Session 2010-12
Publications on the internet

Written evidence from Bob Skinley (MCA 36)


· The consultation process itself is flawed and is not a serious attempt to consult

· The MCA has "previous form" in ignoring consultation

· The proposals made in the consultation document are seriously flawed and may lead to deaths around the UK coastline

· Many of the assertions made in the consultation document are either based on false assumptions or are simply untrue or little or no evidence has been supplied in order that a proper considered judgement of the proposals may be made.

· The MCA should be required to revisit and re-evaluate the entire process, come up with credible evidence to support their conclusions, present alternatives to what they propose, again with supporting evidence so that a reasoned judgement on the best way forward can be made, and made to engage seriously in consultation with the results being independently scrutinised.


I am a serving Coastguard Watch Officer of over 5 years operational coastguard experience at Shetland Maritime Rescue Co-ordination Centre (MRCC). During this time I have been involved in some serious maritime Search and Rescue incidents, such as the capsize of the anchor handling tug "Bourbon Dolphin" west of Shetland. I also have other emergency service experience having been a Police Officer with Grampian Police for two years prior to serving as an RAF Policeman for over 5 years and then as a Special Constable with Northern Constabulary for a further 3 years.



The MCA has presented a consultation document entitled "HM Coastguard Proposals for Modernisation 2010." This document outlines the MCA's proposals for the future of the Coastguard service. These proposals include the reduction of the Coastguard service from its current configuration of 19 MRCC (Maritime Rescue Co-ordination Centres) to just two MOC (Maritime Operations Centres) and five, "daytime only" Maritime Rescue Sub-Centres. It is my firmly held belief as an operational coastguard, that these proposals will result in an alarming loss of "local knowledge" about our coastline and a consequent increase in lives being lost as a result. There will be less resilience, not more. There is a very high likelihood that this project will go the way of previous similar public sector projects, such as the recently cancelled FiReControl Project (which was very similar) at enormous cost to the taxpayer, which, in these economic times, is an alarming prospect.

The Consultation Process

The whole consultation process appears, on the face of it, to be very little to do with consultation at all. It is a very restrictive document, designed to elicit the response the MCA wants to hear. The only accepted form of response appears to be the online questionnaire, which in itself is a limiting factor as it excludes those who do not have internet access or who are not computer literate. The questions in the response form are, and this appears to be deliberate, "closed" i.e. they do not in themselves seek any discussion of what has been proposed and present no other alternatives. Rather, they merely seek additional information or recommendations to what is already proposed, presenting this as a 'fait accompli' which hardly meets my definition of 'consultation.' If I may use Question 1 from the response form as an example, it asks: "We have set out the changes that would affect the way the Coastguard needs to operate. Are there any other changes and pressures that should be taken into account in our plans for a modernised Coastguard service? Please provide supporting evidence for your comments." Furthermore, you will note that whilst the majority of the questions in the response form demand evidence/reasons for the response whilst the MCA themselves provide very little or none at all to back up their assertions, which is somewhat one sided.

Indeed the MCA (previously the Coastguard Agency) has a track record of this sort of behaviour. In a previous consultation exercise in January 1998 regarding the proposals contained in the document "Five Year Strategy For HM Coastguard" they stood accused of similar dubious practices. In their Sixth Report of Session 1998-99, the then Select Committee on Environment, Transport and Regional Affairs said of the consultation process:

"The consultation document offered no alternative proposals about which the views of staff and other interested parties might have been sought: rather it sought only to justify the decisions already made and announced. The data provided by the document was insufficient even for that purpose, since information was provided only about the four stations planned to be closed, and the two to be co-located, rather than all maritime rescue co-ordination stations, thus failing to supply the comparative data which might explain why the stations had been selected. "

History repeating itself. The MCA has attempted the same strategy again in an effort to bulldoze through their proposals in complete defiance of what the Honourable Members of the Committee said in 1998.

The Select Committee further stated:

"The document eventually issued by the Agency appeared to seek only to justify decisions already taken rather than genuinely to canvass the views of interested parties about the Strategy. "

Quite so. This is not the only flaw in the current consultation process and similarity between it and the 1998 process. In 1998 the Select Committee found that the consultation process was done in bad faith and that at the end of it, the responses were ignored, they said:

"The suspicion that consultation about the Five Year Strategy was simply "a PR exercise" was reinforced by its outcome. Although some aspects of the Five Year Strategy, such as the introduction of new technology, were supported by respondents to the consultation exercise, the closures and co-location of stations were condemned. 84 per cent of those who expressed a view about the closure of Pentland maritime rescue co-ordination centre were against it: the equivalent figure for Tyne Tees was 71 per cent, for Liverpool 88 per cent, and for Oban 79 per cent. The co-location of Portland and Solent was supported by only eight per cent of those who addressed the matter, and opposed by 56 per cent. Overall, 86 per cent of respondents expressed an opinion about the implementation of the Five Year Strategy, and 66 per cent of them were opposed. Nevertheless, on 31 July 1998 it was announced that the Strategy would be "taken forward as proposed". The only change as a result of the consultation exercise was slight: Oban and Pentland would now be closed in autumn 2000, Tyne Tees and Liverpool in autumn 2001, and Portland and Solent would be co-located in autumn 2003. The delay in closing the stations corresponded exactly to the additional time taken up by the consultation exercise."

and they concluded:

"Finally, the Agency in any event apparently ignored those who responded to the consultation document, deciding in the face of overwhelming opposition to the Strategy not to alter it in any way. Thus there has been no serious attempt by the Coastguard Agency, and latterly the MCA, to engage in consultation about the Five Year Strategy. There should have been."

Everything points to this current process going in the same direction and on that basis it should be halted and the MCA forced to take away their proposals, rethink them and then engage in consultation in a serious, meaningful manner i.e. by having the results of the consultation process independently scrutinised.

Rationale behind the proposals and why they are wrong

In his foreword to the proposals on Page 3 of the consultation document, Shipping Minister Mike Penning stated:

" like many in the industry, I also recognise that the Coastguard needs urgent modernisation to keep pace with changing demands, changing technologies, and our changing economy."

Nowhere in the document is any evidence presented as to why this modernisation is so "urgent" or indeed that it requires the wholesale dismemberment of HM Coastguard as currently configured. There is no evidence provided that HM Coastguard as it is currently configured is unable to cope with the demands placed upon it. Even if that were the case, no alternatives are posited to alleviate such a problem, the proposals are presented as "the only show in town."

My experience of HM Coastguard is that it is a constantly evolving, changing, modernising organisation. New equipment and procedures are frequently being implemented and adopted. Indeed, the current MCA Chief Executive, Vice Adm Sir Alan Massey, in his foreword to the consultation document stated on Page 5:

"The proud history of the Coastguard over the past two centuries has seen regular change and modernisation"

Indeed, although this is somewhat at odds with the previous statement by the Minister and this, as I will show, is the first of many contradictory statements made in the document. So whilst not disputing that there is always a need to strive to do things better in a more efficient way, what makes this particular modernisation programme so "urgent", above and beyond what already takes place? The consultation document has provided no evidence to back up this assertion.

The Shipping Minister continues:

"But much of the computer and radio technology that was cutting edge a few years ago is now outdated, and there is huge potential to improve the service and make it more efficient. This gives us a real opportunity to modernise the service that was last reviewed in the mid-1970s.

So that is why we are launching this consultation."

Firstly, the statement that the service was "last reviewed in the mid-1970s" is factually untrue. The service has been reviewed numerous times since the mid 1970s. In 1994 we had "Focus For Change" which was described by the then Coastguard Agency as "the most detailed and thorough review undertaken into the structures, workloads and running of the Coastguard Service for decades." This was followed on the 17 November 1997 by the "Five Year Strategy for HM Coastguard" which sought to improve the "effectiveness and efficiency of an already highly proficient Coastguard Service" and which proposed the closure of four Coastguard stations at Oban, Pentland , Tyne Tees and Liverpool and the merger of those at Portland & Solent. So clearly, to state that the "service was last reviewed in the mid 1970s" is factually wrong and misleading.

Secondly, with respect to modernisation, a great deal of the technology we have in Operations Rooms around the coast is being constantly modernised and upgraded. AIS (Automatic Identification System) for example, has recently been configured to allow the overlay of search plans derived by our search planning software SARIS, onto the AIS map, effectively combining the two systems in an integrated approach to search planning. Our Incident Management Software known as "Vision", is currently in the process of being upgraded (indeed a team is conducting the roll-out of this and associated training at the present time). The Medium Frequency radio equipment in certain MRCC is also in the process of being replaced and modernised, with the MF equipment now being fully integrated into ICCS (the Integrated Coastguard Communications System) and a planned replacement programme of all Operations Room PCs (computers) is also in hand. So again, to imply that the Coastguard service is clapped-out, out of date and in need of "urgent" modernisation is somewhat fanciful and far-fetched and takes no account of all the recent and ongoing modernisation work already going on around the coast. Rather, this looks like a deliberate attempt to suggest otherwise to mislead the public into arriving at the same conclusion as is proposed.

The Shipping Minister also argues that the proposals will have:

"flexibility to allow for fewer staff having to work at night when there is often little to do."

This statement bears closer scrutiny. Firstly it is based on an assumption that there are fewer incidents at night than during daylight hours. This is misleading. Whilst this may be the case on the south coast of England it is certainly not true of the majority of Scotland. Using my own station, Shetland MRCC, as an example, our incident profile essentially " flatlines ." What this means is that incidents are evenly spaced between whether they happen during the day or night, whether they happen Spring, Summer, Autumn or Winter and that the severity of incidents has little to do with either of these factors. This whole assertion is based on the "peak demand" fallacy, where it is believed, through an incorrect use of statistics, that such a "peak demand", which may well exist on one part of the coast, can then be extrapolated for the whole of the United Kingdom and used as basis of station opening times and indeed watch manning levels. This is a disingenuous, and indeed a potentially dangerous misuse of statistical data.

Secondly, it implies that under the current configuration, there are dozens of Coastguards around the coast sitting idly twiddling their thumbs with "little to do." This is both factually wrong and an insult to the professionalism and integrity of myself and my colleagues. In any case, even if it were true, it misses the whole raison d'etre of the Coastguard service as a front-line, reactive, emergency service, but then, that is something that the MCA has completely lost sight of at the very top of the organisation for a long time now. The MCA has become very "corporate" in its outlook, something that has no real place in an emergency service. I am quite sure that the same accusation could be made of our emergency service colleagues in the Fire and Rescue Service or the Ambulance Service. Even if it were true, I see no demand for Fire Stations to be closed or the number of Ambulance Stations to be slashed in order to make them "more efficient" the public simply would not tolerate such nonsense since they recognise that we are there "in case something happens" an insurance policy against disaster which none should put a price on. It also fails to acknowledge the sheer volume of "routine" work that goes on in an Operational Coastguard station, whether that be the regular weather broadcasts (every 3 hours), Vessel Traffic Monitoring, (the Dover Strait is not the only busy stretch of water around the UK which requires vessels to report in to the Coastguard, indeed there are several around the coast of the UK). Again using Shetland MRCC as an example, we monitor the Fair Isle Channel, which is a busy route between the oil installations of the Norwegian sector, such as the Mongstad Oil terminal, and the USA/Canada. In 2010 some 935 vessels, representing over 30.5million GRT, reported in to Shetland Coastguard during their passage through this channel, a substantial number. This, however, only represents those vessels who actually report in, since this reporting area is "advisory" not "compulsory" so there are a substantial number of vessels passing through this channel who do not report in. It also fails to acknowledge the sheer volume of studying and ongoing professional development that is required of a Coastguard Officer. In my just over 5 years experience in the Coastguard I can think of very few occasions when I have not been either studying for the huge raft of exams that have to be taken, especially at Watch Officer level, or carrying out self-study or participating in exercises in order to maintain the extremely high level of knowledge that an operational coastguard is required to have in order to just do their job. Then, as a Watch Officer, as well as my own training I am expected to mentor other members of staff who are undergoing training, supervising what they do, teaching them how things are done and actively participating in all aspects of their training. This is just a small handful of the duties we are required to perform so to suggest that somehow we are sitting around with "little to do" is again misleading and does not represent the facts. Also, if it were true, then surely the most obvious solution (and far less costly) would be to revisit current risk-assessments as to what the current manning levels at current stations should be in order to provide the best service, but again the MCA have failed to come up with a single alternative strategy. The MCA is using this misrepresentation as justification for closing stations, reducing watch levels, station opening times and overall manning levels and is simply not to be trusted as a sound basis on which to do so.

The Shipping Minister also justifies the proposals by stating:

"The UK has more than 10,500 miles of coastline that is enjoyed by 200 million visitors a year. Our industries, shops and services depend on ships for 95 per cent of visible trade by weight, and the shipping industry contributes about £1m every hour to our economy. "

They cannot even get a simple fact like this correct! According to the British Cartographic Society, the length of the UK coastline, including all the major island groups comes to 19,491 miles (source British Cartographic Society using Ordnance Survey Data based on the "Mean High Water Springs" measurement using GIS software). Therefore, the Minister has made a frighteningly substantial error of fact by some 8961miles! One has to wonder of the rest of this document rests on such flimsy data.

In the Executive Summary on Page 7, it is stated that:

"we are changing the way we use our waters and our shores. This is making our coastline far busier than ever before. We are building much larger ships that are less manoeuvrable and drilling rigs and increasing numbers of wind farms pepper the seas around the UK. As a result our seas are becoming much more congested. Weather conditions are also becoming more extreme, with significant weather events becoming more frequent and severe, making work at sea more perilous and increasing the risk of coastal flooding."

If we accept that the above is true, then how is it sensible or logical to cut the number of Coastguard Stations around the UK coastline? Surely logic dictates that an increase in a particular circumstance requires an increase in resources to deal with it, for example it has often been said that in order to deal with rising crime rates we need more "police officers on the beat." If it were proposed that with an increasing number of fires we slash the number of fire stations or that with the increasing number of crimes we slash the number of police officers, would those proposals seem sensible and indeed would the public tolerate them? I doubt it very much. The document also proposes increased investment in the Coast Rescue Service, our volunteers around the coast. Again, if it were proposed that to tackle an increase in fires, we would slash the number of full-time, professional Firemen and rely more on retained firemen or with increasing crime rates we slash the number of full-time professional police officers and instead rely on Special Constables, would that be an acceptable way to deal with problem? I venture to suggest it would not. Like our brethren in the Fire And Rescue Service, the Police or the Ambulance Service, HM Coastguard is a front-line, reactive, emergency service just like they are and we should not be over-relying on our volunteers at the expense of full-time professional officers. The MCA may have forgotten our emergency service ethos, we should not.

The Executive Summary continues:

"The current arrangement of the Coastguard dates back forty years and is not well placed to respond to these challenges."

As already outlined in my submission and confirmed by the statement of the Chief Executive in his foreword, to suggest that the Coastguard has effectively stood still and not been reorganised or reconfigured over the pasty 40 years is patently false. This is a misleading statement that is often repeated throughout this document which does not stand up to any basic level of scrutiny. It appears to be a somewhat disreputable attempt to convince a public, unaware of the ongoing modernisation of the Coastguard over a number of years, that sudden, "urgent", drastic reorganisation and modernisation is required or desirable, before some sort of unspecified disaster overtakes us.

The current configuration of the Coastguard works well. That is not to say it could not withstand some improvements, however, that does not necessarily mean the complete decimation of the Coastguard as we know it, as this document proposes. Furthermore, this whole process is fundamentally flawed as it only proposes one possible view of how the Coastguard could be reconfigured or modernised to the exclusion of all others. One cannot escape the conclusion that this is being driven not by necessity but perhaps by personal agendas. Again, in putting all their eggs in one basket, the MCA is culpable of repeating the mistakes of recent history. The Select Committee on Environment, Transport and Regional Affairs observed in its report in 1998 that:

"In a letter sent in February 1998 to the then Chief Executive of the Coastguard Agency, the Scottish Fishermen's Federation claimed that "it is obvious on examining the [consultation] paper that the Coastguard Agency is not, in any case, engaging in meaningful consultation with users of the service. The Agency is at best consulting upon how to implement its closure plans rather than on addressing the more fundamental question of whether closure of the stations is justified in the first instance".We are inclined to agree. The consultation document offered no alternative proposals about which the views of staff and other interested parties might have been sought: rather it sought only to justify the decisions already made and announced."

The Executive Summary further states:

"Each centre's systems are 'paired' with a neighbour allowing them to work together when necessary, but beyond these pairings the stations are not interoperable. "

Again, this is a misleading statement, since it does not give the whole picture. Each station, paired or not, has the facility to operate another stations communications through the ICCS system, as if an operator were seated at a desk in the remote station. By the simple expedient of " remoting in" from one ICCS terminal in one station to a free ICCS terminal in another station, remote control can be taken of another stations aerials, telephones etc. This applies nationwide. For example, I could effectively dial into ICCS from Shetland and remotely operate another ICCS terminal in, say, Falmouth.

The current 'pairing' arrangement has worked very well and has already been used successfully "in anger" so to speak. On 27 December 2005, a fire forced the evacuation of Swansea MRCC and all operations were transferred to Milford Haven MRCC for a number of days whilst repairs were carried out at Swansea. The system works and there is no loss in resilience. That is not to say improvements could not be made, but do improvements necessarily mean the sweeping changes currently being proposed? It is difficult to discern because, as previously pointed out, no alternatives have been submitted for examination.

By its very nature, a system of 19 geographically dispersed MRCC is in itself "resilient" in that it is proof against catastrophic failure. Since all of our current MRCC can, if the need arises, operate completely autonomously and carry out all the usual functions they normally would, then this is patently a resilient operation. One of the major problems confronting Civil Contingency planners in this day and age is the possibility of a major disease pandemic, such as one involving one of the various strains of influenza. In such circumstances, does it really make sense to concentrate as many staff (and indeed their germs!) and functions into two, centralised locations (MOC's) and five Sub-Centres who, could not in themselves cope with a major emergency on such a scale. Even at a basic staffing level, an MRSC with its complement of 10 staff could not hope to cope in such circumstances, should they be required to cover enormous stretches of the UK coast because an MOC was unable to. Whereas, the current set-up, with their much larger staff pool, their clearly defined areas of operation and their ability to take over the functions of a neighbouring station potentially could. It is perfectly possible that given a little work on the communications and IT infrastructure, the current set-up could cope perfectly well with such a scenario and at much less cost but again it is hard to make a rational, evidence based judgement, since no evidence is presented or alternative solutions proposed.

The Executive Summary states further:

"This means that the system suffers from a fundamental lack of resilience. In the event of a problem affecting both centres in a pair, it is not possible for an incident to be managed from another centre."

What evidence is there that indicates the likelihood of such a scenario, that two neighbouring MRCC would completely lose all systems and be unable to function? None is presented, so I cannot accept that as a fact. What I can present as a fact is that in the 5 years or so that I have been an operational coastguard there has been not one occasion were such a scenario was realised. Furthermore, it is a purely imaginary "what if" flight of fancy of which a great many could be concocted, but would that necessarily mean that the answer to any of those would be the complete dismemberment of the Coastguard as we know it? Again one cannot make a sound judgement due to the complete absence of any supporting evidence or alternative proposals, which could potentially have a much lower cost implication.

It also states:

" It is also impossible to spread workloads across the system; so staff in one centre may be struggling to cope with call volumes while workloads in another may be low."

This is another factual inaccuracy that is not supported by evidence.

At present, it is perfectly possible to spread the workload across the system. For example, stations have and do, on a regular basis around the coast, delegate work to their flank (i.e. next door in either direction) stations. In this way a station which is heavily involved in, say, a demanding SAR (Search and Rescue) operation can ask a flank station to take over some of its routine duties such as weather broadcasts or Vessel Traffic Monitoring (VTM) duties. Or an another example being that of when a station is operating on reduced manpower due to sickness etc., it can request flanks to be prepared to carry out search planning duties should the need arise. All perfectly reasonable and resilient. To suggest that uneven workloads cannot at present be spread more evenly is risible.

The Executive Summary continues:

"In addition both emergency and non-emergency demand varies widely by geographical location, the time of day, and the time of year. Analysis shows that the busiest centres handle over five times as many incidents as the quietest with 30% of all incidents happening in July and August and 70% of all incidents occurring between 9am and 7pm."

If it is true that demand varies widely by location, and I accept that it is, then conversely it cannot be true that there is an identifiable "peak demand" period that applies to the entire UK coastline as the consultation paper suggests, you cannot have your cake AND eat it as the saying goes. This so-called period of "peak-demand" is given as one of the reasons for the five Sub-Centres being open only during daytime hours. As stated on Page 20 of the consultation document: "sub-centres would be staffed only during "daylight hours", when activity levels are much higher than at night." As previously noted, this may well be the case along the south coast of England but it does not apply to other areas such as Scotland, therefore any rationale for having any stations in Scotland which were not under 24 hour operation simply does not exist on any evidential basis. It may be the case that peak loads at certain stations could be alleviated by having extra staff available at peak times and/or changing the shift pattern/working practices to overcome what are, short-term difficulties during, say, the summer season. Again, a sound, evidence based decision on what would be the most appropriate solution cannot be readily identified, since no alternatives are proposed.

It also states:

"These uneven workloads lessen resilience, hamper staff development and lead to higher than necessary staff costs."

These are completely unsubstantiated arguments without a shred of evidential basis.

Firstly, in what way does an uneven workload reduce resilience? Is there any evidence at all that shows that any Coastguard station under the current configuration was at any time unable to function because of these "uneven workloads?" None is provided and in my experience it has never happened. As previously stated, there are alternative methods of dealing with this scenario such as delegating tasks to a less-busy flank station, or looking more closely at staff distribution and work/shift practices. To present this as the only way of dealing with this matter is patently ridiculous.

Secondly, it has always been the case that HM Coastguard has offered ample opportunities to progress. There are many examples of staff who have started at or served at comparatively "quiet" Coastguard stations who have gone on to reach the very highest levels of the MCA. Geographical location or station activity level has never, in my experience, been an impediment to career progression, nor should it ever be. If this is an admission by the MCA that it has, then that is to be roundly condemned and is symptomatic, not of a failed Coastguard station structure, but of a failed career progression process and an "anti-small station" bias in the MCA which should be addressed by better Human Resources management processes and not used as a flippant excuse for closing Coastguard stations.

Thirdly, How does uneven workloads between stations produce the "higher than necessary" staff costs? Regardless of where a Coastguard is located we are all paid the same pay scale. How does it logically follow that the end product of uneven workloads between two geographically distant Coastguard stations mean increased staff costs, where is the evidence for this? If they are suggesting that increased costs are down to factors such as overtime and TOIL (Time Off In Lieu) then this argument simply does not hold water. Overtime, TOIL etc. are a fact of life for an employer, particularly one which deals with the safety of life and whose manning levels are dictated by a risk assessment that it is necessary to have a particular number of staff on watch at any time to provide the necessary numbers and expertise levels. Irrespective of where staff are based, be that under the current configuration or that which is proposed, this will essentially not change. There will always be a requirement to have certain minimum staffing levels on watch at any one time and there will always be unexpected, extraneous factors which result in overtime and TOIL being necessary, such as outbreaks of illness (and I'm not necessarily talking about pandemics here either, it could simply be a vigorous outbreak of the common cold for example) or a major incident. If it is the case at present that levels of overtime etc. are inordinately high, then this could potentially be down to one thing, the complete lack of the ability of the MCA to recruit and retain staff due to the appallingly low pay levels, something that this document fails to even recognise.

Loss of Local Knowledge

Throughout the document, the MCA refuses to acknowledge the importance of Local Knowledge, or where it does, it suggests that this can all be obtained from resources such as the Coast Rescue Service or the RNLI.

I disagree. Local Knowledge in the Operations Room is fundamental to what we do and having a good local knowledge of your "patch" reduces response times both in terms of the amount of time needed to be spent on initial information gathering and in subsequent allocation and tasking of resources. To say that local knowledge is unimportant in the Operations Room is to fundamentally misunderstand what a Coastguard Operations Room does. The Operations Room is not a "call centre" where emergency calls are merely taken and the a unit dispatched to deal with that emergency. A lot more substantial work goes on in a Coastguard Ops Room. You cannot have a "call centre" mentality in the Coastguard like you do in other emergency services, why? Because of one, fundamentally important difference - our casualties are not stationary, they drift. So because of this we have to take a whole raft of other information into account and we have to make decisions other than just dispatching a unit. First and foremost, we co-ordinate. No other emergency service can do what we do, as effectively as we do. No other emergency service is as good at co-ordinating multiple search and rescue units with differing characteristics and abilities and be able to also incorporate into that all the other emergency services as well. No other emergency service has to do search planning of the scale and complexity we do. The MCA have tried to insist that local knowledge does not have to reside in the Operations Room, that it resides with the Coastguard teams etc. and with the "power of our technology" as Sir Alan Massey stated in his foreword, and better questioning they would have all the local knowledge they needed. Frankly, on that basis then, there is absolutely no reason why a MOC could not be sited in Mumbai, at a huge cost saving to the taxpayer, other than that is a completely ridiculous suggestion, but then so is the idea that Operations Rooms require no local knowledge.

Furthermore, the management argument that local knowledge in the Operations Room setting is not important, is completely at odds with the training regime for Operations Room Coastguard Officers and the published operating procedures as contained in CG3, essentially the Coastguard "Bible" which contains all of our principles and procedures. CG3 contains page after page detailing the importance of local knowledge in the operations room. Indeed it specifies at length the depth of knowledge required and also lays out how that knowledge should be tested. As serving Coastguard Operations Room officers, we are required to be examined in our local knowledge every two years. This examination is comprehensive, indeed CG3 has pages of suggested questions for such examinations. Furthermore, when embarking on either CWA (Watch Assistant) or Watch Officer Training, an up to date local knowledge certificate is required in order to pass the training course. If local knowledge is so insignificant in the Operations Room setting then why go to these lengths to ensure that local knowledge in the Operations Room is thorough, comprehensive and up to date? Something in their argument does not add up. It is fairly clear to me that this disliking for the importance of local knowledge is that if local knowledge is so important, it puts it completely at odds with what the management is proposing to do with HM Coastguard, it is an inconvenience that needs to be explained away, dismissed as a minor issue, when in fact it is absolutely crucial to what HM Coastguard does. There is a "corporate" mind set in MCA Senior Management, a "Call Centre" mentality, which has no place in a front-line emergency service.

The MCA tried to make this argument previously in 1998 and the Select Committee was having none of it. Their report said:

"The most common concern about the closure programme, however, was that it would lead to a diminution of the local knowledge of Coastguard Watch Officers. Over time, Watch Officers build up knowledge of local tides and currents, unusual weather conditions, rescue resources, colloquial place names, the coastline, and locally-based seafarers and their vessels. That knowledge, we were told, is invaluable to Watch Officers in deciding what resources to deploy, and particularly where they should be sent. We were told that "the more you hone down the area of search, the quicker it is [to find those in difficulty]; the quicker it is, the more chance you have of saving a life". Local knowledge has a vital role to play in enabling the Watch Officer quickly to 'hone down' the area to be searched. The PCS Union said that "the need for a Coastguard officer to have a detailed local knowledge of his or her guard is paramount. This knowledge saves lives". It was feared, however, that the closure programme, by requiring the remaining stations to be responsible for lengthier stretches of coastline, and larger areas of sea, would undermine the quality of the local knowledge of Coastguards. As the Royal Yachting Association put it, "there is considerable concern about lack of local knowledge when rescue centres are up to 200 miles apart".

We were given many examples of the role of local knowledge. Mr Watt, from the PCS Union, said that increasingly emergency calls are made by infrequent visitors to the coast, whose location might only be quickly identified by a Watch Officer with appropriate local knowledge. The Scottish Fishermen's Federation gave details of a case in which a canoeist went adrift off north west Scotland, and it was only because of a local Oban Coastguard's knowledge of the "very strange tidal configurations off the west of Scotland ... that the helicopter went in darkness to [the correct] point, and they plucked him out of the water".The Cruising Association said that "shallow water and tidal effects give particular problems to control centres which can only be resolved by local knowledge. Names of places given in emergency calls are frequently not those charted and many names, particularly of small physical features, are duplicated on charts. Local knowledge is required for quick resolution of the resulting confusion".

The report further stated:

"It is apparent that the overwhelming majority of incidents dealt with by rescue co-ordination centres are either on the coast or just off-shore, exactly where local knowledge is so valuable. To imply otherwise is disingenuous."


"We are convinced that local knowledge, whilst clearly not the only source of information for Coastguards, is a fundamental tool in Watch Officers' armouries. We believe that it helps Officers to respond quickly and appropriately to incidents, and therefore saves lives. We are concerned that the closure programme, by requiring Watch Officers to cover more lengthy stretches of coastline, threatens to dilute local knowledge to such an extent that its value will be reduced, with a potentially very serious impact on the performance of the Coastguard service."

The MCA made exactly the arguments then as now:

"The MCA now seems unconvinced of the importance of local knowledge to Watch Officers. The consultation document said that whilst "a knowledge of the overall operational area a co-ordination centre controls is important ... it is misleading to think that any officer at a co-ordination centre could retain a detailed working knowledge of an area which on average is around 500 miles of indented coastline and many thousands of square miles of sea".The Department of the Environment, Transport and the Regions agreed that each station deals with a large area, and the centre at Falmouth, for example, deals with incidents from around the globe: "it is misleading, therefore, to view co-ordination centres as a focus for only 'local' activity". However, the National Audit Office established that one third of all incidents to which the Coastguard responded in 1996 were on the coast, and the Coastguard Agency itself has revealed that 75 per cent of all search and rescue vessel incidents involve recreational craft, which, in the majority of cases, can be assumed to be close to land. "


"That said, the Coastguard Agency's Five Year Strategy stated that local knowledge "is invested in sector managers and the 3,000 or so auxiliary Coastguards ... [and] is also available from other local rescue facilities-lifeboats, helicopters and those ships and people who work and operate within the area".

In their response to the Select Committee on Communities & Local Government in 2005, regarding the very similar FiReControl Project, the Association of Chief Police Officers stated:

" It is also important to emphasise that, whenever possible, 'local knowledge' must be maintained within any migration to regional call centre systems. Failure to do so is likely to impact on the effectiveness of the Fire and Rescue Service to provide an informed and "intelligence led" response to incidents"

and the Committee themselves said:

"Local knowledge of an area can help to identify the location of an incident, particularly if a caller is not at the incident site (thus reducing the benefit of caller identification/location functions of planned RCC technology). The President of the FBU highlighted how important local knowledge had been in the organisation of the response to the Buncefield Oil Depot Fire, particularly as the initial emergency call did not link the explosion to the oil depot."

Indeed the whole attitude of MCA Management with respect to local knowledge is contradictory because the operational procedures for HM Coastguard, several volumes known collectively as CG3, specifically lay down how important it is for Coastguards working in Operations Centres to have a substantial local knowledge. Even setting out how often we should be tested on such knowledge and laying out in great details the sorts of questions that should be included in the Local Knowledge Test. Furthermore it is a requirement that when a Coastguard goes down to sit their final CWA/Watch Officer examinations, that they have a current, up to date local knowledge certificate. So if they do not attach any great importance to it, why then the insistance that we know it. They cannot square this circle.

What the Committee said then about local knowledge is equally true today. Its is equally clear, from the responses to the inquiry into the FiReControl Project, that the only group of people who think that local knowledge is unimportant in an operations room setting is MCA Management. The argument that local knowledge is not important in the Operations Room has been patently demonstrated to be a fiction, which is all about securing the objectives the MCA wants and nothing to do with its relevance to the saving of life.

Similarity with the FiReControl Project

The FiRe Control Project was established to reconfigure the Fire And Rescue Services control rooms across England. It was proposed that some 47 Local Control Rooms would be centralised into 9 much bigger Regional Control Centres (RCC - essentially the Fire Service equivalent of a MOC). The arguments presented for this radical solution were pretty much identical to those being touted for the reorganisation of the Coastguard. As the Fifth Report of Session 2005-06 Vol.1 of the Select Committee on Communities & Local Government stated:

"The Government's main motivation behind the amalgamation of fire control centres is to increase "resilience" by enabling the FRS to handle large-scale incidents better, from environmental disaster to a terrorist attack. RCCs will co-ordinate services in a region from one central point and will have the capability to co-ordinate with other RCCs across the country, providing fall-back support should any RCC cease to be operational."

Very similar wording to that used to justify the Coastguard reorganisation. Indeed on Page 5 on the Communities & Local Government document " FiReControl and overview" its states:

FiReControl will provide:

Improved systems and better technology providing a more effective response to emergency calls. The project will deliver networked access to up-to-date information on the nearest and most appropriate fire appliances for any incident. This will improve local, regional and national mobilisation.

A more resilient system that supports FRSs in responding to major emergencies. The RCC network will enable fall-back and back-up arrangements.

Enhanced capability for dealing with high volumes of emergency calls. There will be common systems, procedures and mobilising protocols. All FRSs will have the full range of capability that currently only some FRSs benefit from.

"Resilience", "Improved Technology" and "Enhanced Capability" all buzz words or phrases also used in the Coastguard document.

The current Shipping Minister, Mike Penning, whilst being an enthusiastic supporter of such radical plans for the Coastguard, had no such liking for the similar plans for the Fire and Rescue Service, stating in the House of Commons on 12th October 2005: "I fundamentally oppose the project." In particular, he raised concerns about the IT (Information Technology) which underpinned the project, concerns that were borne out as we shall see later. He stated:

" Like many members, I have grave concerns about IT projects. A Labour Member commented earlier......that IT projects went wrong under Conservative Governments too, which is perfectly correct - they have been going wrong since time immemorial. In relation to this IT project, the key is lives being saved. That is why I fundamentally oppose the project and why the FBU (Fire Brigades Union) opposes it, as it understands the situation on the ground much better than any bureaucrat in Westminster."

In the light of the above, could I respectfully request that the Select Committee enquires of Mr. Penning why it is that such proposals were so bad for the Fire and Rescue Service and yet they are to be welcomed for the Coastguard? Why his "Road to Damascus" conversion to the wonders of centralisation and the benefits and reliability afforded by IT, when lives are at stake?

In relation to the FiReControl Project, a number of submissions made to the Select Committees enquiry also sound clear alarm bells for the Coastguard proposals. With respect to the supposed "increased resilience" the FBU stated in their evidence that:

"we do not believe that FiReControl improves the resilience of the fire service and that it's potential risks - both operationally and financially - greatly outweigh any potential rewards."

They were subsequently proven to be correct and I would argue that exactly the same argument can be made for these current proposals for the Coastguard.

Indeed the FBU had more specific concerns about the whole project and these concerns exactly mirror my own and my colleagues, viz.:

· Whether the project will indeed enhance resilience

· The potential impact on front-line services

· The location of RCCs (in the Coastguard case MOCs)

· Whether the project will enhance efficiency

· The technology

· The funding arrangements

The FBU also made the same complaint I have about the total lack of detailed information supporting the project.

The Select Committee's report further found that:

"Some witnesses argued that the RCC structure will have a negative impact on front-line services which in turn would undermine resilience."

As highlighted in the Local Knowledge section previously, the same concerns about the loss of such knowledge from the Coastguard by the move to centralised Control Rooms were made about the FiReControl project. Local knowledge is vital and as been demonstrated, is likely to be lost in any migration to a more centralised system, be it a MOC or an RCC.

This project was subsequently cancelled on 20th December 2010 at a cost of some £423million to the taxpayer and an ongoing cost of rent for the now empty and useless RCCs of some £6.5million per annum. Surely in these financial times, the risk of a similar fate for the Coastguard proposals cannot and should not be tolerated.

Location of Maritime Operations Centres

I have serious reservations about the planned locations for the two MOCs outlined in these proposals and these reservations relate directly to the ability of the Coastguard to recruit and retain staff.

One MOC is to be located in Aberdeen and one in the south of England in the Southampton-Portsmouth area. Clearly, little or no thought has been given to the basic economics of these sites. By this I mean it would be difficult to choose two more expensive and affluent areas of the country in which to place these centres. It is well known that both Aberdeen and the surrounding suburbs and villages and the south coast, particularly around the Hampshire/Dorset area are some of the most expensive in the country, both in terms of their cost of living and indeed property prices. This will, of course have a direct impact on the ability of the MCA to recruit and retain sufficient staff to man these centres. Whilst the document makes vague references to "rewarding our staff" better, it would take a substantial hike on current pay levels, to make that a sustainable reality. When one looks at the profile outlined for the Operations Officer 1 and compare that to the current profile for a Watch Officer, there is very little difference, so I rather suspect that there will not be a substantial difference in remuneration for the post as outlined. Therefore one has to be very sceptical of the ability of the MCA to properly staff such centres without substantial pay increase which would, of course, in turn result in substantially increased budgets for this project.

Information Technology

The consultation document continually refers to "new" and "modern technology" that will enable all of what is proposed to go ahead and give us the "fully integrated national network" they say that it will provide. This whole argument is, frankly, pie-in-the-sky and wishful thinking, dangling the baubles of super technology before respondees like some latter day colonial trying to appease the natives. The trouble is, the technology they are talking about is neither "new" nor is it in any way reliable or capable of providing what they say it can. The MCA cannot give any guarantee whatsoever that this whole project will not, in the end, go the way of so many other similar public service projects at enormous cost to the taxpayer.

Technologies such as AIS, EISEC, DSC (Digital Selective Calling) etc. already exist and are installed in all the current Coastguard Operations Centres. For example, great play is made of the ability of AIS to track vessels in "real time" and this helps either avoid incidents or increase response times to them. This is complete nonsense. In the first place, of the hundreds of thousands of vessels large and small operating around the coast of the UK, over 90% of them do not have AIS fitted. It is only required to be carried by larger commercial vessels so its efficacy in either preventing incidents or increasing response times to them is, to say the least, moot. Furthermore, it requires someone to be actually looking at the screen at the time something happens in order for it to be of use and no one is suggesting that anyone should be constantly monitoring AIS! This would of course be both impracticable and, under current display screen regulations, illegal. DSC likewise is only required to be carried by 'SOLAS' registered (International Convention on the Safety Of Life At Sea) vessels, i.e. those over 300GRT (Gross Register Tonnes) so again, the number of vessels actually carrying this equipment, compared to the total is very small which again calls into question its value. Yes they are useful tools, but they are not the "all singing, all dancing" technologies that this document suggests they are. Furthermore, they are all subject to the same vagaries of atmospheric/weather interference and Remote Radio Site failures as all our other Radio equipment, since they rely on the same VHF transmission technology as voice radio. They are a handy addition to, not a replacement for, VHF Marine Band Radio communications or Satcomms (Satellite Communications). To suggest that "the power of our technology" can be the basis on which to completely dismantle the current Coastguard configuration is misleading in the extreme.

Furthermore, we are all no doubt aware, of the significant number of previous IT projects of this nature that have either failed completely or simply do not work as they should, because the IT has been woefully incapable of producing the results expected of it. As well as the recent FiReControl fiasco, I’m sure we all remeber similar disasters with systems for the NHS, NATS, Child Support Agency, Dept. for Education and Training, Passport Agency, Immigration Service to name but a few. Indeed the Select Committee on Communities & Local Government, when examining the FiReControl Project, quoted from the Outline Business Case for the project that:

"The recent history of delivering IT/change projects in the public sector has demonstrated a less than 50% success rate. There is therefore a risk of unsuccessful delivery of the infrastructure and change components of regional controls which could result in delay or even total project failure."

Given the above then it can be argued that the MCA has a less than 50% chance of delivering what they propose which in good times would be a poor return on investment but in the current economic climate is, I would venture to suggest, reckless and foolhardy and does nothing to protect the public purse, something which all Government departments have a duty to do.


In light of all the evidence I have presented I conclude that the proposals by the MCA as they stand are flawed and fundamentally unsound, based as they are on evidence which is flimsy at best and at times downright misleading. They represent a significant threat to the saving of lives around our coast, through the substantial loss of local knowledge, to which the MCA has a singularly cavalier attitude, increased response times, and a lack of resilience through putting "all our eggs in one basket." They also represent a substantial risk to the public purse of, at the very least delays and substantial budget overruns to complete project failure, as in the case of the very similar FiReControl project.


· On the basis of the proposals' similarity to the FiReControl and other, failed public sector projects, these proposals represent a significant risk to the public purse and should be returned to the MCA for reconsideration and amendment.

· Absent any financial considerations the proposals in any case are not sound and represent a potential threat to life saving around the UK coastline through the closure of so many coastguard stations and the subsequent substantial loss of local knowledge and increased response times. The MCA should therefore be asked to withdraw them and consider alternatives.

· Any future proposals should be supported by concrete evidence to back those proposals and alternatives should also be presented so that a properly informed judgement can be made

· On the basis of the significant risk these proposals represent to the public purse the Committee may wish to consider having them examined by the National Audit Office.

· The MCA in future needs to reconsider its attitude towards consultation and should, in future, consult on a serious and meaningful basis and any results obtained by such a consultations process should be independently verified.

· The Committee may again wish to highlight the importance of Local Knowledge and question the MCAs persistent refusal to acknowledge the same.

February 2011