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:
- registering EPIRBs [PDF]
- getting a licence for a ship [PDF] or transferring a licence for a ship [PDF]
- getting a certificate for an operator by taking a course [DOC] followed by an exam [DOC]. And, for poor benighted foreigners who hold licences issued abroad, there is an application form for an Authority to Operate [PDF].
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.