Tag Archives: certificate

For qualified MIT pirates only

Posted on Saturday 17 February 2018 | 3 comments

Curricukum: archery, fencing, pistol (or rifle) and sailing. But

The MIT Pirate certificate is for entertainment purposes only and does not give the recipient license to engage in piracy or any pirate activities.

Spoilsports.

h/t Tyler Cowen

3 Comments

Posted in Economic activities, Foreign parts, Sea

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Wireless telegraphy

Posted on Tuesday 25 June 2013 | 3 comments

I mentioned here that I thought that, during the major search operation on Lough Derg on 21 June 2013, life would have been easier for everybody if each boat had had a handheld VHF and someone able to operate it. However, I should make it clear that I don’t know what equipment and what sort of organisation and safety procedures the rowing group had, so I’m not going to comment on them. Instead, I’m going to make a general point about what I think are obstacles to the more widespread use of VHF.

Buying a set

Handheld VHF sets can be bought for as little as £50 in the UK or €75 in Ireland. So the technology is now very cheap and, for short range work as on Lough Derg, a handheld VHF should be adequate.

So let’s say you do a bit of searching on tinterweb, say half an hour or so; you find a cheap set from a reliable retailer, give your credit card details and then sit back and wait for the set to be delivered. Elapsed time less than a week, your time say half an hour, the price from say €75 upwards. Getting the hardware is easy and cheap: quite a change from when the Wireless Telegraphy Act 1926 (still applicable) was passed.

But if you want to be legally entitled to use a VHF set, matters are much more complicated.

Hunt the department

Let us suppose that you are a poor benighted foreigner who has decided to hire a boat on the Shannon. You know there is Coast Guard VHF cover there and you think that it would be sensible to bring your handheld set and use it while in Ireland. But, being a poor benighted foreigner, you want to do it all legally.

Your first challenge is to find which Irish government department deals with the matter. Maybe it’s the Department of Communications? You have an old booklet somewhere saying its full name is the Department of Communications, Marine and Natural Resources, which sounds promising. However, you notice that the department seems to have dropped “marine” for “energy” and searching its site for “marine vhf” returns no results.

If, at this point, you were tempted to look at the website of the Commission for Communications Regulation, and thought of looking under Radio Spectrum/Licensing, you would find a link that took you to the right place. But let’s suppose instead that, in reviewing an official list of Irish government departments, you noticed that the word “marine” is now (for some reason) part of the title of the Department of Agriculture, along with “food”.

So you troll on over to the farmers’ friends. The main headings on the site’s front page don’t include marine, though; fisheries is the closest topic. If you use the search facility to find “marine” you get 10800 results, which is rather too many to be useful, but you find that there is a Marine Agencies and Programmes Division, which has a list of Useful Links. Unfortunately none of them are to the department that actually deals with most marine matters: the Department of Transport [and Tourism and Sport], which is at both www.transport.ie and www.dttas.ie.

Things are looking up.

Hunt the unit

Your next challenge is to find the section or unit within the Department of Transport Etc that looks after marine VHF. You could use the department’s search engine, which (at least on my computer) is great for showing the word “Loading” but not for anything else. Or you could click on the word “Maritime”, which takes you to a page whereon you read:

Maritime Safety Directorate (MSD)

The Maritime Safety Directorate (MSD) is comprised of two main sections; the Marine Survey Office (MSO) which includes the Marine Radio Affairs Unit (MRAU) and the Maritime Safety Policy Division (MSPD).

Sure enough, clicking on Maritime Safety Directorate in the left-hand column gives you another page whereon you read:

The Maritime Safety Directorate comprises of two main sections: the Maritime Safety Policy Division (MSPD) and the Marine Survey Office (MSO), which includes the Marine Radio Affairs Unit (MRAU). The Mercantile Marine Office (MMO) also works to the Directorate.

This doesn’t quite correspond to the list of headings in the left-hand column on that page, which makes no mention of a Maritime Safety Policy Division and has lots of other stuff that doesn’t seem to fit in the two (and a half?) main sections, but at least there is a link for the Marine Survey Office (MSO), and on that page there is a link to the Maritime Radio Affairs Unit (MRAU), so you click that and finally you’ve arrived.

Hunt the information

The MRAU has a top-level page and two lower-level pages. The top-level page has an email address, which is good, and a list (dated 6 April 2011) of nine PDFs of Marine Notices relevant to radio. They are identified by numbers rather than by names: there is nothing to indicate what any of them is about,  so the eager seeker after knowledge will have to read all of them. Some are about EPIRBs and suchlike; as far as I can see, the only three relevant to our poor benighted foreigner, wanting to use a handheld VHF, are this one [PDF], that one [PDF] and the other one about fees [PDF].

Selecting the Contact Us page gives you names and phone numbers as well as email addresses. So the page with the detailed information must be the other one headed Forms (and not this one, which seems to be orphaned). Each of the links on the Forms page takes you, for some reason, to another page, from which you can download a document: most are indeed PDFs but two are Word DOC files.

The documents cover three topics:

Thre is also e FAQ [PDF], which outlines the rules. It also suggests that one document is missing from those downloadable: it may be called Ships Radio
Operators Certification and may be an application form.

The FAQ does not explain the different types of licences that are mentioned in Marine Notice 35 of 2010:

An Irish Certificate of Equivalent Competency (CEC) or Irish Certificate of  Competence (COC) issued by the Department of Transport, Ireland, when such
certificate states that the holder has a valid Global Maritime Distress and Safety System (GMDSS), General Operator Certificate (GOC) or Restricted Operator Certificate (ROC) qualification. An Irish CEC or Irish COC must be accompanied by the persons separate valid GMDSS, GOC or ROC qualification.

I have no idea whether I have a CEC, a GOC, a ROC or a … the other thing. And I can’t make out which of them a new applicant (or a poor benighted foreigner) should apply for.

Then Marine Notice 12 of 2004 adds another variant, the SRC:

Radio Operators on board Irish recreational craft, and on board certain other Irish craft  that are required to comply with Merchant Shipping legislation regarding the carriage of maritime radio equipment, must hold as a minimum qualification the Radio Operator’s Short Range Certificate of Competency(SRC) issued by the Commission for Communications Regulation, or an equivalent certificate that is recognised by the Commission as being the equivalent of the Irish SRC.

Is ComReg still involved? I didn’t think so.

But the main point of this marine notice is to say that the only poor benighted foreigners whose short range certificates of competency are recognised in Ireland are the Finns and the Germans; only they can get the Authority to Operate. What should other foreigners do? I don’t know and I can’t see the answer anywhere.

Information

So far, then, it seems to me that (for someone outside the system) it is hard to find the bit of the Irish government web presence that holds the information. (That, of course, is not the fault of the Department of Transport.) Once you’ve got to the relevant part of the Department of Transport website, you have to read far too many documents to find the information you want; it’s not easy to understand and it may be incomplete.

Getting a certificate and a licence

As far as I can see, the process is this:

  • attend a course from one of the approved providers [DOC]. It’s not clear to me which course our poor benighted foreigner [or other would-be operator] would have to do; BIM offers courses ranging from two to ten days, but doesn’t show the costs; I suspect that courses for pleasure-boat operators, especially those from private-sector providers, take rather less time, but I don’t know the cost. The elapsed time could be several months, depending on local supply of and demand for courses
  • take an exam from one of the approved examiners [DOC]. Again, I don’t know the duration (it used to be less than half a day), the cost or the elapsed time (how long you would have to wait until a course is available locally). As far as I can see, the syllabus is not published, so you have no choice but to go to one of the approved providers; that sounds like an anti-competitive practice
  • apply to the department for a certificate. That, it seems, has to be done on paper; the fee [PDF] depends on the certificate you need, which I don’t know, but is either €50 or €60
  • when you’ve got the certificate, you apply for a licence for your, er, ship, using this form [PDF] and paying €100. You give details of the radio operator’s certificate; if it’s a non-Irish certificate you provide a copy, and I guess that you have already applied for an Authority to Operate [PDF].

So your cost is €150 or €160 plus the course fee plus the exam fee; the elapsed time could be several months. All for permission to operate a piece of equipment that is rather less complex than a modern smartphone.

Costs and benefits

Years ago, there was some abuse of VHF channels, which were sometimes used for casual chit-chat. From what I can hear, that is no longer a problem; folk probably send text messages instead. I don’t see any reason to fear an increase in the number of VHF users, and indeed I see many reasons to promote such an increase.

Some of the recent reports of the Marine Casualty Investigation Board on small-boat accidents describe cases in which handheld VHFs could have summoned assistance faster — and would, I think, have been more useful than orange smoke flares. In other cases, folk summoning assistance have relied on mobile phones.

It seems to me that the present system, designed almost ninety years ago for an entirely different context, for large and cumbersome equipment on large vessels, is unsuited to modern leisure boating, with large numbers of small boats that could carry small, cheap, battery-powered handheld VHF sets.

At present, the rational decision for a boat-owner is to buy a cheap VHF without bothering to get either a certificate for the operator or a licence for the vessel. This is the rational decision because the official channels for getting certificates and licences are slow, expensive and cumbersome. It may therefore be — who knows? — that the populace has already decided to ignore the regulations.

For leisure boating within some sensible distance of the shore, I suggest that the current regulations be either drastically simplified or, perhaps better, scrapped altogether. That might mean giving the International Telecommunication Union a kick up the transom, but the present system is counterproductive: it seems to limit the use of handheld VHFs in cases where they could be very useful, if only to allow search and rescue volunteers to stand down earlier.

 

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Posted in Economic activities, Engineering and construction, Extant waterways, Ireland, Irish inland waterways vessels, Irish waterways general, Operations, People, Politics, Safety, Shannon, Tourism, Uncategorized, Water sports activities, waterways, Waterways management, Weather

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There is no houseboat policy

Posted on Friday 27 January 2012 | 4 comments

British Waterways (now in the process of transferring its waterways to the Canal and River Trust) has a commercial subsidiary called British Waterways Marinas Ltd. And BW says:

Our involvement in the commercial moorings business is monitored and regulated by the Board’s Trading Committee [9KB PDF] to ensure that we gain no unfair advantage from our statutory roles and that we comply fully with UK competition law.

BWML, incidentally, has two marinas catering for seagoing boats and also has some caravan pitches available.

As well as providing marinas through BWML, British Waterways also controls long-term moorings along the waterways; its policy on long-term moorings is outlined here with more details here. It uses a system of auctioning moorings, with its own website at BW Mooring Vacancies.

From a quick look at the price list on that second page [PDF], the cheapest mooring seems to be £37.59 (incl VAT) per metre at the Saracens Head on the Leeds and Liverpool Canal, which would be £676.62 a year for an 18m boat; I presume that there would be no services. At the upper end, you can have a residential berth on Regents Canal in London for £8,949.95 a year. Most prices, though, seem to be in the range £70–120 per metre.

The Waterways Ireland houseboat facility

In October 2010 Waterways Ireland announced this (which is hard to find on the WI website):

10/38 Shannon Harbour Developments

Following receipt of planning permission, Waterways Ireland is progressing with the development of a houseboat facility in Shannon Harbour where the Grand Canal meets the Shannon.

The result will be a serviced mooring facility in Shannon Harbour for 6-8 boats. This will include moorings, area lighting, electricity and water.

A section of the Grand Canal, from the 34th Lock to the 35th Lock inclusive, will be closed to navigation between 1st November 2010 and 14th March 2011 to facilitate the improvement works. The towpaths will also be closed during the period of the works.

The design and commissioning of the work has been undertaken by Waterways Ireland. The tenders are currently being assessed and will be awarded shortly.

Waterways Ireland regrets any inconvenience to its customers during the period of the improvement works.

Ends Word Count 133

For further information please contact Waterways Ireland Press Office: Katrina Mc Girr Tel no +353 (0)87 991 8412

Senior Engineer (Technical Services) Joe Mc Mahon Tel no +353 (0)48 6634 6270

Here is the tender for “Development of House Boat Facility”. There are some photos of the work in progress here. Early in 2011 WI reported (inter alia) that:

11/05 Works at Shannon Harbour

Works at Shannon Harbour Continue Despite Weather Conditions

[…] The work on the house boat facility is still on programme with completion expected in early March 2011.

During Engineers Week in 2011, WI provided site visits:

11/08 Engineers Week

Waterways Ireland Offers Engineering Insights

[…] The site visit to the Grand Canal was based at Shannon Harbour, near Banagher. The tour took in the completed regeneration works in Shannon Harbour and the ongoing work to develop a new houseboat facility.

L+M Keating describe the work here. And in April 2011 WI Marine Notice 34/11 announced that the navigation had reopened:

MARINE NOTICE No. 34 of 2011 […]

Marine Notice No. 27 of 2011 refers.

Waterways Ireland wishes to advise masters and users that the navigable channel in Shannon Harbour is now open.

The new house boat facility remains closed to the public as construction work continues.

Waterways Ireland regrets any inconvenience that this may cause its customers.

So that’s all clear, then: WI was developing houseboat berths at Shannon Harbour, although it was having difficulty in finalising a houseboat policy. I commented on some of the issues here.

The latest developments

In January 2012 page2rss alerted me to a new item on the WI website and it turned out to be about the berths in Shannon Harbour. There is a link in the menu on the left-hand side of the WI home page; it says “One Year Serviced Moorings” and leads to a page whereon we read this:

Waterways Ireland’s Extended Term Serviced Mooring Vacancies

This page advertises vacancies that arise at Waterways Ireland’s directly managed mooring sites. Vacancies are advertised for 28 days in advance of allocation.

If you are not a regular internet user and would prefer to receive vacancy details and apply for a vacancy by post, please call (028) 6632 3004 or (048) 6632 3004 from Southern Ireland for an application form.

Latest Release: Shannon Harbour, Grand Canal, Co Offaly
Deadline for Application: 23 February 2012
Minimum entry bid Price €1,250

View full details

Download an application form

View the Mooring Agreement 

Each of the links is to a Word *.doc file.

The missing word

Have you noticed what word is not used there or on the front page?

HOUSEBOAT

or even

HOUSE BOAT

Previous discussion of the Shannon Harbour development, including notices from Waterways Ireland, has been about a facility for houseboats. However, what we have here is something much broader than that: a system by which Waterways Ireland can auction and allocate long-term serviced moorings. WI is going into business and, presumably, aiming to make a few quid (no bad thing, considering that it has been suffering budget cuts).

The current offering

Now, admittedly the present offering does hope to attract houseboats. The “full details” document says:

These are Extended Term Serviced Mooring sites where it is expected that the licence holders will live on board their vessels as their sole or main residence.

That is the only mention of living aboard in that document. There is another in the application form:

I confirm that I am applying for an extended term serviced mooring and the vessel is my sole or principal residence.

As far as I can see, though, the licence agreement refers only to extended term serviced moorings and contains no mention of houseboats, residences or living on board.

So let us suppose that WI doesn’t get seven houseboat-owners who don’t work from their boats, have no pets and want to live in Shannon Harbour. It could then advertise the spaces to barge-owners who wanted non-residential moorings. And at €1250 a year, they are charging about one third of the rate at certain marinas on the Shannon.

Further afield

The licence agreement could also be used, mutatis mutandis, to cover moorings elsewhere within the WI estate. It would not be difficult, for instance, to apply it to the moorings in the inner basin of the Grand Canal Dock in Ringsend in Dublin, with most changes confined to the second schedule.

And it could be applied just as easily to unserviced moorings anywhere along the waterways. Indeed the agreement specifically caters for that:

The Licensor regards the development of extended term and/or serviced moorings as an integral part of the functions referenced at B. above.

So it could be used, for example, to control the allocation of unserviced moorings at Shannon Harbour, Lowtown, Sallins or Hazelhatch, to residential or non-residential boaters: in other words, to anyone who parks their boat on a canal. I have, of course, no evidence that WI has it in contemplation to do any such thing, but it is interesting that the agreement provides for it.

Legal authority

It may be that WI has solved the problem of developing a houseboat policy by deciding not to have a houseboat policy. IANAL, but it may be significant that the licence agreement cites legislation on extended mooring:

D. Pursuant to the Canals Act 1986 and the Canals Act 1986 (Bye-Laws) 1988 (SI No. 247 of 1988) (“the Bye-Laws”) the Licensor is authorised to issue permits to authorise and regulate the use of boats on the canal property so as to permit not only mooring on the canals generally but also, pursuant to Clause 25(d) of the Bye-Laws, extended mooring at the same place, or within 500 metres of the same place, for a period of more than five days at a time.

E. The Licensor regards the development of extended term and/or serviced moorings as an integral part of the functions referenced at B. above.

F. To this end, the Licensor has developed at Shannon Harbour, on lands adjacent to the Grand Canal, a dedicated area containing seven berths for the purpose of extended term serviced mooring, with facilities provided to include the construction of fixed timber jetties with lighting, a clean water supply and electricity supply.

G. The Licensor in exercise of the powers conferred under the Act and the Bye-Laws and of all other powers enabling has agreed to grant to the Licensee a permit to moor his boat named _________ and more particularly described in Part 1 of the First Schedule hereto (“the Boat”), in this mooring facility subject to the terms set out herein, including a charge (“the Licence Fee”) of €_________ payable in consideration of the particular nature of the mooring as described at F above.

It regards the legislation as providing authority not just for regulation of extended mooring itself but also for the development of extended moorings. Could it be that WI feared that the development of houseboat moorings might be ultra vires?

In any event, by approaching the matter in this way, WI has given itself a system that can be applied much more widely to canal issues than just to the regulation of liveaboards.

Behavioural and Technical issues

These documents raise some further issues. For example, there are stipulations about behaviour:

7c Biodegradable products must be used for all cleaning water that is discharged into the navigation.

8a No pets are allowed.

9b If social events are to take place on Boats then noise levels must be contained so as not to disturb other Berth holders and there should be no noise after midnight.

11i Generators may only be used between 08:00hrs and 20:00hrs.

None of these is unreasonable, especially in the context of residential moorings, but they are indicative of WI preferences that might be applied elsewhere.

There are also some technical issues. They include a stipulation that would mean that no large Dutch barges, or other Shannon-size-only vessels, could use the Shannon harbour berths, and that no engineless houseboats are allowed:

g. Boats must be capable of moving under their own steam and be capable of navigation in the canal network.

The dimensions of the Shannon Harbour berths confine them to GCC-size vessels, but would (for instance) a high wheelhouse or a deep draught mean that a boat could not use these berths?

Here are some other technical stipulations. It is not clear how or whether WI would enforce these, but it has the power to do so:

6a All Boats must carry adequate fire fighting equipment and have same serviced as per the manufacturer’s recommendations.

10a Boats must comply with all current bye-law legislation in relation to construction and equipment.

10b Boats must be fitted with an operational waste water holding tank.

10c Engines must be fitted with a drip tray. Engines must be maintained so as to minimise the likelihood of fuel or oil leaks into bilges.

10d Boats must have a manual bilge pump fitted.

10e Boats must have appropriate certification for gas and electrical fits.

10f Boats must have had a recent survey (3 yearly).

Again, these indicate WI desiderata. Might they be introduced in other contexts? Note in particular the reqirement for three-yearly surveys and for certification of gas and electricity installations.

Envoi

I should say that, on the whole, I welcome these documents, but I do think that their provisions — and the context — need to be considered. And I have some reservations about this, if anyone is living aboard:

The Licensor’s Inspectorate staff shall be permitted access to Boats in order to secure same, make safety checks, or routine inspections.

 

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Posted in Ashore, Economic activities, Engineering and construction, Extant waterways, Ireland, Irish inland waterways vessels, Irish waterways general, Operations, Politics, Sources, Uncategorized, waterways, Waterways management

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