The following pressures/changes should be taken into account:-

• In the proposed plan there would appear to be an over-dependence on technology, particularly satellite communications, which are not always available or indeed used by all mariners. This will create new pressures in itself. Has any risk analysis been carried out on this?
• In terms of Marine information Notice 380 Port State Control issues will be further delegated to Port Authorities, creating additional pressures on Port Authority staff. In the absence of a local MCA station there will be no back-up available to Port Authorities taking on these additional responsibilities. With no local MCA representation, who can make the decision to detain a vessel, and who will take on the liability for this decision?
• The absence of a coastguard presence for local marine pollution incidents means additional pressures will be brought to bear on the other members of the Incident Response Team. Under the current system the first call for any port pollution incident is to the MCA, who then become part of the investigation team, dependent on the nature of the incident
• The Police Counter-terrorism Branch’s Project Kraken envisages Local Coastguard as being a key partner in the monitoring of any unusual maritime activity. The current restructuring plans don’t address this role at all. The change in security status relating to ports since the Mumbai attack has not been taken into account in the current proposals.

The strengths of the current system are:-

• The fact that there is a strong core of highly skilled trained personnel situated in key strategic areas with local knowledge and local contacts. They operate in a modern watch room, and have an appreciation of local language issues with particular reference to Gaelic place names and local knowledge of who to contact, where and for what assistance – all of which is of particular importance and relevance in an island situation where the help required may be on another island altogether. The importance of this on- the-ground local knowledge cannot be understated. Numerous examples can be provided of where this has proved crucial. Local names for headlands and islands are particularly important where the small boat user may not have GPS.
• Current system operates 24/7, which is crucial in areas such as the West Coast of Scotland where the fishing and aquaculture industries work through the night, as does the commercial shipping transiting the Minch and the NE Atlantic.
• Strong local partnership interfaces and back up are in place under the current structure between the Coastguard and the local Emergency Services as well as close liaison with local helicopter and lifeboat station too. In Stornoway there are many instances of incidents where what would be a police exercise somewhere else ends up being a coastguard operation for instance because of the terrain or the amount of inland lochs in the area.
• Under the current system all key strategic areas are covered. The West Coast of Scotland alone has more coastline than England and Wales combined, but under the planned restructure it is possible that there may be no coastguard base between Lerwick and Liverpool. Stornoway station is in an ideal location having the greatest outreach into the Atlantic and the Western approaches.

• No. As mentioned above the proposals require an over-dependence upon telecoms and does not provide the 24/7 cover required on the West Coast of Scotland where approximately 50% of incidents happen during the night. Other maritime operations are 24/7
• The proposed staffing levels do not allow for sufficient back-up
• The analysis of the current structure appears to be flawed in that it does not take account of the different patterns in the different districts, instead simply taking an overview of the relevant totals. The pattern of incidents at Stornoway, for instance remains stable throughout the year with a slight increase in the Summer. The time taken to deal with incidents in Stornoway is 4 hrs on average whereas in the South of England it is 15 mins. due to the nature of the incidents in question. The proposed system makes no allowance for the very different requirements of the different districts.

• We believe it is appropriate for both Stornoway and Shetland to be retained as Full time (24/7) MOCs. Stornoway District by itself covers 2,300 miles of coastline, but also covers thousands of inland lochs and the NW Atlantic for SAR purposes.
• The development of marine tourism, aquaculture, oil and renewable energy projects around Shetland, Orkney and the West Coast of Scotland support this point of view.
• As mentioned above it is a major concern that under the proposed structure there is the possibility of having no centre on the West Coast between Lerwick and Liverpool.
• Shetland have already experienced the effects of environmental damage and having stations in both Stornoway and Shetland gives the best opportunity of averting similar recurrences for example at the dual world heritage sites of St Kilda. These wilderness areas of the UK are huge assets to the country, they are the foundation of the tourism industry that is currently propping up the Scottish and UK economies and must be protected. It is our belief that the current system gives a better opportunity of doing that than the proposed system.

• The proposals mean that in the new sub centres less than 50% of the current staff will be responsible for a district more than twice the current size for half the current time. In our view a full risk assessment of these changes is required prior to any implementation.

• Staff may be asked to relocate to Aberdeen, which is one of the highest priced areas for property in the country. Has any assessment been made of the likely uptake?

• While we are unable to comment on the internal workings of the MCA staff we are concerned at the proposed level of loss of experience and expertise

• We completely disagree with this proposal.

• Moving local knowledge to a voluntary basis means that there is no guarantee of its availability. As mentioned above we believe that, particularly in the West of Scotland and the Scottish Islands, local knowledge is CRITICAL to the successful provision of the coastguard service it should be fundamental to the core service and is not something that should be delegated to volunteers.

• Has any assessment been done of whether it will be possible to maintain an adequate number of volunteers in areas where there is no longer a local coastguard centre? Without a focal point it is likely that interest in this role will diminish, particularly if more responsibility is delegated to volunteers at the same time.

• We do not agree that the proposed restructuring will strengthen the system.
• The proposed system does not work with the topography of the Scottish Islands and West Coast areas. Coastal Safety Officers would be required for each island at least if the response was to be “resilient” as claimed
• Have the cost implications of the on-call structure been assessed? We understand that it is intended to operate with a three hour minimum claim. It seems likely that this will eliminate much of the savings that the proposed restructuring was intended to achieve.
• We have concerns about the increasing volumes of incidents and the smaller number of professionals available to deal with them.
• We have concerns also about the retention of volunteers which we believe is likely to become an increasing problem for the reasons previously stated.
• We believe that over-centralisation negatively impacts on effectiveness particularly when the nuances of the different districts are not being taken into account. Instead a general overview has been taken and a “one size fits all” approach has been made to the restructuring. As each area is fundamentally different we believe the proposal is fatally flawed.

It is evident that the driver for the proposed restructuring is cost savings and not improvement of the service. The financial analysis information provided in the consultation document is wholly inadequate to back up the cost saving argument.

We suggest that a different way to tackle the cost saving issue is to start by asking the people on the front line how they would make improvements and cost savings. In this way it may be possible to find ways to achieve savings without material damage to the service provided.

The proposals are:

strong in assertions, weak on facts

strong on strategy, weak on logic

strong on the need to save, totally vague on how savings are to be achieved

strong on detailed analysis, totally incomprehensible in relation to the value of local knowledge