House of Commons - The Coastguard, Emergency Towing Vessels and the Maritime Incident Response Group

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The Coastguard, Emergency Towing Vessels and the Maritime Incident Response Group - Transport Committee Contents

3 Consultation on the future of HM Coastguard

11. The structure of Her Majesty's Coastguard is currently based on 18 Maritime Rescue Coordination Centres around the UK (Figure 2), which are grouped into nine pairs (Figure 3). Watch-keeping staff in the MRCCs provide a 24-hour service to mariners and coastal users by receiving incoming distress calls and tasking appropriate resources to their rescue. The rescue unit personnel are often volunteer coastguards, either the MCA's own 3,500 volunteers (part of the Coastguard Rescue Service) or members of the Royal National Lifeboat Institution or the National Coastwatch Institution (4,800 and 2,000 volunteers respectively).[10]

Figure 2: Maritime Rescue Co-ordination Centres by region

Region Centre Area Covered

Scotland and Northern Ireland Shetland MRCC Shetland Islands, Fair Isle and the Orkney Islands

Stornoway MRCC Arnamurchan Point to Cape Wrath, Barra Head to Butt of Lewis

Aberdeen MRCC Cape Wrath to Doonies Point

Clyde MRCC Mull of Galloway to Ardnamurchan Point, including the Islands of Jura, Gihga, Islay, Arran, Coll, Tiree, Mull, Bute and Cumbrae

Forth MRCC Doonies Point to Anglo-Scottish border

Belfast MRCC Between Northern Ireland/Irish Republic borders at Lough Foyle and Carlingford Lough

Wales and West of England Region Brixham MRCC Topsham to Dodman Point

Falmouth MRCC Dodman Point to Marshland Mouth, Devon/Cornwall border

Swansea MRCC Marsland Mouth to River Towy, Carmathen

Milford Haven MRCC River Towy to near Friog

Holyhead MRCC Near Friog to Queensferry, River Dee

Liverpool MRCC Queensferry to the Mull of Galloway

East of England Region Humber MRCC Anglo-Scottish border to Haile Sand Fort

Yarmouth MRCC Haile Sand Fort to Southwold

Thames MRCC Southwold to Reculver towers, Herne Bay

London Coastguard Shell Haven Point, Egypt Bay to Teddington

Dover Coastguard Reculver Towers to Beachy Head, Belle Tout

Solent MRCC Beachy Head to Hants/Dorset border including Isle of Wight

Portland MRCC Hants/Dorest border to Topsham

Source: House of Commons Library

Figure 3: Current structure of HM Coastguard coordination

Source: Department for Transport

12. The DfT launched its consultation on modernising the coordination of Her Majesty's Coastguard on 16 December 2010.[11] The Government argued that the current system, based on 18 MRCCs grouped into nine pairs, is not well placed to respond to current challenges because it has limited resilience and an uneven distribution of the workload, especially during busy periods.[12]The MCA proposes to introduce a nationally networked system based on two Maritime Operations Centres (MOCs) equipped to manage all incidents wherever they might occur (Figure 4). These would be located at Aberdeen and the Southampton/Portsmouth area,[13] with a 24-hour centre at Dover looking over the Channel traffic separation scheme. In addition, the proposals provide for five other sub-centres operating during daylight hours, located at Falmouth, Humber and Swansea, with a further two sub-centres at either: Belfast or Liverpool; and Shetland or Stornoway. Were these changes implemented, ten existing regional MRCCs would close.[14] The MCA proposes to reduce staff numbers from 596 to 370 over a four-year period.[15] By the end of March, the consultation had received over 1,200 submissions.

Figure 4: MCA proposed structure for HM Coastguard coordination

Source: Department for Transport

13. The proposed changes to the system of coordination, job losses and cuts to the MCA's budget come at a time of increased workload for HM Coastguard Service. The number of incidents to which the Coastguard has responded has risen every year since 2000, from 12,016 to 21,195 incidents in 2009. The number of deaths involved in such incidents increased from 236 to 403 over the same period.[16]

14. In this chapter, we examine the various arguments for and against the MCA's modernisation proposals, and we make specific recommendations about how they can be improved. We conclude the section by giving our overall opinion of the proposals, based on the evidence we have received.

The consultation process

15. A theme throughout our inquiry has been the conspicuous absence of any prior consultation about the proposals with coastguards, unions, volunteers, stakeholders or the devolved administrations.[17] No-one we spoke to formally or informally had been consulted on the detail of the plans. Murdo Macaulay, PCS Stornoway Branch, said: "[The consultation] has been done the wrong way round. We should have had this process as a service before we moved to a plan, not issue a plan and then move to this process in public as a service."[18] We found that the majority of coastguard officers do not object to modernisation per se, but they take issue with aspects of the current proposals and the manner in which the MCA has conducted the consultation. In oral evidence the Minister acknowledged that the proposals are "not perfect" nor "set in stone" and told us that he will "come out with different proposals" when the consultation closed.[19] The Government has committed to make an announcement about the modernisation of the Coastguard before 19 July.[20]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.

16. The Minister has, on several occasions, publicly encouraged coastguards to submit alternative proposals for the future structure of the Coastguard to the MCA consultation. We also received several detailed alternative proposals as evidence to our inquiry. Although we are not in a position to analyse in detail all the alternative proposals we received, 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.

17. The consultation document was not accompanied by a published risk assessment. Sir Alan Massey, Chief Executive of the MCA, explained to us in February that risk assessments had been carried out at every stage of the preparation of the consultation document, but he had chosen not to publish them as there was no explicit requirement to do so.[21] The MCA later published a risk assessment spanning several documents on 10 February. We received detailed critiques of the risk assessment documents from several witnesses.[22]

18. Regrettably, the MCA also chose not to publish an impact assessment of the closures of Oban, Pentland and Tyne Tees stations in 2000 and 2001, as recommended by our predecessor Committee.[23] It took a further request from us before the MCA produced an assessment of these closures. This found no evidence that the closures of the stations had affected the conduct of coastguard operations, although two fatal accident inquiries examining the actions of HM Coastguard were underway at the time of writing.[24] Though the previous round of closures were of a different scale, it should have been obvious that an assessment of its impact would be essential information for evaluating the current scheme.

19. 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.

20. 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.

Savings

21. The Coastguard Service currently costs £35m a year to run with a further annual £6m of capital expenditure.[25] The MCA calculated that to maintain the current structure with essential upgrades and compliance would cost £173m over the next four years (or £639m over 25 years) at net present value.[26] By contrast, it calculates that its proposals would cost £153m over four years (or £516m over 25 years) at net present value. This represents a saving of £20m over the four years of the spending review period (or £123m over 25 years) at net present value.[27] The Minister admitted that the savings represent a "tiny amount of money".[28] The MCA argued that it is the inefficiency of the current system, not the prospect of a reduced budget that is driving change. Sir Alan Massey told the Committee this is shown by the fact that the modernisation project started well before the current Government took office.[29]

Local knowledge in coastguard stations

22. Watch-keeping staff in the existing 18 MRCCs receive incoming distress calls (via the monitoring of emergency radio frequencies or by 999 calls) and task appropriate resources to their rescue. Coastguards currently have to sit an exam in local knowledge in order to make an effective response. Some MRCCs, such as Milford Haven, test their officers on a yearly basis.[30] The current DfT Target is that appropriate rescue units, who are often volunteers, should be tasked within five minutes in 98% of incidents.

23. The consultation document rests on the assumption that local knowledge is best stored and shared in Geographic Information System (GIS) based format made available to all watch-keepers across the UK network as opposed to holding knowledge in local MRCCs.[31] Sir Alan Massey told the Committee: "[Lord Donaldson] put some very strong arguments against local knowledge being held in people's minds and that this needs to be better used across databases using modern geographic information systems because it is just too unreliable to leave it in people's heads."[32] Philip Naylor, Director of Maritime Services at the MCA, admitted that though there will be a requirement for coastguard officers to have a degree of coastal knowledge and knowledge of the maritime domain, it is unlikely that it will extend to the level of detail that is currently set out. He also confirmed that the current DfT target that appropriate rescue units should be tasked within five minutes in 98% of incidents will still apply.[33] While admitting that the MCA's public meetings have for the greater part failed to convince the maritime public that the proposals properly address the issue of local knowledge, the Royal Yachting Association agreed that "it is more important for the 'dispatched' to have a good working knowledge of their areas of responsibility; the dispatcher only needs what is necessary to manage incidents."[34]

24. This position was disputed by all of the coastguard officers we spoke to, who felt that their role had been devalued by the proposals. Murdo Macaulay, of the PCS Stornoway Branch, told us: "We are responsible for the coordination of an incident; we are not simply call takers who take a call, put it on the map. We are responsible from the infancy of that incident until, essentially, it is closed."[35] Carol Collins argued that, "being a part of the community, being a team where you can draw on each other's local knowledge is the key to it".[36] Some argued that databases cannot replace human local knowledge, or 'situational awareness', of tidal anomalies and currents,[37] technology black spots,[38] or local geographical and logistical knowledge in relation to the types of rescues local teams attend, such as mud rescues and cliff edge falls.[39] Databases, Google Earth and other GIS Systems will have difficulty recognising nicknames, colloquial place names and Gaelic spelling.[40] In written evidence, Eric Greenough argued that the depth and familiarity of local knowledge hastens the tasking of the local coastguard team thus reducing their response time.[41] Paul Kirby, of the PCS Liverpool Branch, argued that the new system created several "dog legs" in the system, which increases the possibility of losing contact with the person reporting the situation.[42] Many doubt that local knowledge will effectively be migrated to the MOCs.[43] We also heard concerns that on the west coast of Scotland, the widespread use of Gaelic would be a particular problem for staff at MOCs, a point which Sir Alan Massey conceded.[44]

25. 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.

26. 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.

Volunteers

27. Under the MCA's proposals, the regular Coastguard will draw more heavily on the local knowledge provided by the volunteer Coastguard Rescue Service and increased liaison with partner search and rescue organisations.[45] Michael Vlasto, Operations Director of the Royal National Lifeboat Institution (RNLI) told the Committee that he did not see the proposals as an increased burden on his organisation. Mr Vlasto added that only five out of 201 lifeboat stations around the country responded to the RNLI's own consultation.[46] However, the National Coastwatch Institution (NCI) argued that local knowledge will not cease as a result of the changes. Coastguard auxiliaries and NCI watch keepers are regularly assessed on their local knowledge.[47]

28. Others argued that it would be unfair for an MOC to place the burden of responsibility for local knowledge onto volunteers or expect them to do any of the work that is currently done in operations rooms.[48] A volunteer coastguard was concerned that he would receive a greater number of telephone calls under the proposals than at present, including at night-time, perhaps only because coastguard officers based in the MOC required local information to locate an incident. This could deter volunteers from joining the service.[49] We were also warned of the impact that station closures might have on volunteer recruitment and retention. Brian George, of the PCS Liverpool Branch, argued that the interaction between volunteers and the MRCC, which might involve school and community visits, is a vital relationship.[50] In written evidence, the Northern Ireland Executive expressed its conviction that the existence of a staffed coastguard centre acts as a major factor in attracting and maintaining volunteers for the Coastguard Rescue teams, and that areas that lose their MRCC are in danger of losing many of their volunteers.[51] Others warned that the previous round of station closures had damaged the relationship with volunteer groups. Alex Dodge, of PCS Shetland, told us of the feelings of mistrust towards her station among volunteers in Orkney following the closure of Pentland, while Murdo Macaulay, PCS Stornoway, told us that it had taken ten years to build a good working relationship with the volunteer teams on Oban following the closure of their local station.[52]

29. 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.

30. 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.

Daylight hours

31. If the current proposals are implemented three Coastguard centres would be open 24 hours a day, in contrast to the 18 that are currently open on that basis. Five sub-centres would be open during daylight hours only. Sir Alan Massey said that "[B]roadly speaking, we are looking at early morning to mid-evening as opening hours because that covers the maximum spread of load".[53] According to figures presented in the consultation, 70% of incidents occur between 0900-1900hrs (peaking at 1500hrs with 2,500 incidents).

32. Many witnesses argued that the consultation document is based on flawed or misleading statistics. The figures are simply an incident count; there is no weighting as to the nature or severity or duration of the incident.[54] The Royal Yachting Association told us that from these statistics, "it is not apparent, for example, what the distribution of incidents that require the deployment of assets and a high level of management might be and whether in fact these incidents show a different demand trend that is not addressed by these proposals".[55] Others argued that though there are fewer incidents at night on the south coast of England, the same is not true for Scotland.[56] Bob Skinley said: "Some of our severest incidents will happen precisely during the hours when the MCA thinks it is safe to close coastguard stations: at night, during the winter months, in the severest of weather conditions".[57] Matthew Mace argued that night-time incidents are more likely to last longer and be more complex because they are more likely to involve commercial vessels that only request assistance when they really need it.[58]

33. Philip Naylor, MCA, denied that the statistics did not represent a national picture or that night-time incidents tend to be longer-lasting and more complex.[59] He said: "While it might be accurate to say that an incident, for example, in Scotland might remain open for a number of hours, in fact the absolute level of activity is concentrated into, typically, three quite short bursts. In terms of the overall workload, the duration of such an incident is not an accurate reflection of the amount of work that would go into it."[60]

34. 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.

35. Another major concern with the daylight hours sub-centre model is the risk of information being lost or missed during the handover period between the sub-centre and MOC. Capt. Kevin Richardson said: "Any person that has been involved in an emergency response to an emergency incident will tell you that a real point of weakness is when there is a transfer of either command and control or a transfer from the marine aspect of that incident to the land side aspect of that incident. That is the point at which things can go very wrong".[61] A recent Maritime Accident Investigation Branch report into the sinking of the fishing vessel Aquina found that the decision to hand over control of the incident between MRCC Clyde and MRCC Stornoway "caused a delay of 23 minutes in a rescue helicopter reaching the accident site", although in this instance the MAIB considered it unlikely that the delay affected the three fatalities.[62] Murdo Macaulay told us that, as a result of this incident, the MCA issued an operational advice note "which essentially said that, if at all possible, incidents should not be handed over because it was too dangerous".[63] Robert Paterson, Director of Health & Safety, Oil & Gas UK, added: "The key point for [the oil industry] is that offshore emergencies do not happen very often, but when they do they can be quite protracted. One of the things we would fear is the process of handing things over from a centre like Shetland to Aberdeen and back again, because that is when you lose information and things start to go wrong".[64] Jon Gifford, Honorary President of the NCI, said that the NCI would never allow an incident to be handed over between its own staff.[65]

36. Sir Alan Massey assured us that: "There is absolutely no question that we would do exactly as we do at the moment. Where there is an incident ongoing that is engaging a particular station in an intense way, we would not let them change watch; we would not try and take the incident off them. We would let that go to a logical position at which you could safely hand it off". He added that it would be for the MOC to decide when the hand over would take place.[66] But we heard evidence that coastguards, unlike other emergency service personnel, are not contractually obliged to remain behind to facilitate a handover.[67]

37. 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.

Communications technology

38. The consultation document states that modern communications and information technology, including electronic mapping systems and satellite data, have the potential to gather information from many sources and locations to produce an integrated picture of what is happening and speed up decision making. It highlights the Automatic Identification System (AIS), which provides real-time data about a ship's location, cargo and destination up to 30 miles from the coast, and the development of Long Range Identification and Tracking, which allows ships to be tracked over much longer distances.[68] We learned that the proposals are based on systems that are already set up in MRCCs.[69] The technology used now will be upgraded, but not replaced by newer systems.[70]

39. Several submissions expressed concern that the proposals are aimed at the merchant maritime fleet, but do not adequately address the increase in leisure users or small-scale day boat fisherman around the shoreline who do not generally use systems such as AIS.[71] Coastguards in Stornoway told us that only 4% of the casualties they dealt with related to commercial vessels.[72] Appearing before us in Falmouth, the Royal Yachting Association argued that the boating community is in transition between longstanding analogue communication systems and digital systems, and that the majority of leisure craft are dependent on VHF radio.[73] Smaller vessels are not required to carry all the systems on which the proposals are based.[74] Rob Grose, Chairman, Truro & Penryn Harbour Forum, concluded, "We felt the actual report did not engage or mention the leisure industry at all".[75] We were told that "calling in" or traffic reports are a significant part of a coastguard's daily interaction with marine users. Brian George of the PCS Liverpool Branch, told us: "The reporting-in of yachts, boats and small fishing vessels is a voluntary thing. They do not have to do it, but obviously we encourage it. We then have that information. If somebody goes missing, we have already got the information to hand".[76] Philip Naylor assured us that: "Our ability to hear the people that currently call us will be unchanged. Anybody that can currently contact us on a leisure craft or by telephoning us nationally will be able to do the same in the future as they do now".[77] But we heard concerns that leisure users, yachtsmen and fishermen may feel less inclined to report to a remote MOC.[78]

40. 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.

41. 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.

Resilience

42. The MCA consultation document argued that while some resilience is provided by the current system of coordination because the MRCCs in each pair are interoperable (apart from Shetland and Stornoway, where current telecommunications provide only a limited capability), there is no interoperability between pairs or nationally.[79] We were told that the Integrated Coastguard Communications System is currently being updated to enable each station to 'dial into' three stations north and two south or vice versa, thus significantly strengthening resilience.[80] Murdo Macaulay, of the PCS Stornoway Branch, said: "To now imply that we should take this bought-and-paid-for technology out of current stations, throw it in the bin, and move to another system or move to a system with less stations using exactly the same equipment we have just bought and paid for, does not seem to be a sensible use of money that has been spent on the project".[81]

43. 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.

Conclusion

44. 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.

45. 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.

46. 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.

47. We are concerned about the potential implications of these proposals on volunteers and for the level of protection provided for leisure users. The nature and benefits of the upgraded technology proposed also requires clarification. The Government should withdraw its modernisation proposals for the Coastguard and consult on revised plans that satisfactorily address the key issues we have identified.

10 MCA website; RLNI website; Ev 145

Back

11 Maritime and Coastguard Agency, Protecting our seas and shores in the 21st Century: Consultation on proposals for modernising the Coastguard, December 2010 Back

12 HC Deb, 16 December 2010, c133WS Back

13 According to the consultation document, there is no existing Coastguard facility on the south coast suitable for conversion into a MOC, but the MCA has land at the Daedalus site at Lee-on-Solent which would be suitable for a new-build centre. Back

14 The proposals do not affect the small centre operated by the coastguard alongside the Port of London Authority on the Thames in London. Back

15 Coastguards stationed in the centres would fall by 243 from 491 to 248, but the number of regular Coastguards supporting the volunteers in the Coastguard Rescue Service would increase from 80 to 105. Headquarters staff would fall from 25 to 17. Back

16 Department for Transport, Transport Statistics, November 2010. Back

17 Q 408 Back

18 Q 407 Back

19 Qq 548, 581 Back

20 HC Deb, 7 June 2011, col 190W Back