some little facts to help you fill in your questionaires. "Question 1 (Chapter 1) 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. With a 10% increase in incidents in 2010 (page 12 of the consultation document) in comparison with 2007 it seems illogical to close MRCCs around the UK coast, where the incidents happen, and attempt to run a 2 MOC and 5 sub-centre setup compared with the current 19 MRCC setup. Reeds Directory 2011 lists over 170 marinas UK-wide, and according to a DTI publication from 2004 there are over 300,000 leisure boating berths around the UK coast. This figure is likely to have risen in the past six years. Leisure boats are not required to carry AIS equipment in the same way that SOLAS vessels are. It seems therefore dangerously optimistic to focus only on ships that do carry AIS as page 13 of the consultation document does. None of the statements printed in bold on page 12 ofthe consultation document can convince any person at sea or on the shore that closing 10 MRCCs is a good idea, the opposite appears to be the case. The system ofMRCC numbers might be 40 years old (a good few MRCCs and MRSCs have closed since then), but the amount of new and updated technology that has come into the MRCC operations rooms has increased over these years and so have, by necessity, the skills of the officers operating them. The concluding paragraph on page 13 does not accurately reflect the work that Coastguard Officers do in MRCCs - it talks of a long bygone past with "observers all around our coast". Very misleading to the general public who are not aware of the variety of work MRCC staff have to deal with. In Question 3 of the public consultation Q&A available on the MCA website (see link below) speaks ofthe current arrangement ofMRCCs as being borne of the "age of radio which has been superseded by the technological advances of AIS, Vessel Traffic Monitoring and Digital Selective Calling". All these new advances are still based on Radio Technology! They are an addition to Radio Calling Procedure, not a replaceme]1t of it. (Link for Public Consultation Q &A: http://w\vw.mcga.gov.ukJc4mca/mcga07hQm~LshiQ§~!ILQQ9JZQ~S/ ~9ns ultatioD);/l1J,Qg?:= f]JTryntc:S~n§lIJj:ations/hm coastguard 12rQQosals for...JDQgS:mi~mtLQn__~onsul tation 2QIQ(~g~stguam~on sultation-q a.htm) Question 2 (Chapter 2) We have explained the current Coastguard structure and the potential weakness in that structure in the face of increasing demand. Are there other strengths or weaknesses in the current arrangements that we should be taking into account? Please provide supporting reasons for your comments. To write about the substantial knowledge and skills that Coastguard officers in MRCCs need to acquire over many years (page 15 of the consultation document) and then talk about a forty year old system that needs upgrading while almost 250 MRCC staff are set to lose their jobs within the next five years is cynical in the highest degree towards those who do these jobs and go to great lengths in progressing their careers in HMCG. The "Loading" mentioned on page 16 in no way reflects the severity, and therefore the quality or intensity, of incidents dealt with in MRCCs, it only reflects the quantity of incidents. Very bad use of statistics. Question 3 (Chapter 3) Under our proposals we would establish two Maritime Operations Centres handling emergency messages 24 hours a day, supported by a number of sub-centres operating at times of peak demand linked by a national network of radio connections and information sources. In your view, does this provide an appropriate and effective approach to Search and Rescue coordination response? Please provide supporting reasons for your comments. The proposals do not provide an appropriate approach to Search and Rescue co-ordination. The last paragraph on page 19 speaks of a strong link between officers in the MOC and the Coast Rescue Officers (CROs). How would this strong link be established when an MOC looks after a vast area of coast line and therefore a large number of local CRO teams? At the moment, many of the Coastguard Officers in the MRCCs know the CROs personally and therefore have a strong link with them. This local link will be severed with the introduction ofMOCs and day-time only MRCCs. Bullet point 1 on page 20 states some sub-centres will remain open but gives no reason for subcentres being retained and MRCCs scheduled to close. Bullet point 3 essentially says that in some locations it is more important to have MOC/MRCC links with the Coast Rescue Service than in other locations - what is this decision based on? Bullet point 4 claims the geographical pool will be widened for future recruitment. This is factually wrong, and there will be fewer positions advertised and available to apply for. Currently, the positions advertised are available to every person with the appropriate qualifications and the necessary skills anyway. The geographical pool will remain exactly as it is at the moment! Generalisations and platitudes are not enough in such an important proposal/consultation document. Question 4 (Chapter 4) Our proposals for Maritime Operations Centres and sub-centres locates these around the UK coastline and makes use of the MCA current estate. What is your opinion on the proposals for the location of these Centres and sub-centres? Please provide supporting reasons for your comments. The last paragraph on page22 is in direct contradiction to the staff questions and answers available on the MCA mnet: "[. . .] there are no compelling operational reasons for preferring one geographical location to another." This sentence is the exact opposite of answer 7 in the staff Q & A: "the selection of stations to remain open has been based principally on operational grounds [...]." This is a very unprofessional approach to a consultation that will impact on the lives of hundreds of families. MRCCs Stomoway and Shetland have the same number of officers, a similar amount of incidents in a year (extractable from BOSS Web on the MCA mnet) and a similar size of area of responsibility. Vessel traffic through the Fair Isle channel and to the North of Shetland in addition to ever increasing oil and gas related traffic East and West of Shetland make downgrading or closing MRCC Shetland a dangerous proposition. Furthermore, there is a radio mast adjacent to and hardwired into the MRCC providing a stable and secure radio link when remote aerial sites go faulty. This is a further argument for retaining MRCC Shetland and correlates directly to paragraph 2 on page 23 of the consultation document where radio masts at existing MRCC sites are quoted as one of the reasons for retaining them. Question 5 (Chapter 4) In your view, are the new roles and responsibilities for Coastguard officers at different levels in thE proposed structure appropriate to the tasks that need to be delivered? Please provide supporting reasons for your comments. The first paragraph on page 25 (under 'Watch Levels') cites "foreseeable peak incident activity periods". The Scottish coastline hardly has such periods when compared to the South Coast of England and Wales. There may be a slightly higher number of incidents at Scottish MRCCs betv. May and September in comparison with the other months of the year; the MRCCs around the SOl of England and Wales however have a far greater discrepancy between incidents in May- Septem when compared with the rest of the year. This "foreseeable peak" is another generalisation of the consultation document that does not do reality any justice - it is misleading to the general public. The paragraph on shift patterns (page 25 of the consultation document) can only have been comp by someone who has either never worked shift patterns or has long forgotten what the implicatiOJ are. The "I2-hour, four watch system [...] offers few opportunities in the way of flexible workinJ and a better work-life balance for staff [...]." (Page 25) A regular I2-hour, 4-watch shift pattern enables MRCC officers to spend four (4!) days at home with their families! It has got to be one 0 most advantageous shift pattern arrangements around in terms of work-life balance. Working irregular shift patterns has been proven time and again to have a negative effect on health and families (e.g. http://wv./w.cdc.gov/niosh/topi cs/workschedules/ or http://wfnctwork.bc.edu/Thc Network News/06/The Network News Interview06.pdf). Another impact of altering the regular shift pattern to an irregular one would be the loss of incom for employees due to increased travel cost caused by having to go to work more frequently. The word "daytime" when applied to sub-centres that are to remain open (on page 25 of the consultation document) hardly applies to the North of Scotland where the days last for a very lon, time indeed during the summer (up to 22 hours of daylight) and for a very short time during the winter. III thought-out wording and misleading. Question 6 (Chapter 5) Under these proposals the regular Coastguard working in Maritime Operations Centres and subcentres will draw more heavily on the local knowledge of geography, community and coastal risk provided by the network of local volunteer HM Coastguard Rescue Teams and increased liaison with partner SAR organisations. Do you agree that this is the best way to ensure the availability of such knowledge. Please provide supporting reasons for your statement. The proposal for the future ofHMCG hinges on false assumptions: In 2010,8737 incidents out of a total of20544 were attended by Coast Rescue Officers (page 12 of the Consultation document). This accounts for only 43% of all incidents. This means that fewer than half of all incidents rely on local knowledge of Coastguard Rescue Officers. What about the other 47% of incidents? Coast Rescue Officers are extremely helpful for assisting with incidents on the coast - the officers' title is the giveaway. For incidents at sea they are of very limited help. The number of incidents attended by RNLI boats (quoted on page 13) only amounts to 34% of all incidents. These two percentages do not simply add up to 43% + 34% = 77% because many incidents will be attended by both Coast Rescue Officers and RNLI boats. There are dangerously inaccurate assumptions being made in the Consultation document that are disproved by the very same document. Furthermore, there is no "regular" Coastguard because there is no "irregular" Coastguard (See above under "Question 6"). There are only Coastguard Officers, Coast Rescue Officers and Sector managers. Filling a document with unnecessary and misguiding words is wrong and a misrepresentation of reality. To call the Sector Managers "regular Coastguard officers" (page 32) is another false statement because the training and skills required by them is entirely different to that of the Coastguard Officen employed in the MRCCs who are called "regular Coastguard officers" in this response form as well. To anyone reading this document who is unaccustomed to the language used in the Coastguard service there is no difference between Coastguard Officers in MRCCs and Sector Managers when they are both called "regular" Coastguard Officers. Filling a document with unnecessary and misguiding words has always been the preserve of those who have not got the appropriate words in the first place. Page 32 of the Consultation document lists an average of six Coast Rescue Service teams per sector. There are 64 sectors around the UK coast. The number of teams in each of those sectors range from just three (3) to seventeen (15). To average the amount of teams across all the sectors is not useful and does not reflect truthfully the difference in team numbers, and therefore the difference in responsibility and work load that each Sector Manager currently has. Page 33 of the document suggests that new Coastal Safety Officers (the old Sector Managers by otheJ names with an extended role) "would operate around a team hub". There is no explanation as to what this means and looks like an attempt to fill the document with words that look good" These are just some things to help you, some thoughts that someone came up with, feel free to use these as a guide.
