This following letter is to be given (by hand) to Mike Penning, the Minister responsible for the closure plans of Coastguard Stations. It highlights grave discrepancies between what is being said and the reality of matters. We sincerely hope that other MPs share the same qualities of integrity and honour that Paul Maynard does.
For the Attention of Paul Maynard MP
Ref. HM Coastguard MRCC Closures (incl. Liverpool/Crosby)
25th June 2012
Dear Mr. Maynard,
We have corresponded on this subject a number of times; I thank you for your prompt and diligent replies.
I am grateful therefore, for the opportunity that you have offered by taking my concerns directly to the Transport Minister Mike Penning, with your promise to ensure the matter gets full and fair consideration.
The attached document gives an outline of my concerns, the annex gives detailed information of those concerns stating the flaws in the plan and referenced documents.
I sincerely hope that once you have read this document you will fully back the call for closures to be halted.
You will be aware that these concerns are shared by many other people as the website www.coastguardsos.com proves. The campaign based on the website is led and run by members of the public, which I fully support.
I look forward to this opportunity and trust that it provides some way forward in resolving the major flaws in the MCA modernisation plan for HM Coastguard.
The list below is a Summary of my concerns (they are not in any order), the appendix gives greater detail for each and references any corresponding evidence.
- Loss of local knowledge. There is no evidence that the ‘National Gazetteer‘ will be in place prior to any MRCC being closed. Majority of knowledge is held by the staff that are going to be lost before this system is in place or proven to be adequate in ‘real world’ incidents.
- Loss of Expertise & Experience. Many of the MRCCs that are to be closed have the highest incident rates and the majority of experienced staff will be lost.
- Early closure of MRCCs before MOC running or proven. There can be no cost justification for the early closure of MRCC when it is contrary to the explicit assurances made and risks compromising the whole modernisation strategy and more importantly the lives of people in the areas affected.
- Language & dialect issues. Much was made in the consultation process about retaining stations for the ability to speak e.g. Welsh. This has never had any operational basis.
- Pairing Fiction. ‘Pairing’ between MRCCs is, in reality, (if it happens) it’s limited to switch over of 999 calls and monitoring of local VHF channels. Local Knowledge is NOT shared. Assurances were given on the basis that one of each pair could fully take over the others area, which is simply NOT TRUE.
- Unreasonable workloads. Remaining MRCCs will face unreasonable amounts of extra responsibility by taking on workloads which can equate to 4 or 5 times existing loads.
- Staff morale at all time low. Due to closures & item 6 there is an increase in all MRCCs being understaffed due to stress, sickness and staff leaving.
- Real flaws in MCA/HMCG plan not being addressed. Infrastructure has no proper resilience and as such will stop MOC from working.
- Incident handovers between MRCCs proven high risk, yet MOC system relies on process.
- Lack of Individual Risk Assessments as required by Law. There is no credible evidence that MCA has considered all the Risks associated with each closure. A blanket National Assessment is inadequate.
A U-Turn on closures of HM Coastguard MRCCs is urgently demanded.
There is significant evidence that gives compelling reasons for the current plan to be reconsidered.
The foundations of the modernisation plan were Pairing & Resilience; they no longer provide any credible basis for the plan.
1. Loss of local knowledge.
1a Risk Overview table Ref. 6 Risk Mitigation states “No national standard Gazetteer” exists for Local Knowledge (document dated February 2011). http://www.dft.gov.uk/mca/2.risk_overview_table.pdf
1b MCA response to Independent Review of 2nd Consultation “Local knowledge will be continuously gathered, stored and shared across MCA systems. This information will include alternative and multiple place names, including phonetic spelling and will be available, in a standard format, to all watch-keepers across the whole UK network.” http://www.dft.gov.uk/mca/irt_response_table_v3.3.pdf
1c See also Pairing in respect to “Retaining additional centres with one from each of the existing pairs and increasing to 24 hour coverage at all remaining stations will enable the current levels of local knowledge, local intelligence and familiarity with local languages, dialect and place names, to be transitioned into the new structure.”( From pdf referenced in 1b)
MCA documents (above) acknowledge the lack of a National Database for Local knowledge and promises to deliver such a system. Given the timeframe it will be impossible to implement a purpose written programme, any commercial system would need a fully quality controlled & verified customisation by trained experienced staff.
With imminent closure of MRCCs, much of this Local Knowledge will be lost before it can be added to the ‘National Gazetteer’, provided staff would be willing to add date prior to redundancy.
Ref.7 Local Knowledge – the Operational Context states
“Coastguard officers can still draw on detailed local knowledge by contacting a wide selection of coastal community based resources (CRS, RNLI, NCI, Harbour and port authorities etc.) for advice. “
However in an emergency situation this is hardly practical due to availability of such volunteer sources and will waste valuable time in any incident.
Justification for not keeping all MRCCs open was added cost of computer links/equipment to MOC; this prevents future updating of National Gazetteer and its interface with Master mapping data. Without access to the system, how can contributors ensure that the data is correctly entered? Without a Regional MRCC to audit any database (place names or maps/charts) how will it be properly audited? Any system depends on the quality of data to be effective.
HMCG has recognised the need for MRCCs at strategic places to provide an on-scene local service because of local risks, like the introduction of theLondonstation after the Marchioness disaster. Where is the proof that technology or working practices mitigate past requirements?
There are significant local variations to the National computer simulation software & planning, there are reports that prediction models do not fully cater for manmade influences on tide movement patterns.
2. Loss of Expertise & Experience.
The historical Incident data shown in the table (right) clearly demonstrates that MRCCs scheduled to close are the busiest with extremely competent and highly experienced staff.
Latest incident figures show that closing stations are experiencing increases of up to 12% for 2011.
MCA Annual Canoe & Kayak Report for 2010 (issued Jun 2011)
This report clearly indicates the closing stations have the highest number of this type of incident.
A similar picture is also given in the MCA 2010 Diving Incident Annual Report. http://www.dft.gov.uk/mca/2010_diving_report.pdf The report contains this statement…
“the district with the highest individual total is Portland having the single highest recorded
number of diving incidents totalling 41, not surprising when you consider that Portland is one of the most popular diving areas in the country.”
MCA data gives irrifutable evidence of incident knowledge & experience that will be lost when these stations close.
3. Early closure of MRCCs before MOC running or proven.
On 22nd November 2011 in the House of Commons, Mike Penning stated in reply to Sheryl Murray MP “no centres will close before the robustness of the system is demonstrated. Should there be any blips in the system, I can assure my hon. Friend that no station will close until we have the level of resilience that we do not have today”.
Link to transcript/formal record:
Commons Hansard: Statement on coastguard modernisation
Link to official TV recording of HoC session:
Forth now due to close 28th September 2012 along with Clyde in December, which will have an impact on the gathering of local knowledge for the database and leave inadequate time for remaining stations to become acquainted with the areas they are going to be responsible for. (See Pairing)
At the same HoC session both Charles Kennedy MP & Richard Drax MP requested assurances regarding MOC ability to be proven. While, Paul Maynard MP requested that there was not a “Cliff edge changeover” between existing MRCCs closing and MOC becoming fully operational & proven.
Any closure of MRCC will further damage moral, overload the service which is already stretched. This may prove extremely costly in time, finances and possibly lives.
4. Language & dialect issues.
MCA FOI Request F0001014 the following reply was received:
“In respect of the use of the Welsh language during distress calls the Maritime and Coastguard Agency does not hold the information you have requested as HM Coastguard does not record which language was used by a caller during a distress call.
In respect if the tasking of RNLI Lifeboats I can advise that English is used as it is the International language for all Search and Rescue missions; Standard Marine Communications Phrases are used.”
Similarly a response by the RNLI Press Office (Roger Aldham)
“I had a quick chat this morning with some colleagues inWales; however no one can think of any particular incidents where pronouncing place names was a problem. I suggest you also contact the coastguard inWalesas they co-ordinate almost all of the incidents we launch to and may be able to better answer your query. “
It is clear that language & dialect are a consideration, familiarity with place names is important for every station.
Local names can be mispronounced by anyone not familiar to the area, underlining the importance of all stations.
If the MCA seriously accepts that the ability to speak Welsh/Gaelic is a primary factor in keeping any MRCC open, then it must accept equal importance of every MRCC’s ability to recognise dialect and local phraseology for places, names and topography references.
5. Pairing Fiction. The following statement can be found in the document….
Future Coastguard Consultation Exercise Equality Impact Assessment (EqIA)
“Each MRCC operates as the coordination centre for a defined geographical area. A measure of resilience is provided by the organisation of the 19 centres into 9 pairings (with Dover/Thames also being linked toLondon).
This resilience is however limited to providing cover for a proportion of resources across the pairing. With the exception of Aberdeen, MRCCs are neither staffed nor equipped to provide full cover across a pairing.”
The above public document is further backed up by leaked minutes of…
Notes from Maritime Operations (MarOps) CSMs Maritime Meeting
Held at Spring Place on the 25 January 2012
Some Paired stations report they have not paired since trials in 2005, whereas others have failed to Pair due to technical incompatibilities even though they are due to close soon.
These prove that the current plan is based on Dangerous Assumptions of operational procedures which are unfounded; the whole modernisation plan is flawed and requires immediate suspension of all closures & an independent review.
6. Unreasonable workloads.
With reference to both Ref.2 (Loss of Expertise & Experience) and Ref.7 below, staffing levels are currently at the lowest for quite some time but workloads are increasing.
Incident numbers are rising by up to 12% from the 2011 figures released under MCA FOI F0001010; this year’s figures are likely to show another sharp rise of incidents as one closing MRCC experienced 54 incidents in a weekend where the monthly average was 100.
Contributing factors cited are increase in Severe Weather events and more people utilisingUKholiday/leisure than before.
7. Staff morale at all time low.
In the Second Consultation document entitled “Protecting our Seas and Shores in the 21st Century “, the quoted number of HM Coastguard staff at all MRCCs in Section 2 (Original consultation Proposals) was quoted as 491.
The same document above also sets out the minimum staffing levels for 8 of the remaining MRCCs as 23. It can be seen; therefore that the recorded staff levels for 8 existing MRCCs is short of the minimum.
The 2011 total was 85 staff short of the 491.
||1 May 2010
||31 October 2011
Figures in table (right) were extracted from the parliament publication linked below.
There are plenty of media reports covering the dire staff shortages within HM Coastguard service, which extremely worrying, with one source quoting 163 Operational Coastguard Officers short across the service. (June 2012)
Staff at closing MRCCs have publicly expressed that many will not transfer to remaining stations due to a variety of reasons like distance & loss of faith in the service. This will lead to a ‘Cliff Edge’
once stations start closing and may render the service incapable of dealing with multiple incidents of any kind.
8. Real flaws in MCA/HMCG plan not being addressed.
According to one consultation FOI answer, there were nearly 2 instances a month in 2010 where MRCCs lost communications or systems. Average downtime was 5Hours 10mins
With a similar picture from the 2009 report.
A worrying trend is that average downtime is increasing.
Technology infrastructure has shown to have an average of 17 faults per month for the 2010 BT Wide Area Network log found in the following link.
Press article showing blackouts can be caused by crime – in this case 3 hours lost due to a problem with BT exchange
The key word for the Modernisation Plan was ‘Resilience’ (ability to recover readily from illness, depression, adversity, or the like; buoyancy.); it is a major concern that the reduction (by 50%) of MRCCs actually removes resilience from the system. The greater number of centres means the less likely that any system failures will have an adverse effect on the emergency response.
The lower the number of control centres equates to less resilience in the system, as failure points become more critical having larger impact on the whole system.
All technology depends upon infrastructure integrity, which has power supply as the biggest weakness. It is well known that National Grid supply failures are on the increase as demand rises, reserve capacity is at an all time low and severe weather events are more frequent.
There will be more system failure like the one reported recently in the press; it’s only a matter of time before it coincides with an incident where lives are at risk.
9. Incident handovers
On the 20th July 2009 the Fishing Vessel MV Aquila capsized with the loss of 3 crew.
The Fatal Accident Inquiry by the Sheriff concluded that although there was nothing that could have prevented the tragedy, there were lessons to be learnt by Maritime Coastguard Agency (MCA) & HM Coastguard (HMCG) in respect of delays and mistakes that were made.
The report is here: http://www.scotcourts.gov.uk/opinions/2012FAI22.html
My assessment & summary of the Sheriff’s report:
- There was initial doubt over the incident location due to duplicate place names even though the 999 caller gave precise location details.
- The original MRCC taking the 999 call & initiating the response assumed responsibility for the incident but then decided to pass to a nearer MRCC.
- The original MRCC failed to follow through with vital information when handing over to another MRCC due to high workload.
- Mayday protocol was broken which failed to ensure all vessels in the area were properly updated & therefore may not have been aware to respond.
- Inadequate staffing levels at the nearest MRCC who assumed responsibility, failed to advise of the shortages before incident handover.
- The experience & training of staff at the nearest MRCC were inadequate through lack of training in vital areas such as Risk Assessing incidents.
- The assuming MRCC staff were overstretched & unable to fulfil the requirement of a Search Plan. (this danger has increased significantly with current staff losses.)
The current modernisation plan requires frequent passing of incidents from MOC to MRCC with local knowledge or specialism in incident type, which according to the Inquiry recommendation should not happen, as mistakes are made as in (b & c).
10. Lack of Individual Risk Assessments
The Maritime Coastguard Agency made some attempt to evaluate Risk by producing a generalised Assessment. However, the result was a poorly constructed process with the documentation disjointed and difficult to follow. In particular Solution failed to adequately justify the Mitigation and lost sight of the fact that failure (however low the percentage of risk) will result in loss of life.
Post Consultation Risk Assessment here:
The process of Risk Assessment should be straight forward, by breaking down into simple understood hazards & risk with proper solutions with the emphasis on Risk removal not reduction. Risk reduction to the letter of the law “requirement is to reduce risk using reasonably practical measures“
UK Law requires that individual Risk Assessments are done on the basis that each MRCC will have already done local Risk Assessments. These Risks remain in place regardless of the station staying open or not. It is therefore incumbent on MCA to evaluate each of these Risks against closing stations, as each MRCC may have differing Risk profiles. Additionally each closing station will have to be considered on known future impacts to Risk.
Note: It is a fact that the H&S at work act was further strengthened by Management of H&S Regs1999; which covers the explicit need to consider changes made to practices that affect the Public.
Failure to meet the requirement for comprehensive Risk Assessment of MRCC closures has been the subject of much debate within many areas including Welsh & Scottish Governments, where there have been calls for devolved responsibility to them for Coastguard activities & SOLAS commitment.
Written by Coastal Joe