currently long established procedures that address the handing over of an incident from one station to another. One of the key advantages of the modernisation plan is that, with a networked organisation, any coastguard at any location is working on the same systems and has access to listen to all of the aerials. Thus the situation involves less handover and more a taking of control. This is very much like the process that occurs every day in every centre at the change of watch. Alongside the consultation document published on 14 July 2011, the MCA has made more information available at about how a Maritime Operations Centre with sub-centres would work in practice.

Following the Westminster Hall debate on 24 March 2011, the MCA published a significant amount of additional detailed incident data showing in detail the number and nature of incidents, by MRCC for each of the past 5 years. This provided the base data from which the extracts shown as graphs in the first consultation document were drawn. However, because of ongoing industrial action within coastguard coordination centres, information is not available in sufficient detail to allow the publication of data for the number of staff hours per incident, disaggregated by region.


Recommendation 13. It appears to us that the current proposals pay more attention to the MCA's statutory obligations towards the commercial shipping industry and far less to its obligations towards leisure craft and small boat users. Accidents involving commercial vessels represent only a small proportion of all those that the Coastguard manage. Revised proposals must show how the level of protection afforded to leisure users, small fishing vessels and the like will not be reduced as a result of any reorganisation of the Coastguard. (Paragraph 40)

DfT Response: Safety is the Government's top priority and it is committed to maintaining the level of service that all mariners and those using our coasts presently receive and could expect to receive in the future. Indeed, the proposals set out in December 2010, and adjusted in July 2011, enhance that capability by allowing for the redistribution of work at busy times across a national network so that a distress call can be heard and handled by any coastguard at any centre.

Retaining additional centres and increasing to 24 hour coverage at all locations will give assurances about communication with and the service provided to local leisure activity and fishing communities. This was also addressed within the original proposal by the 50% uplift in the number of professional coastguards who will be working with volunteer coastguards based in coastal communities. These professional coastguard will be the prime contact for local organisations including the leisure and fishing sectors. This represents an investment in the face to face contact and knowledge sharing with these sectors.

Recommendation 14. The MCA's proposals rely heavily on the use of upgraded technology in the operations rooms. In its revised proposals, the MCA must be much clearer about the nature and benefits of technology being proposed and how it differs from the existing technology that is installed in the current MRCCs. (Paragraph 41)

DfT Response: The second consultation document includes an overview on technology and it is accompanied by additional information provided as part of the 'supporting documentation' pack available on the MCA website.

The future design will see the same core technologies as we use today being used, but located and configured differently. It is proposed to connect the existing radio aerial sites to a centralised equipment stack located across two geographically separate locations; operator consoles at the MOC and all sub-centres will connect to these. This means that coastguards anywhere within the network will be able to access any of the radio aerials they need to carry out their operational duties. In the new technical design the national nature of the reconfigured information systems means that any coastguard can receive and enter information, thereby making it immediately available to all coastguards in the national network. This facilitates information sharing rather than information exchange. The single network approach for information systems such as Command & Control (Vision), Geographical Information (C-Scope) and Search Planning (SARIS) will enable all coastguards to have access to information held in these systems whenever they need it. More detail is contained in the Supporting Documentation in the IT Technical Brief (pages 33 to 38) on the MCA website.

Currently coastguards act on information passed to them which is subsequently stored within local information systems, a design which limits access for others outside of the current pairing structure. In the new technical design the national nature of those information systems means that any coastguard can receive and enter the information, making it immediately available to all coastguards in the national network.


Recommendation 15. The MCA has not satisfactorily explained why creating interoperability across more of the current centres is not a better way of increasing resilience in the current system than the wholesale change it has put forward. We recommend that its future revised proposals demonstrate how improvements in interoperability will add to the improvements already being made with the updating of the Integrated Coastguard Communication System. (Paragraph 43)

DfT Response: The current upgrading of technology through the MCA's Radio Equipment Replacement project does increase the interoperability between a number of centres, but it is limited and only allows access to some systems in up to four other locations from a single desk. This is the limit of interoperability possible with the current systems and is dependent on each of the 18 individual Integrated Coastguard Communications System (ICCS) remaining operable. A fully-networked national system as proposed, will provide full access to all information and systems from any other location, regardless of whether the ICCS is functioning. Only through a national network with a strategic Maritime Operations Centre at its heart can workloads be better managed through the redistribution of activity to cope with peaks and troughs.

A Maritime Operations Centre differs significantly from existing rescue coordination centres. It is the base from which all maritime functions are overseen, principally search and rescue coordination, counter pollution and vessel traffic monitoring. It is not limited geographically, but instead will be responsible for monitoring all UK maritime interests.

The MOC also exercises command and control over all coastguard operations nationally and generates a maritime picture using information from a variety of sources to enable the active management of risk in the maritime environment.

The MOC detects threats to safety, the environment and security at an early stage by comparing what is known to be normal routine activity with the prevailing situation, using information and intelligence. In this way the emphasis is moved to one of proactive working whilst retaining the ability to react appropriately to emergency situations. The MOC is sufficiently large and staffed to manage operations for which it assumes direct control, and actively to monitor and influence operations at other sites. It is sufficiently resilient in terms of staffing to absorb the very heavy initial demand that might be presented by a major incident or civil emergency. Heavy demands can come from a disaster, natural or man made, or a major maritime accident.

The decisions and actions taken early, if effective, can do much to mitigate the consequences. Currently such a demand would present itself at an MRCC that may have an inadequate watch level to deal with the initial scale of effort required, without ceasing other functions nor the ability to share that or existing workloads more widely. Reinforcing it can and does take time, many hours or even days, whereas a properly staffed MOC, supported by a wider network, can provide the resilience to ensure that such surge loading is managed effectively, including short term diversion of effort and resource from non-safety and non-time critical work. The maritime picture is also extremely useful to other government departments with an interest in energy security, border security, or offshore conservation or development.

The benefits will be to give greater flexibility on the use of available resources, and provide coastguards in coordination centres with opportunities to use their skills more often. More detailed information about the concept of operations for a national network and the information technology to support that was published alongside the consultation document of 14 July 2011.


Recommendation 16. The MCA's current proposals to modernise the Coastguard, as they stand, do not provide reassurance that the ability of the Coastguard to respond to emergencies at sea will be maintained at current levels, let alone improved. The evidence we have received raises serious concerns that safety will be jeopardised if the proposals proceed in their current form. We welcome the Minister's assurances that the final proposals will be substantially different to those that were consulted on. (Paragraph 44)

Recommendation 17. Our main concern about safety is the loss of local knowledge amongst coastguard officers that will inevitably occur under these proposals. Rationalising the number of MRCCs so drastically, in our view, will reduce the quality and rate of exchange of information, particularly at key points when information needs to be passed swiftly in order to save lives. We are not satisfied that this issue has been adequately addressed in the MCA's proposals. (Paragraph 45)

Recommendation 18. In particular, we are not convinced that the concept of daylight-hour stations should be proceeded with. Whilst there is general acceptance that there is scope to rationalise the number of MRCCs, there is a strong case for any future re-organisation of the Coastguard to be based on 24-hour centres in order to provide swift and expert assistance to people on local coastlines and in local waters, whatever the time of day. (Paragraph 46)

Recommendation 19. The Government should withdraw its modernisation proposals for the Coastguard and consult on revised plans that satisfactorily address the key issues we have identified. (Paragraph 47)

DfT Response: The Government announced modified plans for Coastguard modernisation in the light of consultation on 14 July 2011 and is now consulting on the changes from the previous consultation. The second consultation document is available at

Those revised plans provide for:-

  • a single 24 hour MOC based in the Southampton/Portsmouth area with 96 operational coastguards.
  • Dover would be configured to act as a stand-by MOC for contingency purposes with 28 staff and retaining its responsibilities for the Channel Navigation Information Service.
  • a further eight centres, In addition to the MOC and Dover, all of which would be open 24 hours a day with a total staffing of 23 in each based at:
    • Aberdeen
    • Shetland
    • Stornoway
    • Belfast
    • Holyhead
    • Milford Haven
    • Falmouth
    • Humber

In addition London Coastguard would be retained unchanged.

A further consultation on the changes to the previous proposals will run until 6 October 2011. The consultation is focused on four matters: the shift to a single MOC; the retention of both Shetland and Stornoway with both operating 24 hours; the retention of Holyhead rather than Liverpool; and the retention of Milford Haven rather than Swansea.

Emergency Towing Vessels

Recommendation 20. The decision to cease the MCA's provision of the Emergency Towing Vessels, which was made without consultation and against the findings of an independent risk assessment, is unwise and short-sighted. It is, quite literally, inviting disaster. We are not convinced that anything has happened since Lord Donaldson's report to lead to the conclusion that ETVs are no longer required. On the contrary, we have heard of several occasions on which the intervention of an ETV has averted a major incident. ETVs represent a prudent, and seemingly cost-effective, insurance policy for the British taxpayer. It would take just one major accident and any savings that had been made by the decision to cease the contract would be wiped out in a stroke. We urge the Government to reverse its decision to terminate the provision of ETVs through the MCA. (Paragraph 58)

Commercial Tugs

Recommendation 21. Our evidence strongly suggests that there is no suitable commercial alternative to the Emergency Towing Vessels. A harbour tug has neither the ocean towage capacity nor the bollard pull that an ETV possesses. Unless the Government can provide a persuasive case that such capacity exists in appropriate form and at appropriate locations, it should recognise that the solution it has proposed is unviable and potentially reckless. (Paragraph 62)

Alternative Funding Sources

Recommendation 22. The Government is the guarantor of last resort for the protection of our marine and shoreline environment, and for the lives of those in peril on our seas. That duty, we conclude, would be best discharged by responsibility for the provision of Emergency Towing Vessels resting with the state. However, we recognise that there is a strong case for finding other sources of income to help cover their costs. We note that the Government is brokering discussions with the ETV working group in pursuit of a solution to this problem. But the indications we have received are that these discussions may take some time. It would be unacceptable for the UK shoreline to lie unprotected if no agreement has been reached by 30 September. In such a scenario, the Government should make exceptional provision by extending the ETV contract over the winter, giving the ETV working group a further six months in which to resolve the issue. (Paragraph 65)

DfT Response: The Government recognises the Committee's concerns, but continues to believe that responsibility for ensuring the operational safety of ships is properly a matter for the commercial shipping industry, working in partnership with the tug and salvage industries. The Government has had to take difficult decisions as part of its wider strategy to reduce the fiscal deficit, and it is simply not appropriate for the taxpayer to underwrite a responsibility on operators.

The current contract for the provision of ETVs will end on 30 September 2011. The MCA has been facilitating discussions with interested parties about commercially-based arrangements that will apply in future.

The Government is satisfied that there is sufficient commercial tug capacity to provide an acceptable response to disabled vessels that break down in the vicinity of the Dover Strait and the South-West approaches. The waters off the Shetland and Orkney Islands can be reached within reasonable time by tugs that operate at Sullom Voe or by vessels that service the offshore industry to the west of the Shetland Isles.

The situation in the waters off the Western Isles is different because no suitable commercial tugs operate in the area. A working group comprising locally interested parties has been considering how at ETV could continue to be provided without recourse to Government funds. The Shipping Minister, Mike Penning MP, met the ETV Working Group at Inverness on 25 July 2011 to discuss its work to secure funding for the continued operation of ETVs, in particular the ETV that operates from Stornoway. During this meeting the Minister explained that the Government would consider extending the provision of an ETV capability in the vicinity of Stornoway by up to six weeks beyond the determination of the extant contract. Such extension would be subject to the working group being able to demonstrate a certain plan for future funding in reasonable time to allow Government to procure the necessary short term capability. It is now for the Working Group to respond to that challenge.

In readiness for the end of the ETV provision, the MCA is making arrangements for shipping to be alerted in the areas affected. The relevant coastguard coordination centres will actively monitor shipping using the automatic identification system and will be proactive in contacting ships that are observed to be stopped at sea or behaving erratically. Coastguards will monitor tug availability in the waters around the UK and will encourage ship masters, owners and their insurers to take early action to summon tug assistance should ships get into difficulty or become disabled. Coastguards will also advise the principal salvage and towage brokers about the existence of disabled vessels so that they can match market capabilities with demand.

Separately the MCA will review and maintain the Coastguard Agreement on Salvage and Towage - CAST. This establishes pre-agreed terms for the hire of tugs which, subject to availability, can be engaged to assist vessels that get into difficulty or which are disabled. This will help to provide tug assistance of last resort, with the cost being borne by Government. It will also serve to provide the Secretary of State's Representative - SOSREP, with the means to exercise his powers of direction and intervention on maritime salvage.

Maritime Incident Response Group

Recommendation 23. Though the Maritime Incident Response Group (MIRG) has been involved in only seven incidents, its intervention has been significant. Our evidence suggests that while ships' crews have some training their skills do not match the expertise of the MIRG. It is equally clear that without MCA funding, the MIRG will cease to operate. The operations of the MIRG are a matter of national resilience and responsibility to fund them should not be left to the local taxpayer. We are concerned that, as with the Emergency Towing Vessels, the Government has again taken a decision driven by the impetus to reduce expenditure that runs against an independent risk assessment. We recommend that the Government adopt a rationalised MIRG model which is better calibrated to the risk and more cost-effective than the present arrangement. (Paragraph 65)

DfT Response: The Government recognises the value of the Maritime and Coastguard Agency and coastal Fire and Rescue Services working together to support firefighting at sea. The MIRG has provided a good example by which the work of autonomous Fire and Rescue Services (FRS) can be coordinated and made inter-operable. In the majority of incidents when MIRG has been deployed to ships on fire at sea the tasking has served to exercise and demonstrate the validity of the MIRG concept for inter-operability rather than to contain or to fight the fire.

In considering future options the MCA has consulted the Chairs of the 15 participating Fire and Rescue Authorities. Two have notified their decision to withdraw from the MIRG because of their own funding pressures. The remaining thirteen have indicated that they will not be able to maintain an inter-operable capability if central funding was stopped although four have indicated that it will be their intention to maintain an ad hoc capability.

The MCA has also consulted MIRG representatives to the Chief Fire Officers Association (CFOA). The MCA hoped that these discussions would provide the basis for agreement to a reduced level of MIRG response that could be calibrated to the underlying operational requirement and be capable of operating more cost effectively than the current arrangements. This envisages a fire assessment capability that could be deployed onboard ships at sea to advise and reassure port authorities that a ship could be safely accepted into a port so that shore based fire fighters can attend to the fire. Such agreement has not been possible because FRS systems of work require a minimum of 12 persons to attend onboard, one of the reasons being that they will not deploy fire fighters to the scene of a fire without the capability to fight or at least contain the fire. The CFOA have determined that the lowest acceptable level of MIRG provision would be an organisation half the size of the current arrangements, operating in a similar way but at approximately two thirds of the cost. This would continue to provide the full fire containment activity - which is seldom able to arrive on scene in time to have a material effect on the outcome of a fire, but would not fulfil the operational requirement to assess and provide advice about the situation.

As a result the Government intends to discontinue the MIRG arrangements in accordance with the terms of the MIRG MOU and to put alternative arrangements in place for fire assessment and advice using commercial salvors.

Recommendation 24. It is regrettable that the Department for Transport announced all three sets of maritime proposals with no prior consultation whatsoever and did not consider their combined impact. (Paragraph 79)

DfT Response: Announcements in relation to the Comprehensive Spending Review were not matters on which prior consultation was appropriate. The Government set out its intention to Parliament on 20 October 2010. As explained at that time, the intention to reform both the coastguard and the Maritime Incident Response Group would then be subject to further consultation, both of which subsequently took place.

The Government does not accept that there is a combined impact of the three issues raised in the Committee's report. The three areas of work each addresses a different aspect of the Maritime and Coastguard Agency's work. Although they all take place in the maritime environment and are safety activities, each has a different role and the safe implementation of each does not impact on the others.

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