Tag Archives: licence

Wireless telegraphy

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.


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.


Software licence agreements

A universal translation:

All your base are belong to us.

WI canal permits

Latest update here. These are the main points.


Applications for extended mooring permits at nine new locations will be available for two weeks from 19 November to 3 December 2012. The locations are Rathangan and Vicarstown on the Barrow Line (with a third stretch now at Vicarstown), two at Confey and one each at Cloondara and Lock 15 on the Royal and just one, Lock 34 to Griffith Bridge, on the Grand.

The schedule:

Applications for each set of locations are open for two weeks. Completed applications will be processed in order of receipt and mooring locations allocated. If availability exists after the application timeframe for a location has closed, late applications may be considered. Once all the extended mooring locations in an area have been allocated, no more extended mooring permits will be issued for that area in 2013. It is Waterways Ireland’s intention to complete the roll out of the extended mooring permit by March 2013.

That seems to be intended to get boaters to apply ASAP; otherwise they’ll be moored in the middle of nowhere for the rest of 2013.

The application process is set out in detail, with a new item.

From 16 November 2012 permits will no longer be issued by Lockkeepers, or the Eastern Regional Office. Permits will only be issued on completion of an application form submit to and processed by the Tullamore Office.

It is confirmed that applications must be accompanied by “copies of the insurance, and payment for the permit and a damage deposit”.


There are four downloads: the application form [DOC] and a supplementary form for consortium members [also DOC], a sample 11-page EMP licence [not permit] agreement [PDF] and a 5-page guidance document [PDF]. A consortium is defined in the guidelines as a group of more than two people who own a single vessel. Owners of unpowered vessels are advised, but not required, to have insurance.


The guidelines have a new item about disposing of rubbish:

Boat owners on the canals will be required to dispose of domestic rubbish at  their own expense. On the application form you need to indicate how you intend to manage this. For example, evidence of a paid collection service or by confirming that you will take your rubbish home and dispose of it through your domestic collection service.

In a limited number of locations Waterways Ireland may offer this service for a charge. Details of this will be notified when the area opens for extended mooring permit applications.

That is as I predicted in the last issue of Afloat.

And there is a paragraph about holding-tanks:

You are asked to tell us if your boat has an operational waste holding tank.  This is not a mandatory requirement, but information is being collected for management purposes.

The licence agreement says that owners have to clean up after dogs.

Here comes the BSC

From 2015 Waterways Ireland will be introducing the requirement for boats needing permits and wishing to use the canals to have a current hull survey to provide evidence that the boat is in good condition.

Not all boats will require this.

Your attention is being drawn to this requirement now to allow you time to prepare for 2015.

That’s from the guidelines document (join the queue now for the dry docks). And these bits are from the licence agreement:

The Licensee undertakes to have regular inspections of the gas and electric services of  his Boat as required to ensure these are kept in a safe and serviceable condition. […]

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


The application form requires applicants to agree to this:

I/We hereby indemnify and shall keep indemnified Waterways Ireland from and against all actions proceedings costs claims demands and liabilities howsoever arising from my/our use of the facilities provided by Waterways Ireland on the Royal Canal, Grand Canal and Barrow Navigation and shall further indemnify and keep indemnified Waterways Ireland in respect of any accident, injury, loss or damage to any person or property howsoever arising including, without prejudice to the generality of the foregoing, where such accident injury loss or damage arises by reason of any matter or thing done or omitted to be done by me/us or person authorised by me/us or the purported exercise of such use.

I would welcome guidance on whether that might invalidate insurance policies.

Moorings are not transferable

If a Boat is sold it must be removed from the Mooring within seven days and the  Licensee must advise the Licensor’s Inspectorate. The new Boat owner will be required to make an application if they wish to avail of an extended mooring permit and Waterways Ireland will refund the balance pro rata of any fee paid for an extended mooring permit to the Boat owner less a fee of €50 to cover administration costs.

That’s from the draft licence.

Buy shares in Lowtown

Also from the draft licence.

It is not permitted to re-fuel Boats at an extended mooring.

Lots of exciting reading.

WI commercial operating licences

It’s getting hard to keep up with the amount of new regulatory information Waterways Ireland is producing (not that I’m complaining: it’s good that (a) systems exist and (b) information be made public). Today it has put up a page about commercial operating licences with downloadable PDFs for new applicants and for renewals.

WI says that

Waterways Ireland will give consideration to applications for permission to carry on commercial  operations on the waterways which would serve to encourage their use and contribute towards a vibrant waterway environment.

But getting a new licence is not easy. As well as describing the proposed business, you have to have registered the boat with WI and got a Passenger Certificate for from the Marine Surveyor’s office of the Department of Transport (which ain’t easy). If you want to sell alcohol, you have to have a Passenger Vessel
Licence from the Revenue Commissioners.

You have to provide a copy of your insurance policy:

Waterways Ireland requires that vessels carrying passengers hold adequate levels of insurance and appropriately indemnifies [sic] Waterways Ireland […].

And after that you have to show that your business has a chance of surviving:

Waterways Ireland is required to satisfy itself of the financial and economic standing of entities with whom it proposes to contract. In order to make this assessment, please provide relevant information such as recent accounts or Business Plan (including resources, financing, programme for delivery, target market, etc.).

And you have to supply a current Tax Clearance Certificate.

It seems that folk without capital (including working capital) need not apply.

WI extended mooring permits

A Waterways Ireland press release has winged its way to my desk. If you want a permit (or licence?) you must provide a copy of your insurance and pay a damage deposit.

The full thing:

Waterways Ireland announced in June 2012 a change in the permit system allowing for year-long mooring permits on the Grand & Royal Canal and Barrow Navigation. The full list of Extended Mooring Locations has been published and is available on www.waterwaysireland.org, in the Canal Bye-Law Enforcement section.

The first four [for certain values of four. bjg] locations where the permits for extended mooring are being opened for application are Shannon Harbour on the Grand Canal, Rathangan and Vicarstown on the Barrow Line and Barrow Navigation, Clondra (East of Richmond Harbour), Confey and the 15th lock on the Royal Canal.

The application process for the Extended Mooring Permit for these locations will open on the 19th November and will remain open for 2 weeks. Boat owners with boats in the four locations with Combined Mooring and Passage Permits will be advised by letter. The Application Form and Guidance Notes for all applicants will be placed on www.waterwaysireland.org. The applicant is required to complete an application form, supply a copy of their insurance, certify that the boat complies with the byelaws and pay the €152 fee and a damage deposit of €250.

Permits will be allocated on a first come first served basis, so to receive a preferred location early applications are advised. Applications will only be accepted from owners already holding a valid annual Combined Mooring and Passage Permit. Boat owners without a Combined Mooring & Passage Permit who wish to apply for an Extended Mooring Permit can do so by ticking the box on the Extended Mooring Application Form and supplying the additional fee.

Applicants will be notified within 28 days of the success of their application.  Successful applicants will be required to sign the Extended Mooring Permit license and will then have a period in which to move to their new mooring. Enforcement of the 5 day rule will begin in this area following the issue of a Marine Notice.

Applications for the next set of Extended Mooring Locations will continue on a rolling basis thereafter with Waterways Ireland intention to open sufficient locations to cover demand on all of the canals by the end of March 2013.

Boats that cruise and move (staying at a mooring for up to 5 days) will not require an Extended Mooring Permit or be in breach of the Bye-laws.

Waterways Ireland will continue to contact permit holders regularly to ensure they are kept up to date with the roll-out of the new permit. All queries about the enforcement of the current bye-laws or the Extended Mooring Permit should be directed to Shane Anderson, Assistant Inspector of Navigation: Tel no +353 (0)87 286 5726, Email shane.anderson@waterwaysireland.org.

These changes are necessary steps to improve the management of the canals and waterway amenities for both the navigational and recreational user, so that investment in the new infrastructure and facilities which Waterways Ireland has undertaken is maximised for every user.

Despite asking them several times, I still don’t understand what WI means by “permit” and “licence”. And now we have a “Permit licence”.

Canal mooring rules

Waterways Ireland issued two press releases about moorings today. The first was the usual one about winter moorings on the Shannon and the SEW; the second was about the canals. Here, unedited, is the text of the second.

Canal Mooring Rules Coming into Force

Waterways Ireland announced in June 2012 that the Canal Bye-laws on the Grand & Royal Canal and Barrow Navigation are to be enforced from autumn 2012, with an accompanying change in the permit system allowing for year-long mooring permits and locations.

Part of bringing in this new location-based permit has been the identification of locations suitable for extended mooring. This process is now completed and work has begun in some areas to improve accessibility.

Waterways Ireland will roll out Extended Mooring Permit applications by area, rather than giving a date when applications for the permit will open. For boat owners this will mean that enforcement of the maximum stay rule will not commence in an area until after boat owners have had the opportunity to purchase an Extended Mooring Permit.

The initial 12 month Extended Mooring Permit will cost €152 and will only be available to boats already holding a valid annual Mooring and Passage Permit.

Boats that cruise and move (staying at a mooring for up to 5 days) will not be in breach of the Bye-laws or require an Extended Mooring Permit.

Waterways Ireland has proposed a small number of draft amendments to the current Bye-laws which date from 1988. These include proposals to provide a range of charges for mooring permits that reflect the location and services provided throughout the canals and also will take into account the size of boat. These proposals include low cost rural moorings on soft banks to ensure the canals are accessible for everyone who owns a boat and requires a mooring. Boat owners allocated an extended mooring location in key areas in villages or towns or with services should be aware that if the new Bye-laws are approved Waterways Ireland will increase the charges for moorings in the future to reflect the location, services, and size of boat.

Waterways Ireland recognises the current situation whereby a small number of boat owners use their boats as their sole or permanent residence. Proposals to make provision for this use of the navigation property have been included in the Bye-law changes.

Furthermore Waterways Ireland intends to work towards the provision of a small number of serviced house boat moorings on the canal network. Such provision will be subject to finance, land availability and compliance with requisite statutory approvals.

Waterways Ireland recognises that a transition period of a number of years will be required to implement this. In the interim these boat owners should apply for an Extended Mooring Permit.

The draft Bye Law amendments are currently being considered by Waterways Ireland’s sponsor Departments. When Waterways Ireland has Ministerial consent, it will proceed to public consultation on the proposed Bye-law amendments.

Waterways Ireland will continue to contact permit holders regularly to ensure they are kept up to date with the roll-out of the new permit. All queries about the enforcement of the current bye-laws or the Extended Mooring Permit should be directed to Shane Anderson, Assistant Inspector of Navigation: Tel no +353 (0)87 286 5726, Email shane.anderson@waterwaysireland.org . Queries about houseboats should be directed to Property & Legal Section Tel no +44 (0)28 6632 3004.

These changes are necessary steps to improve the management of the canals and waterway amenities for both the navigational and recreational user, so that investment in the new infrastructure and facilities which Waterways Ireland has undertaken is maximised for every user.