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COUNTER POLLUTION, SALVAGE AND SEARCH

AND RESCUE FUNCTIONS

UK National Contingency Plan Exercise GREY SEAL Report

DIRECTORATE OF MARITIME OPERATIONS

Author: C Mulvana Owner: R Parkes

Client: MCA

Version 1.0

Date: 05.06.2017

Document History

Location

This Document will be located on the Government web site https://www.gov.uk/. Revision History

Date of this revision: 05.06.2017

Revision Date Summary of Changes

27 February 2017 First Draft

17 March 2017 Revised formatting

31 March 2017 Revised following Review and Debrief

27 April 2017 Final Draft

05 June 2017 Agreed Document

Approvals

Name Title Signature

R Parkes MCA Director of Maritime Operations

H Shaw Secretary of State’s Representative (SOSREP)

J A Wood Head of Maritime Operations

S Woznicki Head of Counter Pollution

C Mulvana Deputy to the SOSREP & Exercise Director

Distribution

Name Title

R Parkes MCA Director of Maritime Operations

Government Web site https://www.gov.uk/government/publications

Table of Contents

1. EXECUTIVE SUMMARY ....................................................................................................................................... 1

2. NATIONAL CONTINGENCY PLAN (NCP) - A STRATEGIC OVERVIEW FOR RESPONSES TO MARINE POLLUTION FROM SHIPPING AND OFFSHORE INSTALLATIONS. ..................................................................................................... 4

2.1 PURPOSE OF THE NCP ................................................................................................................................................ 4 2.2 IMPLEMENTATION OF THE NCP .................................................................................................................................... 4

3. INTRODUCTION ................................................................................................................................................. 5

4. PURPOSE ........................................................................................................................................................... 5

5. GLOSSARY ......................................................................................................................................................... 5

6. SAFETY .............................................................................................................................................................. 5

7. EXERCISE SPONSOR ........................................................................................................................................... 6

8. EXERCISE DIRECTOR ........................................................................................................................................... 6

9. AIM AND OBJECTIVES ........................................................................................................................................ 6

10. EXERCISE DEVELOPMENT................................................................................................................................... 7

11. EXERCISE SCENARIO .......................................................................................................................................... 8

12. EXERCISE PARTICIPANTS .................................................................................................................................... 9

13. EXERCISE CONDUCT ........................................................................................................................................... 9

14. EXERCISE CONTROLLERS .................................................................................................................................... 9

15. EXERCISE DIRECTING STAFF ..............................................................................................................................10

16. OBSERVERS.......................................................................................................................................................11

17. EXERCISE EVALUATION .....................................................................................................................................11

18. MEDIA OPERATIONS .........................................................................................................................................12

19. EVALUATION PROCESS .....................................................................................................................................13

19.1 EXERCISE PRACTICE IDENTIFIED AS ‘MOST EFFECTIVE’ ................................................................................................ 13 19.2 EXERCISE PRACTICE IDENTIFIED AS ‘LEAST EFFECTIVE’ ................................................................................................ 15

20. EVALUATORS REPORTS .....................................................................................................................................16

20.1 COASTGUARD OPERATIONS CENTRE (HUMBER) ........................................................................................................ 16 Objectives: ............................................................................................................................................................... 16 Evaluators Overview:............................................................................................................................................... 16 Most Effective: ........................................................................................................................................................ 17 Least Effective: ........................................................................................................................................................ 17

20.2 NATIONAL MARITIME OPERATIONS CENTRE (NMOC) ............................................................................................... 20 Objectives: ............................................................................................................................................................... 20 Evaluators Overview:............................................................................................................................................... 20 Most Effective: ........................................................................................................................................................ 21 Least Effective: ........................................................................................................................................................ 21

20.3 MARINE RESPONSE CENTRE (MRC) ....................................................................................................................... 23 Objectives ................................................................................................................................................................ 23 Evaluators Overview ................................................................................................................................................ 23 Most Effective.......................................................................................................................................................... 24 Least Effective ......................................................................................................................................................... 24 MRC Staff comments ............................................................................................................................................... 25

20.4 SALVAGE CONTROL UNIT (SCU) ............................................................................................................................ 26 Objectives ................................................................................................................................................................ 26 Evaluators Overview ................................................................................................................................................ 26 Least Effective ......................................................................................................................................................... 27

20.5 MCA COMMUNICATIONS BRANCH ........................................................................................................................ 28 Objectives ................................................................................................................................................................ 28 Evaluators Overview ................................................................................................................................................ 28 Most Effective.......................................................................................................................................................... 29 Least Effective ......................................................................................................................................................... 30

20.6 MCA OFFICE OF THE CHAIRMAN AND CHIEF EXECUTIVE (OCCE) ................................................................................. 31 Objectives ................................................................................................................................................................ 31 Evaluators Overview ................................................................................................................................................ 31 Most Effective.......................................................................................................................................................... 31 Least Effective ......................................................................................................................................................... 31

20.7 MARITIME RESILIENCE TEAM, DEPARTMENT FOR TRANSPORT ..................................................................................... 32 Objectives ................................................................................................................................................................ 32 Evaluators Overview ................................................................................................................................................ 32 Most Effective.......................................................................................................................................................... 33 Least Effective ......................................................................................................................................................... 33

20.8 HUMBER STANDING ENVIRONMENT GROUP ............................................................................................................ 36 Objectives ................................................................................................................................................................ 36 Evaluators Overview ................................................................................................................................................ 36 Most Effective.......................................................................................................................................................... 37 Least Effective ......................................................................................................................................................... 37

20.9 HUMBER LOCAL RESILIENCE FORUM ....................................................................................................................... 39 Objectives ................................................................................................................................................................ 39 Evaluators Overview ................................................................................................................................................ 39 Most Effective.......................................................................................................................................................... 40 Least Effective ......................................................................................................................................................... 41

20.10 LINCOLNSHIRE LOCAL RESILIENCE FORUM ................................................................................................................ 43 Objectives ................................................................................................................................................................ 43 Strategic Co-ordinating Group ................................................................................................................................ 43 Tactical Co-ordinating Group (TCG) ........................................................................................................................ 44 Most Effective.......................................................................................................................................................... 45

20.11 P&O FERRIES .................................................................................................................................................... 47 Objectives ................................................................................................................................................................ 47 Evaluators Introduction ........................................................................................................................................... 47 Most Effective.......................................................................................................................................................... 47 Least Effective ......................................................................................................................................................... 48

20.12 SHELL ............................................................................................................................................................... 49 Objectives ................................................................................................................................................................ 49 Evaluators Overview ................................................................................................................................................ 49 Most Effective.......................................................................................................................................................... 50 Least Effective ......................................................................................................................................................... 50

21. CONCLUSION ....................................................................................................................................................53

22. ANNEX A – PARTICIPATING ORGANISATIONS ...................................................................................................54

23. ANNEX B – OTHER PARTICIPATING ORGANISATIONS COMMENTS ...................................................................55

23.1 PHILLIPS 66 – TETNEY OIL TERMINAL ..................................................................................................................... 55 23.2 HM COASTGUARD COASTAL OPERATIONS ............................................................................................................... 56 23.3 CENTRICA RENEWABLE ENERGY – INNER DOWSING WINDFARM .................................................................................. 58 23.4 MARINE MANAGEMENT ORGANISATION ................................................................................................................. 59 23.5 ROYAL SOCIETY FOR THE PROTECTION OF CRUELTY TO ANIMALS (RSPCA) ..................................................................... 60 EXERCISE DIRECTOR COMMENT: THE RSPCA WERE REPRESENTED AT THE EXERCISE REVIEW AND DEBRIEF, IT WAS REEMPHASISED THERE

IS A NEED FOR RESILIENCE AND OF POTENTIAL TO DEVELOP A WILDLIFE RESPONSE STOP NOTE TO AID RESPONSE – O27 REFERS. ......... 62 23.6 FOOD STANDARDS AGENCY (FSA) ......................................................................................................................... 63 23.7 MCA BEVERLEY MARINE OFFICE ......................................................................................................................... 64 23.8 JOINT NATURE CONSERVATION COMMITTEE ............................................................................................................ 65

24. ANNEX C – EXERCISE REVIEW AND DEBRIEF .....................................................................................................67

25. ANNEX D - SUMMARY OF RECOMMENDATIONS ..............................................................................................69

26. ANNEX E - OBSERVATIONS ...............................................................................................................................79

27. ANNEX F - GOOD PRACTICE ..............................................................................................................................84

28. ANNEX G - GLOSSARY OF TERMS ......................................................................................................................87

29. ANNEX H – UK SEARCH AND RESCUE REGION ZONES .......................................................................................97

1. Executive Summary

1.1 Exercise GREY SEAL was held over 22nd and 23rd November 2016 to test the National Contingency Plan for Marine Pollution from Shipping and Offshore Installations (NCP). Government departments, local authorities, the shipping industry and their contractors were all tested in their response to a major shipping incident resulting in offshore and onshore pollution. As well as testing the response cells described within the NCP the office of the Minister for Transport also participated.

1.2 The aim of the exercise was to test the United Kingdom’s (UK) response to a major oil spill within the UK Exclusive Economic Zone (EEZ).

1.3 The exercise scenario involved a collision between a product tanker and a roro ferry resulting in a release of a large volume of crude oil from the tanker over a long period of time which would impact upon the coastline of Lincolnshire and Humberside within two days. An additional element to the scenario was the requirement to evacuate six injured passengers from the ferry which had sustained stern loading ramp damage rendering the ramp inoperable. This also resulted in a requirement to determine a place of refuge for the ferry.

1.4 Day one of the exercise was designed to test the initial response procedures of each organisation to a significant shipping pollution event. Day two of the exercise saw the incident timeline advanced one day to ensure that shoreline impact of oil occurred in a realistic timeframe. Day two primarily tested the salvage implications of the scenario and the shoreline response effort, including the resourcing of a prolonged pollution incident.

1.5 The exercise was primarily a ‘table-top’ event with no live assets physically deployed, with the exception of the local Coastguard Rescue Teams (CRT).

1.6 Ten response groups, each with their own pre-determined areas of responsibility, were observed and evaluated during the exercise using pre agreed success criteria. The major participants in the exercise were the Maritime and Coastguard Agency (MCA), the Secretary of State’s Representative (SOSREP), Lincolnshire and Humber Local Resilience Forum (LRF), P&O Ferries (P&O), Shell International Shipping and Trading Company Limited (hereinafter referred to as ‘Shell’) and the Norfolk, Suffolk and The Wash and Humber joint Environment Group (EG).

1.7 The initial response by all those involved in the exercise was in accordance with laid down practices and procedures with all relevant organisations being informed and responding appropriately.

1.8 Assessments of the potential pollution impact were quickly and correctly identified and appropriate resources notionally tasked to respond with short, medium and long term response requirements being addressed.

1.9 Response cells were correctly established as detailed within the NCP and communications between the cells initiated. Some of the cells experienced communications difficulties and these are covered in the main report.

1.10 Shell established their Incident Command System (ICS) in Grimsby and the exercise demonstrated that the UK system can work in tandem with ICS, both systems complemented each other very well proving good exchange of information.

1.11 Shell, their pollution response contractor and the local authorities involved all developed short, medium and long term response strategies for monitoring, containing the pollution and recovering and disposing of the waste.

1.12 The interaction between the shipping companies and the SOSREP was considered excellent and allowed full presentation of salvage and pollution response strategies.

1.13 There was discussion between the EG, Marine Management Organisation (MMO), Marine Response Centre (MRC) and other responding agencies/authorities on the authorisation and appropriate use of dispersants. These discussions concluded that dispersant use was not appropriate in the prevailing circumstances presented by the scenario.

1.14 During day one, the involvement of the Strategic Coordinating Groups (SCG) and Tactical Coordinating Groups (TCG) was limited whilst information was gathered and a fuller picture developed of locations and quantities of oil likely to make landfall. This involvement increased on day two following the progression of the timeline.

1.15 Evidence provided by evaluators, controllers, players and observers led the exercise planning team to conclude that the exercise achieved its over-arching aim and objectives and that the UK pollution response infrastructure currently in place can effectively respond to a major shipping incident causing significant pollution.

1.16 The exercise planning team felt that Exercise GREY SEAL effectively tested the national UK response system, underpinned by the NCP, as well as individual response organisations. More importantly it identified a number of key recommendations and learning points which, once addressed, will enhance UK marine pollution response contingencies.

1.17 The most salient learning point from the exercise was the need to ensure that all responders are clear about their overall roles and responsibilities, as clearly defined within the NCP.

1.18 A full list of recommendations, observations and good/best practice are detailed within Annexes to this report.

1.19 The HM Coastguard (HMCG) Standards branch will monitor progress on action taken in response to the recommendations by those tasked to address them.

I would personally like to thank all those involved in the planning and execution of this exercise, their expertise, dedication and enthusiasm throughout was commendable.

I would also like to commend all of the exercise participants who entered into the spirit of the exercise, executing the scenario as if it were a live incident and making it a successful learning experience for everyone involved.

Finally I offer my great appreciation to ABP Grimsby for the use of their facilities, providing support, accommodation and hospitality to exercise response cells and participants during the two day period.

Colin Mulvana Exercise Director

2. National Contingency Plan (NCP) - A strategic overview for responses to marine pollution from shipping and offshore installations.

2.1 Purpose of the NCP

2.1.1 The purpose of the National Contingency Plan is to ensure that there is a timely,

measured and effective response to maritime incidents. The owners and masters of ships and the operators of offshore installations bear the primary responsibility for ensuring that they do not pollute the sea. Harbour authorities are likewise responsible for ensuring that their ports operate in a manner that avoids marine pollution and for responding to incidents within their limits. However, ships, offshore installations and harbour authorities may face problems which exceed the response capabilities they can reasonably maintain, and in these circumstances the MCA may need to use national assets in the response to a marine pollution incident.

2.1.2 The National Contingency Plan sets out the circumstances in which the MCA deploys

the UK’s national assets to respond to a marine pollution incident to protect the overriding public interest.

2.2 Implementation of the NCP

2.2.1 The MCA, an Executive Agency of the Department for Transport (DfT), has overall

responsibility for the implementation of the NCP. For this purpose, MCA exercises the functions of the Secretary of State for Transport under the 1995 Merchant Shipping Act, including the Secretary of State’s intervention powers.

2.2.2 The SOSREP is empowered to act in relation to shipping and offshore installations.

In the absence of the SOSREP, the Deputy or designated personnel are empowered to exercise the SOSREP’s powers.

2.2.3 The Government has appointed the SOSREP to provide overall direction for salvage,

intervention and the prevention of marine pollution incidents involving ships or offshore installations which require a national response.

2.2.4 During significant shipping or offshore incidents, SOSREP exercises operational

control. As recommended in the late Lord Donaldson of Lymington’s report on Salvage and Intervention and their Command and Control, Ministers and senior officials should not attempt to influence SOSREP’s operational decisions while operations are in progress.

2.2.5 The SOSREP role does not include any responsibility for either at-sea or shoreline

clean-up activities, although SOSREP does have the decisive voice should an inter-cell confliction of priorities arise.

2.2.6 The Civil Contingencies Act 2004, Section 2, places a duty upon Category 1

responders to prevent an emergency, reduce, control or mitigate its effects, in relation to their functions and take any other action in connection with it. Local Authorities are Category 1 responders and are required to prepare and implement local response plans based on this requirement.

3. Introduction

3.1 Exercise GREY SEAL was a live, multi-agency oil spill response exercise, designed to test the United Kingdom’s NCP.

3.2 Held over the course of two days and involving over 500 participants from more than

60 organisations, Exercise GREY SEAL proved to be a successful event; verifying that the NCP does allow for a timely, measured and effective response to incidents of marine pollution from a shipping related incident.

3.3 The exercise was conducted over several locations, with no live assets deployed

other than the CRT who utilised the opportunity to conduct training and familiarisation during the exercise and was the first maritime exercise of its type to test the procedures and protocols for cascading information throughout the DfT from incident source to Ministerial level.

3.4 The severity of the scenario was designed to activate the strategic, tactical and

operational levels of the various response organisations and focussed on the three main response areas; counter pollution response to oil at sea and on the shoreline and at sea salvage activities to control the source of the spill.

4. Purpose

4.1 The purpose of this report is to capture lessons learnt from the exercise and produce recommendations, observations and areas of best practice for all participating organisations to consider adopting during an incident.

4.2 HMCG Standards Branch will monitor the progress and conclusion of the

recommendations and observations assigned to the MCA but it will be the responsibility of individual organisations to consider and develop any observations assigned to their own organisation.

5. Glossary

5.1 A full glossary of terms can be found in Annex F of this report.

6. Safety

6.1 All participants in Exercise GREY SEAL had responsibility for their own and others’ safety - including the public. As a result, there were no reports of any injuries or damage to the environment during the exercise.

7. Exercise Sponsor

7.1 Exercise GREY SEAL was sponsored by the MCA’s Director of Maritime Operations. The sponsor organisation was accountable for the delivery of the event and for ensuring lessons are captured and commensurate corrective actions and solutions are implemented.

7.2 The exercise sponsor has no authority to direct other organisations to act on the

recommendations made in this report. Therefore observations have been made as an alternative for all NCP stakeholders to consider.

8. Exercise Director

8.1 An Exercise Director was appointed for exercise GREY SEAL and was accountable to the Exercise Sponsor for the preparation and delivery of the exercise. This included the planning and execution of the exercise and the production of the Post Exercise Report.

8.2 During the planning phases the Exercise Director led a multi-agency planning team

drawn together from internal and external participating organisations. This diverse team ensured that each team and organisation was represented and that their own exercise aim(s) and objective(s) would be catered for during the exercise.

9. Aim and Objectives

9.1 The aim of the exercise was to test that the NCP was still fit for purpose and could guide all responding organisations effectively, to manage a marine oil spill of national significance, from a shipping related incident within the UK EEZ.

9.2 Participating organisations establishing response cells in accordance with the NCP

were requested to produce a number of objectives to enable an evaluation criteria for individual cells to be developed.

9.3 These are located in the evaluation report which is located in Section 20 of this report.

10. Exercise Development

10.1 The MCA membership of the core planning team was selected by the Exercise Director for their experience, knowledge and expertise in their particular fields to ensure the right balance of people were available to develop and execute a credible exercise scenario.

10.2 The core planning team also comprised of proficient experienced representatives

from Shell, P&O and Lincolnshire and Humber Emergency Planning Units. Petrofac Training Services (PTS) provided the project management for the exercise.

10.3 Other experts were invited to attend the planning meetings on an ad hoc basis to

provide valuable input at specific stages of the planning process. 10.4 The table below identifies the Core Planning Team assigned to this exercise.

Core Planning Team

Name Role Organisation

Colin Mulvana Exercise Director MCA

Lisa McAuliffe Project Manager PTS

Dominic Stevens Exercise Secretariat MCA

Gilles Ranchoux Planning Team Member Shell

Dawn Gibson Planning Team Member Shell

Grant Laversuch Planning Team Member P&O

Geoff Matthews Planning Team Member MCA

Andy Jenkins Planning Team Member MCA

Cliff Robbins Planning Team Member Lincolnshire LRF

Alan Bravey Planning Team Member Humber LRF

Joanne Groenenberg Media Planning Lead MCA

10.5 The planning team met physically and via conference call on a monthly basis between

May and November 2016, with the locations of meetings varied to accommodate the national imprint of the exercise and reduce time and financial impacts.

10.6 Meeting agendas conformed to a standard format, allowing the Exercise Director to

address the composite planning functions and proposed corrective actions. 10.7 The minutes of planning meetings were accurately captured and a rolling action plan

maintained and closed off when appropriate. 10.8 Outside of the meetings regular communication was maintained at all levels across

the organisations ensuring a thorough integrated planning process was achieved.

10.9 PTS was appointed to assist with the project management of the exercise. They produced a range of excellent documentation and supported the Exercise Director and planning team throughout.

10.10 PTS also maintained an evolving exercise briefing through PowerPoint to provide

status updates to the planning team. This proved useful at monthly meetings as a means of catch up and confirmation, especially when attendees varied from meeting to meeting.

11. Exercise Scenario

11.1 To fulfil the overall aim of the exercise of responding to significant pollution the scenario was built around a collision between two vessels; a Shell product tanker and a P&O roro ferry.

11.2 The collision occurred approximately 30 nautical miles east of Lincolnshire, whilst the

product tanker was on passage to the Humber and the ferry was on a regular route to Rotterdam.

11.3 Six passengers on the ferry sustained injuries and were required to be evacuated by

helicopter. The ferry itself suffered damage to the stern loading ramp rendering the ramp inoperable. No other damage was sustained to the ferry and other than a small quantity of hydraulic oil there was no release of hydrocarbons to the sea.

11.4 The collision did however cause significant

damage to the product tanker; rupturing No.2 port side cargo tank resulting in the release, over the duration of the exercise, of approximately 6000 metric tonnes of crude oil to the sea.

11.5 The first day of the exercise was played in real time1, with the first distress call

transmitted by the ferry initiating the start of the exercise. Consequent notifications and information gathering triggered the mobilisation of the expected key response cells during the first day.

11.6 To simulate pollution from the product tanker reaching the shoreline, the exercise was

played forward 24 hours, thus making day two of the exercise day three of the incident. This allowed for the local authorities to prepare for and implement a shoreline response strategy and the key environmental bodies to evaluate the effect on the environment.

1 There was some pre-positioning of personnel to ensure maximum benefits

12. Exercise Participants

12.1 A full list of participating agencies and organisations can be found in Annex A of this report

13. Exercise Conduct

13.1 The exercise was allowed to flow naturally from the initial distress call made by the ferry, this enabled participants to respond to an escalating situation, allowing them to realise their roles and responsibilities as if reacting to a live incident.

13.2 Pre-scripted injects were available to the exercise directing staff and fed into the

exercise at various stages to ensure key elements of the response were tested and objectives achieved.

14. Exercise Controllers

14.1 The Exercise Director and a number of exercise controllers occupied the Command Cell, which was located at the ABP Port Offices in Grimsby. They managed the pace of the exercise and ensured key events were executed in accordance with the agreed timeline of events.

15. Exercise Directing Staff

15.1 Exercise directing staff were positioned within the key response cells to assist the Exercise Director and controllers with the execution of the exercise and ensure the exercise was kept on track and in line with agreed expectations.

15.2 The table below identifies the Exercise Controllers and Directing Staff and their

respective locations.

Exercise Directing Staff

Name Location Organisation

Colin Mulvana Command Cell, ABP Grimsby MCA

Lisa McAuliffe Command Cell, ABP Grimsby PTS

Gilles Ranchoux Command Cell, ABP Grimsby Shell

Dawn Gibson Command Cell, ABP Grimsby Shell

Marko Gospic Command Cell, ABP Grimsby Shell

Grant Laversuch Command Cell, ABP Grimsby P&O

Allan Quinn Command Cell, ABP Grimsby P&O

Steve Cox Command Cell, ABP Grimsby MCA

Catherine Jefferson Command Cell, ABP Grimsby ABP

Gary Ferguson Command Cell, ABP Grimsby RVL

Andy Lang Marine Response Centre, ABP Grimsby PTS

Kaimes Beasley Salvage Control Unit, ABP Grimsby MCA

Stuart Hankey Environment Group, ABP Grimsby EA

Geoff Matthews CGOC Humber MCA

Andy Jenkins NMOC Fareham MCA

Joanne Groenenberg Media Briefing Centre, Cleethorpes MCA

Cliff Robins and Ian Reid

TCG / SCG Lincolnshire Fire and Rescue HQ

LCC

Alan Bravey TCG / SCG / RCG Humber Brough / Clough Road

HEPS

Thomas Smith Incident Management Team London / Grimsby

Shell

Ville Patrikainen Incident Management Team, Dover P&O

16. Observers

16.1 A limited number of observers attended on both days of the exercise and were hosted by the head of the response cell they were visiting.

17. Exercise Evaluation

17.1 The Exercise Director assigned an Evaluation Lead to oversee and co-ordinate a team of evaluators from a range of participating agencies and organisations.

17.2 This team was responsible for the evaluation of the key response cells during the

exercise; in accordance with the agreed evaluation criteria, to determine to what degree the objectives for that cell / organisation had been achieved.

17.3 On completion of the exercise all evaluators were requested to compile and submit

their evaluation assessments, including recommendations and areas of best practice, to the Evaluation Lead. This information was then collated and presented in a formal report to the Exercise Director and to which has formed the basis of this report.

17.4 The table below identifies the evaluators assigned for the exercise

2 Appointed by Shell

Exercise Evaluators

Name Location Parent Organisation

Lee Fisher Command Cell, ABP Grimsby MCA

Jim McKie MRC, ABP Grimsby Marine Scotland

Guy Heaton SCU, ABP Grimsby BEIS

Stuart Hankey EG, ABP Grimsby Environment Agency

Bernie Bennett Humber Royal Hotel, Grimsby Morlich Services2

Steve Harris CGOC Humber MCA

Carl Evans NMOC Fareham MCA

Jo Evans SCG Lincoln NRW

Sandie Higginbotham

TCG Lincoln MCA

Dustin Eno Media Briefing Cell Navigate Response

Lisa Gilmour DfT, London DfT

Lisa Clark SCG / TCG Humber HEPS

Ville Patrikainen Incident Management Team, Dover P&O

Alex Smith CGOC Humber MCA

18. Media Operations

18.1 The media response operations were managed and co-ordinated by the MCA, who engaged Navigate Response to project manage the media element of the exercise.

18.2 There was live traditional and social media play during the exercise utilising Navigate

Response’s media platform Triton3. Key agencies participated from the media briefing cell located at the Pelham Suite, Grimsby, other response organisations were active and participated remotely in Dover, London and Lincoln.

18.3 The table below identifies the Media Sub Group members.

Media

Name Organisation

Joanne Groenenberg MCA

Julia Gosling MCA

Dustin Eno Navigate Response

Bill Lines Navigate Response

18.4 As the lead authority, the MCA Press Office agreed a pre-exercise public press

release with other participating authorities. The purpose of the release was to make the public aware that an exercise was taking place and thereby allay any public concern.

3 Triton is Navigate Response’s social media simulation platform.

19. Evaluation Process

19.1 A number of organisations submitted objectives for the exercise, 10 of which were identified for formal evaluation:

Marine Response Centre

Salvage Control Unit

NMOC Fareham

CGOC Humber

Multi-agency Media Response

Norfolk, Suffolk and The Wash and Humber joint Environment Group

Lincolnshire Strategic and Tactical Co-ordinating Groups

Humber Strategic, Tactical and Recovery Co-ordinating Groups

Shell London and Grimsby Incident Management Team

P&O Incident Management Team

19.2 The Evaluators were selected for their expertise and knowledge in a particular field as well as their knowledge of pollution and emergency response.

19.3 This expertise and knowledge was a key element to ensure there was a full and

accurate evaluation on how response cells, groups and individuals reacted and whether respective roles and responsibilities were effectively fulfilled.

19.4 Where applicable, the evaluation areas and assessment criteria were generic and

applied to all cells and groups to enable across the board analysis. In those cells and groups with specialist evaluation areas, bespoke assessment criteria were used.

19.5 A separate set of success criteria was also used for each evaluation area to aid

the Evaluator. 19.6 Evaluators were required to comment on whether an organisation’s objectives

had been achieved or otherwise. In some cases this was an assessment over two or more cells.

19.7 The evaluation reports received from each Evaluator have been analysed by the

Exercise Evaluation Lead and the planning team and broken down into recommendations, observations and good/best practice.

19.1 Exercise Practice Identified as ‘Most Effective’

19.1.1 The Exercise Planning Team consisted of personnel from the key participating

organisations. 19.1.2 During the planning stages they were required to communicate on a daily bases

to ensure the proposed objectives we’re being met during the scenario development.

19.1.3 Planning team members were geographically spread therefore good use of conference call facilities were utilised to ensure core members were involved in all of the planning meetings if not able to be available in person.

19.1.4 During the execution of the exercise, the Core Planning Team formed part of the

exercise command cell in Grimsby and the exercise directing staff in key responding areas.

19.1.5 The aim and objectives of the exercise were clearly identified for the key exercise

participants and became critical in forming the basis for the performance measurements. Essential component parts associated with the planning process were identified and the necessary sub groups established to work through the activities.

19.1.6 The planning team were very experienced in exercise planning and many had

first-hand knowledge of previous large scale multi-agency Regional, National and International exercises involving at sea and shoreline activities.

19.1.7 The individual members also contained the appropriate level of expertise in their

fields to ensure all elements of the exercise were adequately prepared for with good leadership during planning meetings.

19.1.8 The scenario and timeframe was realistic and engaged the entire exercise

community. It was designed to be free-flow and largely unscripted to enable the response teams to react as they would for a live incident. This meant that preparations for future escalation was continually evolving and kept players active over the course of the two days.

19.1.9 The exercise documentation was produced in good time and fully supported all

elements of the exercise. The exercise telephone directory was purposefully distributed just prior to the exercise so as not to serve as a check list of persons, organisations or authorities to call.

19.1.10 The planning team executed the exercise by putting in place clear command and

control arrangements with communication pathways for exercise directing staff and evaluators.

19.1.11 The debrief process proved successful in capturing the critical points and allowing

the planning team to ensure the exercise ran in alignment with the objectives. 19.1.12 A hot-wash was conducted immediately following ‘Endex’ to highlight the main

points of the exercise. 19.1.13 An exercise email account was created to collate all correspondence relating to

the exercise development. The email account was also used during the exercise to assist with the tracking of the exercise. Despite being requested in the Exercise Orders for all email address lists to include the exercise account this was not strictly adhered to and many emails were not received, which sometimes made it difficult for the Command Team to track where errors had occurred.

Recommendation R01: An exercise email account to be created when the MCA planning team has been assembled to store documentation relating to the exercise providing access to all internal planning team members.

19.1.14 At the end of day 1 the Evaluation Lead conducted a feedback session with all

evaluators. This was achieved prior to any other debrief session as such information was received first hand and advised on whether objectives were being realised.

19.2 Exercise Practice Identified as ‘Least Effective’

19.2.1 There was little resilience for the Exercise Director and during incident response

it was noticeable due to lack of information being disseminated at certain stages of planning. It would have been beneficial to have an additional person working closely with the Exercise Director to ensure continued progress of the planning during periods when the Exercise Director was absent. The assigned person must be a representative of the MCA.

Recommendation R02: A Deputy or Assistant Exercise Director to be considered for future National Contingency Plan exercise planning team to support the Exercise Director.

20. Evaluators Reports

20.1 Coastguard Operations Centre (Humber)

20.1.1 The Coastguard Operations Centre (CGOC) participating in this exercise was

Humber and is located in Bridlington East Yorkshire. The UK maritime response area is divided into 36 zones each CGOC is assigned specific geographical zones however due to the UK National Network system all CGOCs are able to support each other during incident response. A map of the zones can be found in Annex G.

20.1.2 HM Coastguard is responsible for:

Minimising loss of life amongst seafarers and coastal users;

Responding to maritime emergencies 24 hours a day;

Developing, promoting and enforcing high standards of maritime safety and

pollution prevention for ships;

Minimising the impact of pollution on UK interests;

Responding to non-maritime incidents such as floods, searches or assisting

in evacuating areas.

Objectives:

20.1.3 To exercise the national network, including the Strategic Command Room, in relation to a major maritime incident.

20.1.4 To test national maritime operations decision making at strategic and tactical

levels 20.1.5 To exercise the warning and informing interfaces between maritime operations

and all stakeholders (internal and external) up to ministerial level.

Evaluators Overview:

20.1.6 The CGOC Humber was supported by a number of CGOC’s around the UK

throughout the exercise. 20.1.7 The CGOC team was controlled well throughout the exercise by the Controller. 20.1.8 Alteration to working hours, words of encouragement and strong leadership saw

positive and professional engagement and support from the team being given to the Controller.

20.1.9 CGOC Humber remained an operational base during the exercise and the team

worked well to ensure they maintained a full (live) response capability.

Most Effective:

20.1.10 A good working practice was observed in a variety of areas. This included the

Search Mission Coordinator (SMC) maintaining Action Coordinating Authority (ACA) throughout and the Major Incident Check List being referenced.

20.1.11 Use of the Integrated Coastguard Communication System (ICCS) to perform

“Connect Calls” between the Duty Counter Pollution & Salvage Officer (DCPSO), Surveyor and Master of the tanker assisted with clear and accurate communications.

20.1.12 Due to the serious and escalating nature of the situation the Duty Operations

Director (DOD) was informed and a decision made to activate the strategic command room located at the National Maritime Operations Centre (NMOC).

20.1.13 Conferences in the Operations room, with Commanders, Controllers and

Coastguard Rescue Service were used to good effect and helped maintain the Common Recognised Information Picture (CRIP). The Heads of Cells meeting brought similar benefits.

20.1.14 The Duty Commander is responsible for overall strategic command of the UK’s

Search and Rescue resources. Part of their duty is to ensure that workload across the Network is balanced against available team numbers and skills. The Duty Commander utilised the CRIP to make decisions to provide Zone support to CGOC Humber by removing all non-essential Zones.

20.1.15 On day two CGOC Belfast took control of marine band radio channel 16 and

maintained communications with CGOC Humber using the Group 14 talk group on ICCS.

Least Effective:

20.1.16 Staff at the Maritime Operations Officer (MOO) level have received introductory

training of Joint Emergency Service Interoperability Programme (JESIP) principles. The Principles need further embedding and integration into HMCG Concept of Operations to ensure full benefit of the Principles are realised. In this exercise, the use of the emergency service model METHANE to brief Police would have been beneficial.

Exercise Director Comment: Maritime Operations Staff have received

awareness training in JESIP principles. JESIP forms part of Basic Training for all grades in Maritime Operations. Consolidation of JESIP principles into Coastguard Operations will continue over the next year.

20.1.17 On day one, a decision was made not to inform other emergency services as it

was considered a marine incident. On day two it appears an assumption was made that contact with other Emergency Services would be made by the Coastguard Liaison Officers (CGLO) at the MRC, as such this initial alerting and

4 These have subsequently been renamed as a ‘Talk Box’, with ten available to the network

notification requirement was still not completed by the CGOC Humber during the exercise.

20.1.18 Whilst this nature of maritime incidents quite often precludes the need for other

emergency services to become involved, in this case a clear opportunity was missed. It is vitally important that the SMC and command team have the foresight and inclination to predict an impact on the public or environment at large and therefore a need to alert or notify other emergency services or authorities in an appropriate timeframe.

Recommendation R03: OmS procedures, SMC and JESIP training should be reviewed to ensure they encourage thought processes of engaging with partner organisations at the earliest opportunity. Post Exercise Note: The MCA’s Major Incident Plan has been revised, and ‘Operation WAYPOINT’ developed, which provides a clear unambiguous route to informing other emergency services and authorities that may be required to put in place arrangements for dealing with a maritime incident that has the potential to move shore side. This revised Plan and Operation Order will become live in the Spring of 2017.

20.1.19 The division of responsibilities became confused when zones from CGOC

Humber’s normal area of operation were distributed elsewhere in the network (a process known as ‘Zone Flexing’). As a result CGOC Holyhead received a call which had been intended for GGOC Humber.

20.1.20 The NMOC Controller undertook some tasks without prior knowledge of CGOC

Humber which also confused control of the incident. The NMOC Controller made ViSION entries in respect of staffing levels and appeared to be considering resilience options for CGOC Humber in isolation, without consultation with the Controller at Humber

20.1.21 The NMOC issued a second SAR Situation Report (SITREP) after taking control

of the incident which was used to inform other agencies that the incident was now being co-ordinated from the NMOC, this appeared to confuse matters, with outside agencies enquiring as to what new contact numbers they should use.

20.1.22 Any hand over of incident coordination should be seamless and with the new

Network established, it should not be necessary to communicate a handover to other agencies.

20.1.23 Operational control of the incident appears to have been undermined by a lack of

division of responsibilities. Maritime Operations should reinforce the need to establish where in the Network coordination lies and a clear CRIP should be in place before planning and executing network flexing, formal reporting and staffing resilience. Consideration should be given to flexing “missions” and not “dividing zones”, because removing Zones from CGOC Humber’s control impacted on the overall Mission delivery.

Recommendation R04: A review of procedures and protocols to be conducted to ensure cohesion during division of responsibilities and assigning roles during incident response.

20.1.24 The MCA uses a number of formal reports to convey important operational

information on a regular basis. These reports are aligned to varying MCA operations and awareness of information overload should be maintained for large scale incidents.

20.1.25 With various formal reports required to support operational activities, the

workload on HMCG and the potential to confuse end users is significant in a major incident. It is suggested that a review of formal reports such as Search and Rescue (SAR) SITREP, Pollution Report (POLREP), Defect Report (DEFREP) and European Union (EU) SITREP etc. is conducted to determine if the number of formal reports used can be rationalised in any way.

Recommendation R05: Rationalisation of formal reports to be discussed, with due consideration given to timings of submission and possible duplication.

20.2 National Maritime Operations Centre (NMOC)

20.2.1 The NMOC is located at Fareham in Hampshire and is the strategic support

centre for a new integrated network with 10 other coordinating stations around the UK, working together to manage the national workload.

Objectives:

20.2.2 To exercise the national network, including the strategic command room, in relation to a major maritime incident;

20.2.3 To test national maritime operations decision making at strategic and tactical

levels; 20.2.4 To exercise the warning and informing interfaces between maritime operations

and all stakeholders (internal and external) up to ministerial level.

Evaluators Overview:

20.2.5 Overall, the observed response of HMCG at the NMOC was measured,

proportionate and effective, with good interaction and support from all levels of command. The MCA Major Incident Plan (MIP) and NCP would benefit from further exercising to ensure wider understanding and familiarity to assist in any validation or review.

20.2.6 There is a clear need for wider group and cell communications and the capability

to understand any decisions made. This would require use of the Joint Decision Model (JDM) process and the ability to facilitate a common information sharing platform to ensure shared situational awareness at all levels of the multi-agency response.

20.2.7 A Controller RAG (Red/Amber/Green) statement was made within 15 mins of the

first call. A, brief to the NMOC Commander from CGOC Humber followed, prompting early plan development, instigating a wider national support network.

20.2.8 A major incident was declared in a timely manner following consultation between

tactical and strategic level commanders and use of the newly issued MIP. 20.2.9 HMCG command decisions focussed on Coastguard operations, with no sharing

of information or consideration being given to the SCG’s, TCG’s or other NCP response cells.

20.2.10 This was also the same in reverse; with decisions from the NCP response cells

not being fully communicated to Coastguard strategic commanders.

Recommendation R06: Coastguard Liaison Officers positioned in response cells to be provided with training on roles and responsibilities to ensure up to date information is disseminated to other operational cells/stations.

Recommendation R07: The SCG should be the main coordinating group for shoreline response to maintain the collective strategic oversight and direction of the incident. This capability should be clearly established within operational doctrine.

Most Effective:

20.2.11 At an early stage wider NMOC and national network support capability was

utilised to relieve and mitigate the challenging workload consequential to a major incident. It was also evident that having both live tactical and strategic level officer command assisted in early recognition and declaration of a major incident status, although clear accountability and understanding is required between all network assets to clarify who is responsible for the various operational parameters.

20.2.12 Situational awareness regarding positions of critical Offshore Renewable Energy

Installations (OREI) and sub-sea infrastructure was positive, with operations staff utilising C-Scope to obtain good domain awareness.

20.2.13 Management of the search and rescue personnel Tote board normally proves

problematic, particularly with highly populated ships, i.e. ferries and cruise liners. However, there was good control of the ferry evacuation and maintenance of a search and rescue Tote board for residual crew and passengers. This was underpinned by a good understanding of consequential impacts and re-verification of reported muster returns.

Least Effective:

20.2.14 An updateable and expandable recording format is required to provide visibility and understanding to all. Consideration that the format has compatibility with external agency command processes, whereby overall shared situational awareness can be facilitated.

Recommendation R08: Consider development and implementation of an updateable and expandable recording format.

20.2.15 Throughout the exercise, a Common Operating Picture (COP) was facilitated by

Shell to assist the Shared Situational Awareness (SSA). Unfortunately the system could not be updated by all agencies and the requirement for a common information sharing platform is a current capability gap.

20.2.16 SSA is one of the five underpinning JESIP principles for joint working. Resilience

Direct (RD) is used by some LRF incident responders.

20.2.17 During the exercise a mock social media and news feed was provided (Triton).

At no time were Coastguard Commanders, responsible for the co-ordination of the incident, aware of these media news-feeds. MCA media briefs should appraise and feedback these issues to Coastguard Commanders.

20.2.18 There is currently no news or social media feed monitoring capability in CGOC’s / NMOC. HMCG are blind to this potential source of information often live from the scene, which would aid them greatly in understanding the evolving picture and allow better understanding of the challenges they and the wider team are facing as well as the general public opinion, mood and reaction.

Exercise Director Comment: Post exercise - this capability has been

provided by the use of Surface Hubs within each operations centre. 20.2.19 The NMOC Commander’s Operational Briefing Note (OBN) is an important

briefing tool used to cascade communications to DfT and Ministers. However the OBN required significant tactical and strategic level resourcing to compile, causing an adverse effect on command activities, timelines and operational outputs.

20.2.20 Whilst the duty NMOC Commander needs to sign off the statement other support

staff or infrastructure should be provided to compile the information for simple review this will release the Commander to maintain an overall strategic view of the situation.

Recommendation R09: Consider implementing training for support staff to compile OBNs/statements on behalf of the NMOC Commander prior to sign-off and distribution.

20.2.21 Whilst due consideration should be given to HMCG internal needs, caution must

be applied to the impact on other briefing formats that are used in the exercise, i.e. SOSREP to Office of the Chairman and Chief Executive (OCCE) to DfT to Ministers.

20.2.22 As a separate matter it may also be more efficient to utilise the IIMARCH JESIP

template (http://www.jesip.org.uk/IIMARCH-template) to organise internal / external operational-tactical-strategic briefings which would suit up, down and across communications.

Recommendation R10: Consider convening a discussion to assess the appropriateness of using IIMARCH JESIP template for SITREPs and briefings.

http://www.jesip.org.uk/IIMARCH-template

20.3 Marine Response Centre (MRC)

20.3.1 The MRC considers and implements the most appropriate means to contain, disperse, and remove potential pollutants from the scene based on all the information available to them.

Objectives

20.3.2 To exercise the NCP’s incident alerting and response activation procedures, culminating in a coherent and effective national commitment.

20.3.3 To exercise the MRC, assess the effectiveness of current internal procedures

and to test the command and control and other interactions between the MRC and other maritime and participating land based response cells.

20.3.4 To exercise interfaces and interdependences across all response levels, looking

particularly at EG, Scientific and Technical Advisory Cell (STAC) functions, cross-government and inter-agency liaison, and the co-ordination of public communication arrangements.

Evaluators Overview

20.3.5 The initial alert process was clear and followed protocol. 20.3.6 The Chair of the MRC brought the team together well during the initial stages of

the response. It would have been useful to see a clearer procedure set out during the early stages of the response but this is a difficult process to achieve during times of duress and with new and inexperienced team members.

20.3.7 The early identification of a Deputy

Chair is to be encouraged. It must be said though that during this exercise, when it mattered, a Deputy was required, one was assigned but having something in place permanently and from the outset would ensure there is a continuous and clear command and control process in place, especially during times where the Chair may be otherwise engaged at short notice.

Recommendation R11: Identification of personnel within the MRC to act as Deputies when key members of the team are absent.

20.3.8 The MRC engaged with the other response cells very early into the response.

This is to be commended and a process which should be encouraged by all response cells.

20.3.9 Liaison Officers (LO) were requested and established early into the response however there appeared to be some uncertainty by some LO’s as to what their role / expectation was within the MRC.

Observation O01: Consideration to review the STOp Notice with regard to the role of LRF/Local Authority liaison officers in the MRC.

Most Effective

20.3.10 The MRC established an agenda during team briefings which enabled the MRC to settle into a routine.

20.3.11 Incident logbooks were distributed to members of the team which should have

helped ensure an accurate log of events was captured throughout. 20.3.12 Oil spill modelling predictions provided by both the MCA and Oil Spill Response

Limited (OSRL) created some confusion as they produced different results, expertise within the MRC meant these issues could be discussed and clarified with the other key responding agencies.

Exercise Director Comment: Oil spill modelling programmes provide prediction results for an oil spill. They should never be taken as an accurate picture or prediction but should be discussed between interested parties and considered throughout any response.

20.3.13 The MRC made good efforts to broker and sustain contacts with the various

response groups responsible for shoreline response. This included, identifying risks and priorities and communicating (internally and externally) outputs both visually and orally.

20.3.14 Stateboards designed for use in the MRC had been prepared but were not able

to be displayed on the walls, therefore blank anti-static Magic Whiteboard sheets were utilised as an alternative.

20.3.15 The MRC appeared to have key response documents i.e. charts and sensitivity

mapping to assist with their at sea response planning. There was also good focus on the media interest surrounding this element of the response which is to be encouraged throughout any incident / exercise.

Least Effective

20.3.16 There was a lack of resilience in a number of important MRC roles, notably the Chair, (as mentioned earlier) but also a CPSO and additional Scientific Advisor, all of which would have aided the team not only during the exercise but also for resilience purposes. The MRC would have also benefitted from additional administration support.

Recommendation R12: Assess the staffing levels and resilience requirement in the MRC.

20.3.17 Whilst white boards were an adequate medium on this, the MRC’s record keeping / event logging, should be made available electronically.

Recommendation R13: Consider development of appropriate formal electronic logging system to incorporate action assignments and decision making.

20.3.18 There were obvious issues with the oil pollution modelling outputs, which were

not always in the evaluator’s opinion of the best quality and had to be ignored on at least one occasion, and therefore provided at times little or no confidence when setting out a counter pollution strategy.

Recommendation R14: Review the process of “central modelling information”, discussions should take place with other relevant parties to discuss any differences with modelling predictions which is critical to responders, advisors and for public assurance.

MRC Staff comments

20.3.19 There was tension within the cell between OSRL and the MCA regarding roles and responsibilities. What was lacking was an Incident Action Plan (IAP), which OSRL / Shell would have worked up and shared, for integration with MCA actions. OSRL preparations didn’t correlate with the developing scenario.

Recommendation R15: Consideration to be given to convening a meeting to clarify the MCA and OSRL roles and responsibilities including the requirement for production of an IAP.

20.3.20 The MRC should have a ‘room manager’ (common practice amongst other Cat 1

Responders), and Standing Operating Procedures (SOP) should be developed.

Recommendation R16: Consideration should be given to provision of a room manager for the MRC and a programme of training and development for the role.

20.3.21 The MRC should convene more structured sub cells: Air Cell, At Sea Response,

Modelling and Environmental, Logistics and Cost Recovery, with representatives from relevant contractors.

Recommendation R17: Consideration be given to a review of the current MRC structure with regard to sub cell structure, activity and responsibilities.

20.3.22 Briefing notes or Action Cards for external contractors and liaison officers

participating in the MRC would be useful to aid understanding and expectations and help improve information flow between cells.

Recommendation R18: Consider the development and use of Action Cards for key roles within the MRC membership

20.4 Salvage Control Unit (SCU)

20.4.1 The SCU is established to monitor salvage operations and actions that are being taken and / or proposed relating to salvage activity and to ensure that such actions do not have an adverse effect on the safety of personnel and the environment.

Objectives

20.4.2 To exercise the SOSREP function in relation to a major shipping incident, establishing a Salvage Control Unit and testing communication protocols across Government;

20.4.3 To test the new European Commission (EC) Places of Refuge (PoR) Guidance.

Evaluators Overview

20.4.4 The SOSREP was alerted to the incident by the Duty CPSO early into the response.

20.4.5 After the initial clearer information on the incident started to be gathered and

relayed to the SOSREP, members of the SCU staff were contacted and advised of a potential requirement for an SCU to be established.

20.4.6 Once confirmed that the tanker was

adrift and with the potential to ground within a few hours the trigger point had been reached and the SOSREP established an SCU with appropriate members of MCA staff mobilised to a pre-established location5. Other members of the SCU were to be contacted by the Duty CPSO.

20.4.7 At the first SCU meeting the SOSREP ensured that the roles and responsibilities

of the SCU staff were adequately addressed and that these roles were clearly understood.

20.4.8 It was felt that a ‘member introduction sheet’ may have been of benefit for each

member of the SCU to have at the start of the first meeting as an aide to members roles, although these were available they were not utilised on this occasion.

20.4.9 An established agenda was followed throughout the meeting, during which the

SOSREP requested Shell and SMIT (the appointed salvors) to complete a PoR request form and submit back to the SCU in line with the EU PoR guidance document. Unfortunately the exercise closed before the PoR process could be

5 All response cells for this exercise were pre-determined.

fully explored but SMIT did successfully submit the PoR request form, prior to the end of the exercise which allowed for some hypothetical discussion.

20.4.10 The SCU was very well run, with SOSREP proficiently assimilating all information

presented at the meetings and briefing in a clear, structured and direct manner. 20.4.11 Shell’s decision to engage SMIT on a wreck hire contract was challenged, due to

the nature of the situation by the SOSREP having independent salvage advice. Following discussion an agreement was reached to apply a Lloyd’s Open Form as the more appropriate contract.

20.4.12 A member of the MCA OCCE was positioned in the SCU with a function to provide

updates on Governmental correspondence, recording appropriate details as required, this role was beneficial as it relieved the SOSREP of that function who was able to focus on the salvage response.

Least Effective

20.4.13 The exercise was designed to test the provisions and implementation of the NCP therefore the responding groups should function as a “National Contingency Team”, this was not obvious during the first day of the exercise. Such meetings are likely to be essential where time constraints result in no SITREP’s being issued by the SCU or communicated to the SCU by other cells.

20.4.14 One notable example of technical information being incorrectly documented in

minutes, was the recording of “Hydrogen Sulphate” as the substance of concern, when it was actually “Hydrogen Sulphide”. This error is important as the two compounds have markedly different impacts and effect on the response measures. This error was subsequently identified and the minutes amended accordingly.

20.5 MCA Communications Branch

20.5.1 The MCA Communications Branch press officers are responsible for handling all

media liaison for the Agency. They work reactively and proactively with print, broadcast and online organisations as well as engaging with a wider audience via various social media platforms.

Objectives

20.5.2 Ensure all groups and individuals have a consistent understanding of thresholds for alerting MCA and DfT press offices, the agreed processes, and how the branch work both in and outside working hours;

20.5.3 Review the flow of information at each stage of an incident, maintaining close

liaison with the lead organisation; 20.5.4 To test the players’ ability to organise a media conference and media briefings.

Evaluators Overview

20.5.5 The Duty Press Officer (DPO) became aware of the incident through social media and a call from the BBC at 0830. Whilst not alerted by HMCG in the first 30 minutes, the call from the BBC emphasises the need for HMCG to inform the DPO in a timely manner to pre-empt press interest. Subsequent contact by the DPO with HMCG as met with a useful information flow.

20.5.6 MCA press officers faced intense media pressure and were quickly

overwhelmed. Most calls were eventually returned, but some journalists experienced long delays. To some extent this was inevitable, and during a real incident press officers would be backed up with additional back office support. Information coordination with emergency services, local authorities and Shell was a strength, but unfortunately there were issues with some other players.

20.5.7 A multi-agency Media Briefing

Centre was established. On day one this mainly consisted of press officers working remotely, on day two the MCA, Local Authorities, Shell and Government Press Officers worked as a team, with a handful of other press officers working remote. The relevant LRF Warning and Informing Groups were communicated with via the two LA press officers allocated to the media cell. One press conference was organised, which on the whole went well, although set back by Communications problems.

20.5.8 The social media simulator, “Triton”, was projected onto a big screen throughout the day as well as being available to all players on their internet enabled devices.

Most Effective

20.5.9 Whilst colocation with the SCU and MRC would have had its benefits, the venue for the media cell proved excellent, with plenty of space, uninterrupted access to Wi-Fi, sufficient electrical supply and good catering. The venue staff were very willing to assist where they could.

20.5.10 Several media teams engaged well with social media. For example, the

Lincolnshire County Council account was very well run with questions and comments responded to quickly, reiterating the importance of strong social media monitoring and capacity management in the face of intense media pressure.

20.5.11 The social media simulator, “Triton” was invaluable in keeping abreast of what

was being said in the media throughout the ‘incident’.

20.5.12 The media teams worked well together, and whilst there were some issues on

day one due to press officers working remotely, a degree of forward planning about how they would manage the media on day two improved their outputs.

20.5.13 Information was readily shared by e-mail and roles for the press conference were

clearly defined in advance. Feedback from journalist’s confirmed they were receiving consistent messaging from all press officers by day two and that responses to journalists were friendly even when pressure was applied.

20.5.14 Press releases and other materials were well written and, after a process of sign-

off, were promptly distributed and coordinated, particularly when shared across social media channels. SOSREP was the only face-to-face and talking head opportunity provided away from the press conference and whilst this worked, more opportunities could be provided. Those opportunities provided were very well managed.

20.5.15 The mock media invaded the media centre twice and both times they were quickly

spotted and politely ejected.

Least Effective

20.5.16 Press officers were very good at sharing their releases on social media, but most organisations did not appear to be actively monitoring or responding to questions directed at them via social media.

20.5.17 Evidence that drones were operating in the area of the incident was

ignored. Facebook users organised “Beach Clean-up Groups” without any response from press teams to discourage such risky behaviour. The social media simulator, “Triton” could easily be replicated in real life using “Hootsuite”, however this would not be possible through MCA laptops due to restrictions.

20.5.18 It is imperative that MCA press officers have full access to social media during

this kind of incident, not having it makes managing the media very difficult. More active monitoring of social media should take place during incidents to ensure that questions are responded to and that any risky or inappropriate behaviour is discouraged.

Recommendation R19: MCA Communications team to be provided with appropriate technology to enable active monitoring of social media.

20.5.19 Coordination between the press teams on day one was insufficient and

contradictory information was received from several sources. Some information was confirmed as accurate although it was incorrect and this incorrect information was added to statements apparently without going through a full approvals process.

20.5.20 MCA press officers and DfT press officers were unable to make international

calls, and this created frustration for our international journalists who were leaving messages with the pager service, but never receiving call backs.

Recommendation R20: MCA press officers must to be able to make international calls from all devices without restrictions.

20.6 MCA Office of the Chairman and Chief Executive (OCCE)

20.6.1 The OCCE is responsible for the overall management of relationships with government and parliament.

Objectives

20.6.2 To provide Ministers and Senior DfT officials with a clear, non-technical brief of the incident in a timely manner;

20.6.3 To keep Ministers and senior DfT officials continuously updated on important

developments and impacts; 20.6.4 To test internal communication flow between the MCA OCCE, the DOD and

SOSREP.

Evaluators Overview

20.6.5 The evaluation of the MCA’s OCCE was conducted from within DfT, by monitoring the flow and content of information compiled jointly by the OCCE, DOD and SOSREP arriving at DfT for further dissemination to relevant DfT departments, officials and the Minister.

Most Effective

20.6.6 Information was received in a timely manner and provided effective briefings to ministers whilst answering any follow-up questions. This was successfully done electronically but in a real incident the process would have benefitted from verbal communications.

Least Effective

20.6.7 Onward communication with the DfT press office could be improved. This may have been more of an issue within DfT rather than an expectation of MCA.

20.6.8 The information exchange between the OCCE and DfT and back again was

predominantly conducted via electronic mediums. 20.6.9 The use of verbal mediums was not evident.

Recommendation R21: Consider development of a communication protocol for exchange/update of time critical information by verbal and electronic means.

20.7 Maritime Resilience Team, Department for Transport

20.7.1 The role is to work with other government departments and the maritime sector

to strengthen resilience to natural and other hazards including cyber-attack.

Objectives

20.7.2 To exercise the Maritime Resilience Team in its response to a major maritime incident, particularly the role expected of it and the support it provides to the MCA and Ministers;

20.7.3 To ensure that the MCA and DfT press offices have an understanding of their

respective roles during the incident; 20.7.4 To familiarise the Minister and his officials with the procedures and stakeholders

during a major maritime incident.

Evaluators Overview

20.7.5 Following the notification of the incident, the Department’s Maritime Resilience Team adopted its established procedures detailed in the Maritime Emergency Response Plan.

20.7.6 These internal procedures ensured there was regular and effective contact during

the initial phases between the team, press officers and the Minister’s office. The team was able to assess the situation, reassure itself that all necessary actions were underway and determine where it was able to be most effective.

20.7.7 The exercise has again highlighted the perennial problem of the notification of an

incident to the DfT by the MCA. There is still a concern that MCA staff have not received adequate guidance on when and how to inform the Department and its Ministers and how to maintain that awareness during the key stages of an incident.

20.7.8 Whilst it is correct that MCA’s primary concerns must be the safety of life and

protection of the environment it should not overlook the importance of keeping Whitehall informed.

Recommendation R22: The OCCE, Press Officers and the DfT Maritime Resilience Team to build personal relationships and engagement so that a better understanding develops about the nature of incidents that should be reported and how best to do that.

20.7.9 DfT must also ensure that its own procedures are regularly exercised and

reviewed.

Most Effective

20.7.10 DfT’s Maritime Resilience Team could resource and manage the incident alongside non-incident related work. The two press teams worked efficiently and effectively together and information was quickly shared and roles and responsibilities were clear. Other press teams were quickly involved and a “rolling awareness” of lines to take was available to all press teams.

20.7.11 The Minister and his team were introduced to the procedures during a major

incident and gained an understanding of the key stakeholders involved and the way in which events are likely to unfold. This lesson was also learned by the Permanent Secretary’s Office. Issues raised by the Minister were quickly addressed.

20.7.12 The Minister for Ports and Shipping actively participated in the exercise, on

completion of which the following statement was made:

“As Minister for Ports and Shipping, I was pleased and privileged to have participated in the largest joint maritime exercise carried out in recent times: EXERCISE GREY SEAL. The updates received were regular and consistent, demonstrating the importance placed in assuring Ministerial concerns during a seafaring emergency. John Hayes MP Minister of State at the Department for Transport

Least Effective

20.7.13 The initial notification of the incident did not come from the MCA DOD or the MCA Chief Executive Officer (CEO) but was received via DfT’s Press Office. Current practice is inconsistent and e-mail notification lists contain personnel no longer in position. Exercise Director Comment: The initial notification of an incident should be via verbal means and not be reliant on an email. Embedded email group accounts/distribution lists can be flawed as personnel can and do change on a regular basis thus rendering them out of date quickly and often. The use of generic email addresses that can be accessed by all duty officers, assigned access to the account, alleviates the requirement to constantly update them.

20.7.14 This contributed to time being lost in standing up the DfT response in the

immediate aftermath of the incident. These lists should be regularly reviewed to take account of staff changes.

20.7.15 The MCA needs to ensure that rapid communication of major incidents to DfT takes place and should include the development of e-mail distribution lists for various scenarios that can be readily utilised to ensure that fast and effective communication takes place between MCA and the DfT.

Recommendation R23: Consider development of e-mail distribution and telephone contact lists for various scenarios that can be readily utilised to ensure that fast and effective communication takes place between MCA and the DfT. A nominated focal point from the MCA and DfT should be appointed to administer the lists and to distribute changes.

20.7.16 The senior team member in the DfT Resilience Team was working remotely and

so was unaware that they should have taken the lead when the alert arrived. There was a delay before the lead responsibility for the event was assumed.

20.7.17 All members of the Resilience Team should immediately ascertain via all means

possible who is available when an incident occurs and ensure that a lead is appointed. They should develop an established procedure for immediately advising senior colleagues, Transport Security Operations Centre (TSOC), press officers and Ministerial teams on notification of an incident.

Recommendation R24: Consider development of a protocol assigning a ‘lead’ during incidents responsible for informing appropriate identified personnel on receipt of an incident.

20.7.18 There was no established timescale for the provision of updates from the MCA

Chief Executive’s office. DfT’s team was occasionally unsighted by the lack of information coming from the MCA.

20.7.19 Whilst there was regular contact between the press teams and the CEO’s office

and although they were able to answer questions posed there was uncertainty about the latest developments.

20.7.20 There should be an agreed procedure between MCA CEO and the DfT Maritime

Resilience Team; important information ought to be immediately notified but an agreed timescale should ensure that at least a “nothing further to report” update is sent to DfT.

Recommendation R25: Develop a procedure for providing regular updates and briefings including ‘nothing further to report’ notifications at an agreed timescale.

20.7.21 Any communications between or by the press teams should automatically be

copied to the MCA CEO’s team and the DfT’s Maritime Resilience Team. The briefings from the MCA did not readily identify new information which meant time was lost trawling through old briefings trying to identify changes to the situation.

Recommendation R26: Agree a method of ensuring the most recent information is displayed in a readily identifiable format when briefings are submitted.

20.7.22 On occasions the MCA briefings introduced terminology that was not fully

explained or associated acronyms not recognised. This leads to a lack of understanding of the information being provided, it should be ensured that abbreviations and acronyms being used are explained and that operational matters can be understood by the policy staff and Ministers who may have to brief across Whitehall.

Recommendation R27: The MCA should consider maintaining a team of staff who are trained in Emergency Planning and briefing Ministers who are capable of deploying to the scene to provide administrative support to the SOSREP.

20.7.23 It should be recognised that if a major incident occurs it is possible that COBR

will be sitting and staff should be aware of Central Government Response Procedures.

20.8 Humber Standing Environment Group

20.8.1 The Environment Group provides a single advisory line on public health and environmental issues at sea to all response cells.

Objectives

20.8.2 To experience dealing with a scenario as realistic as possible for the location and time of year.

20.8.3 To assess our capability to provide robust advice when SEG members work

remotely from one another (e.g. by sharing information by Resilience Direct or Magic system);

20.8.4 To assess our capability to provide advice to response units consistent with

neighbouring standing environment groups.

Evaluators Overview

20.8.5 Overall the Humber SEG worked effectively as a group, with all members fully engaged and providing support to other group members as needed during the response.

20.8.6 The group was effectively chaired during the two day exercise and the use of two

Environment Liaison Officers (ELO’s) in for each response cell was an effective function ensuring the EG could have effective communication within the response groups.

20.8.7 The EG effectively used Resilience Direct in sharing information between the

response groups during the exercise. 20.8.8 The exercise provided a valuable learning opportunity, allowing all those involved

to gain experience of responding to and liaising with a neighbouring SEG’s in a realistic scenario.

20.8.9 The Chair provided a clear opening

briefing ensuring the group was aware of health and safety, welfare and security protocols while operating at ABP Grimsby. Members were encouraged to introduce themselves so everyone was familiar with roles and responsibilities within the group, and were reminded by chair on the requirement to record working hours to enable cost recovery during the post incident phase.

20.8.10 The Chair and Deputy when covering provided effective direction throughout,

ensuring the excellent coordination of tasks.

20.8.11 The EG was kept informed of the current position using the POLREP as an overview and enhancing situational awareness through regular team briefings.

20.8.12 Uploading EG SITREP’s to Resilience Direct allowed ELOs deployed within the

LRF response cells, MRC and SCU to access the information as required, ensuring consistency of EG information across all response cells.

Most Effective

20.8.13 The EG positively considered the potential for cross border impacts on neighbouring SEG areas and further liaison with Norfolk, Suffolk and The Wash SEG allowed both EG’s to determine their response and de-escalation as required. This also facilitated cross organisational support, for instance with Joint Nature Conservation Committee (JNCC) and Natural England (NE) to enable timely information be provided to the response groups.

20.8.14 Status boards were used effectively to track actions and the timings of associated

cell meetings for coordinating information briefings both to and from the ELO’s within the response cells. Good consideration was given by the EG to resourcing, logistics and finance issues as well as longer term resourcing requirements to cover response shifts and the likely need and coordination of mutual aid between the organisations within the EG.

20.8.15 The benefit of having Resilience Direct as a platform for sharing information was

influential, and was commended by the MRC evaluator who had observed the MRC ELO using it to provide accurate and timely EG information to the MRC.

20.8.16 As a result of bringing together the EG cross organisational learning was

achieved by all EG members in the response cell when collocated.

Least Effective

20.8.17 The level of information flow entering the EG was intense, this was due to members receiving a lot of information in their individual email accounts, caused delays in the extraction, quantifying and sharing of the information with the group.

20.8.18 It was soon evident by the group that the pace and outputs required during a

response was intense and for a live incident additional administrative resource would have been required to manage the information flow.

Observation: O02 Environment Group Chairs throughout the UK should consider a review of their current administrative support levels to take into account the additional workload associated with a response to a major incident.

20.8.19 During the exercise various conflicting oil spill modelling was issued by different

organisations, initially leading to various discussions with an agreement by the EG and MRC to use the MCA modelling as the definitive model for preparing advice during the response.

20.8.20 During day two the Pollution Response in Emergencies: Marine Impact

Assessment and Monitoring (PREMIAM) cell challenged the EG about using

incorrect oil map information, which was out of date. This required the EG Chair, JNCC and NE representatives to double check information.

20.8.21 The result confirmed PREMIAM cell oil map information was incorrect and EG

version used was correct as issued. To rectify any doubt the EG Chair found it necessary to inform relevant parties that the EG briefing was in fact correct and should be used to maintain consistency of response.

20.8.22 During the response difficulty was experienced by the EG in obtaining Shoreline

Clean-up Assessment Techniques (SCAT) reports. The distribution of these reports appeared to be problematic and neither the EG or the operator representative was able to receive any of the reports during the exercise.

20.8.23 During the response the EG provided advice and information as required,

however there was no preparedness planning evident during day one for coastal sensitivity mapping assessments in readiness of the potential for SOSREP requiring a review of potential places of refuge.

20.9 Humber Local Resilience Forum

20.9.1 The process of bringing together all the Category 1 and 2 responders within a

police force area for the purpose of facilitating co-operation in fulfilment of their duties under the Civil Contingencies Act.

Objectives

20.9.2 To establish a Strategic Coordinating Group (SCG), Tactical Coordinating Group (TCG), Humber wide Recovery Coordinating Group (RCG) and a Response Coordinating Group (ResCG)

20.9.3 To exercise an appropriate emergency response 20.9.4 To exercise an appropriate pollution response 20.9.5 To exercise an appropriate salvage response 20.9.6 To exercise appropriate information sharing, public warning and informing and

media communication response 20.9.7 To exercise links and liaison between the Humber LRF cells and marine

operations

Evaluators Overview

20.9.8 Notification from the MCA had not been received as expected, so the Duty Officer (prompted by Directing Staff) responded to information seen on “Triton” and made a call to the Coastguard for incident information.

20.9.9 From this point on it all worked well. Plans were triggered accordingly, and

although the likely extent and impact was not known early on, the level of situational awareness was appropriate and in accordance with contingency plans.

20.9.10 Humberside Police had previously stated they would not be involved in the

response to the vessel at sea. In reality the TCG would have been called in response to the media enquiries being generated on “Triton”, leading to the Police becoming involved in the emergency response sooner than planned.

20.9.11 The process for passing the TCG Chair from the Police to a more appropriate

agency worked well. This was discussed between the Police and the MCA prior to the meeting and achieved half way through the first TCG meeting.

20.9.12 It was noted that regional coordination structures, whilst fast tracked for exercise

purposes, would take time to establish. Consideration was given to how effectively some of the more urgent issues and requests could be dealt with during this set up time, for example, identify priority areas for protection.

20.9.13 It was felt that stronger communication links between the national response cells were required to aid communication flow.

Observation: O03 Consider development, or review current protocols, of a generic communications plan to ensure good communications links between relevant response cells.

20.9.14 The clean up and waste disposal strategies were thought to be fit for purpose,

but it was recognised that they would take two full days to complete properly. 20.9.15 It was also identified that the “protection” element of the clean-up strategy was

difficult for LA’s to achieve without national resources. It was felt more consideration could have been given to the financial costs of the clean up before agreeing the initial plan.

20.9.16 Debriefs identified that much of the environmental Information requested by the

MRC and RCG could have been prepared in advance as it was unlikely to change for 10-15 years. An environmental information pack containing baseline data would be useful in providing immediate environmental data where the environment is at risk.

Observation O04: UK LAs/SEGs consider the development of generic environmental information packs that can be readily available for pollution and other incidents where the environment is at risk.

20.9.17 The RCG were keen to accept offers of assistance from spontaneous volunteers,

including Shell, Royal Society for the Protection of Birds (RSPB), Yorkshire Wildlife Trust and Parish Councils to coordinate. However technical staff raised concerns over impact on clean up and safety concerns of the associated risks when working on beaches seeking a pre-agreed approach.

20.9.18 The media activities of the LRF communications cells was limited on day one

because the TCG / SCG felt it was too early to issue warning and informing messages. In a real incident response the LRF communications cell may have stood down on day one and reconvened later.

20.9.19 The Humber LRF had identified a representative to attend the Press Conference,

but the timings changed clashing with a planned RCG, preventing the representative’s attendance. In a real incident everything would have been done to provide representatives wherever they were required, however it was felt the presence of the Humber LRF representative at a press conference predominantly focused on Lincolnshire may need clarity of purpose, function and benefit.

Most Effective

20.9.20 The TCG meeting was well managed, with the Humberside Police Tactical Advisor and broad range of attendees, providing effective support to the Chair.

20.9.21 When the MCA’s pollution modelling map was not received at the first TCG meeting Shell became the definitive source of information on the nature of the oil spill, hazards and the likely beaching locations. Shell would not normally be an invitee to the first TCG meeting because responders would not necessarily be aware that they were the polluter.

20.9.22 However if Shell had not been present then the TCG would not have had

sufficient information to begin to consider the impact of the clean-up operations. This may be realistic in terms of real life response, but obviously the sooner the modelling can be shared the sooner partners can begin detailed preparations.

Exercise Director Comment: A lot of exercise artificiality appears to have had an impact, modelling was available but does not appear to have been provided by the MCA or requested by the LRF.

20.9.23 The co-location of Local Authority Oil Pollution Officers, Environment Agency

(EA), EG ELO, Shell and OSRL at Brough worked very well, with Shell’s and OSRL’s presence considered invaluable as a source of technical expertise.

20.9.24 Local Authority (LO’s) at the EG reported that Resilience Direct had worked well,

citing it is a useful information platform for incident working.

Observation O05: Consider sharing and promoting the values and benefits of utilising Resilience Direct during incident response with other UK SEGs.

20.9.25 Numerous participants remarked on the benefit of having “Triton”. This Social

Media Platform was an incredibly helpful tool in developing exercise realism for all of the players involved and is strongly recommended as something to be used in future exercises.

20.9.26 The media and public relations mass notification system and shared email alert

worked well, and there was appropriate representation and engagement on both days of the exercise. There were press releases and statement prepared and issued in a timely manner. There was effective consultation with responders.

Least Effective

20.9.27 Whilst there was an effective transfer of Chairs at the TCG, observations were made about whether all organisations at the TCG if required to assume the role of Chair were appropriately trained to chair a TCG as opposed to acting as a representative.

Observation O06: Consideration to be given to developing a training and/or familiarisation package to ensure members of staff within organisations likely to provide a ‘chair’ for a TCG are trained to undertake the task.

20.9.28 It was not clear if the TCG was aware of the existence of the Humber EG and did not direct any questions towards the ELO, who was sat at the back in the meeting.

Observation O07: Consider producing TCG member introduction sheets or requesting all personnel introduce themselves and their role at the onset of a TCG meeting to ensure familiarisation with other members of the TCG.

20.9.29 This was exacerbated by Shell highlighting the impact on vulnerable people, but

there was no direct questioning of the EG by TCG or SCG, who instead followed normal arrangements and requested the National Health Service England to consider the need to establish a STAC, without being aware that Public Health England (PHE) input was available through the already established EG.

20.9.30 PHE eventually reverted to liaison with the EG, which culminated in time lost. A

greater TCG / SCG awareness and familiarity with the role, responsibilities and functions of the EG would have saved time and negated the request for a STAC.

Observation O08: Consider the development of a familiarisation session for TCG members on other operational cells and/or organisations that would be expected to be participating in maritime incident response in conjunction with those found in the NCP.

20.9.31 E-mail cascade lists did not work very well which may have been related to the

e-mails being circulated containing large files, e.g. maps and images. Partner Information & Communications Technology teams should be prepared to lift size restrictions on e-mails for those involved in incident response.

20.9.32 The ResCG was not an effective way for the Humber and Lincolnshire LRFs to

communicate and prioritise clean up responses during an oil spill and an alternative solution should be explored. Although exercise play may have affected this aspect, a morning ResCG meeting or an oil pollution specific agenda might improve this.

20.9.33 More strategically it is key that LRF’s and the Department for Communities and

Local Government (DCLG) work closely to resolve this as there is risk of overlap and conflicting messages.

20.9.34 It may have been helpful for both TCG chairs to communicate at regular points

throughout the exercise in order to encourage a ResCG to be organised earlier.

Observation O09: Consider updating current response plans/developing new ones to include how adjacent LRFs are able to effectively communicate during incident response. This may have UK wide implications for other LRFs.

20.10 Lincolnshire Local Resilience Forum

20.10.1 The process of bringing together all the Category 1 and 2 responders within a police force area for the purpose of facilitating co-operation in fulfilment of their duties under the Civil Contingencies Act.

Objectives

20.10.2 To test the co-ordination between national, sub-national and local levels (including cross border liaison between Lincolnshire and Humber) in response to a major coastal pollution incident.

20.10.3 To validate both the Lincolnshire LRF Coastal Pollution Response Plan and the

LRF Site Clearance Plan and to test capabilities around command and control, environmental pollution and waste management.

20.10.4 To test the integration of local communities and volunteer responses to an

environmental emergency.

Strategic Co-ordinating Group

20.10.5 The SCG meeting was well organised. It was mainly an ‘around the table’ meeting with some organisations dialling in, although some telephone discipline would have assisted with background noise etc.

20.10.6 The SCG Chair in particular

demonstrated a thorough understanding of the role, strictly following an agenda, leading structured discussions and the JDM throughout. Clear leadership ensured that a review of membership identified the need for an ELO and the Ministry of Defence appropriate priorities were identified and communicated quickly to the TCG, the appropriate LRF Plans were identified and activated, and a request was made for the ResCG to be established.

20.10.7 Some members were not familiar with the SCG response under the NCP, or remit

of other response cells activated by the NCP and situational awareness at the first meeting appeared limited.

20.10.8 Strategy and objectives were set early into the response and continually reviewed

throughout. 20.10.9 The SCG set a battle rhythm for itself and the TCG but didn’t take the battle

rhythm of other response cells into account, resulting in clashes with other cells meetings.

20.10.10 A STAC was not discussed, so the opportunity to establish how it would link with the EG was missed. Some organisations present did not input into SCG meetings resulting in useful and sometimes important information not being shared.

20.10.11 Warning and informing was a pertinent discussion point, but media related

matters were considered in isolation rather than with the Media Briefing Centre. 20.10.12 The SCG continued to adjust and set strategy and priorities, forecasting the need

to update DCLG later on day two. 20.10.13 Mutual aid requirements was raised within the TCG, but there worst case

scenario horizon scanning for the following day(s) was not evident. 20.10.14 Generally the pace of the exercise presented a challenge to Lincolnshire LRF in

that their positive notional planning was not able to be tested by an impact scenario in the exercise time frame.

Tactical Co-ordinating Group (TCG)

Exercise Director Comment: It should be noted that the TCG was only established and participated on the second day of the exercise.

20.10.15 Both a Command Support Manager and County Emergency Centre Manager

were established at the County Emergency Centre (CEC) in Lincoln. 20.10.16 Only one organisational Technical Advisor (from Lincolnshire County Council -

LCC) was present at the TCG however they were initially mistaken for a TCG member rather than a Technical Advisor.

20.10.17 A comprehensive briefing for the TCG took place however members, would have

benefitted from a more structured briefing format. A TCG briefing agenda would help guide the Chair though key areas of the response whilst prompting the review and assignment of actions.

Observation O10: Consider the use of administrative support during meetings with a specific task to record actions and provide a review at meeting closure thus ensuring actions are captured and assigned appropriately.

20.10.18 It wasn’t evident if the Council Incident Room Briefings had been activated or

which cells were operational which led to clashes with meeting times. It was also not apparent when the MRC, SCU or EG meetings were sitting and with very little output from these meetings received back.

20.10.19 This could have been an exercise artificiality with the TCG only meeting on day

two however it would be good practice for all response cells to maintain a programmed of meetings to support a more structured approach.

Observation O11: When multiple LRF’s are involved in the same incident, consideration should be given to addressing the timings of the various meetings to enable a more streamline and manageable approach.

20.10.20 The cells established seemed appropriate to the incident type, but with some

information flows not being effective it was felt the TCG was probably unsighted on the holistic incident management picture and did not appreciate the magnitude of the likely clear up operation, for example:, over 200 days of tankers removing waste and huge storage implications was not voiced / known until the debrief at the end of the day.

20.10.21 The Logistics Cell Chair reported expenditure to the TCG but it was not clear

whether this was just LA expenditure or all responding Lincolnshire organisations. The TCG should have an overall awareness of expenditure and what organisations it applies to in order that they can escalate any financial concerns and issues to the SCG.

Most Effective

20.10.22 The set up in the CEC was very good in terms of information about which cell was located where, together with the boards which advised who was sitting in each cell and coloured tabards to identify personnel i.e. the Chair, Logistics etc.

20.10.23 The TCG demonstrated good team dynamics and strived to meet and achieve

the strategic objectives as best as they could. Whilst there was no evidence of awareness or setting of an overall aim in the TCG they worked to six strategic objectives set by the SCG very early on.

20.10.24 All of the cell leads attended TCG meetings, with all the relevant key agencies

engaged as standing members around the table, with the TCG Chair attended the beginning of an SCG to provide a brief.

20.10.25 The Police were offering additional staff in the form of “support officer role” in the

Operations Cell, which seemed to be working well. This function would have benefitted the TCG had it been introduced and utilised to maintain a COP and status boards for the TCG.

20.10.26 The TCG discussed staffing resilience in terms of the using volunteers

(staggering their ‘start’ times and days working) and also in terms of their own resilience as a group particularly as a decision was taken to have a skeleton staffed TCG overnight. Welfare arrangements were considered both in terms of appropriate Personal Protective Equipment (PPE) for on-scene activities and also within the staffing resilience discussions.

20.10.27 Organisational and spontaneous volunteers were discussed extensively in terms

of where those turning up at sites should be directed to report to and their potential role in clean-up operations balanced against Hydrogen Sulphide (H2S) PPE requirements. Ultimately, despite earlier advice, the exposure to H2S risk had been diminished by the delay in time and H2S exposure water, whereby normal PPE would suffice as any substance washed up would now be low risk.

20.10.28 The TCG were very much engaged in terms of warning and informing, with a high

degree of awareness of and discussion about public perception and expectations.

Least Effective 20.10.29 Briefings were not focused and where hard copy briefings are produced, Chairs

or their Support Officers should have read them to verify and validate them before circulation.

20.10.30 The TCG Chair must provide a SITREP / brief at the beginning of each meeting

detailing any information received direct to the TCG, especially where it arrives from an SCG. As such there was no checking of and an absence of a COP. Equally there was no use of a Geographic Information System, maps or white / status boards.

20.10.31 Some actions at TCG here were left “hanging in the air” or were unclear and there

was no review of what had been agreed before the close of each meeting. 20.10.32 Before closing the meeting, the TCG Chair should review all task and proposed

or agreed actions from the meeting, determining and confirming who owns them and when an update or completion can be expected.

20.10.33 The TCG lacked representation from the MRC and EG and only ever really had

sight or knowledge of what the response cells at ABP Grimsby were doing or what their roles, responsibilities and capabilities were.

20.10.34 A lack of information and slow flow rate could cause duplication of effort, greater

chance of conflicting information and at worse misunderstanding and miscommunications for those trying to resolve the incident at an operational level. The TCG would have benefitted from having EG and MRC representatives at or dialling into meetings.

20.10.35 Technical advice and information passed to the TCG was lacking and what there

was, was not always understood or it presented conflicting advice or information. The TCG struggled to understand the risk and impacts, which greatly affected their effectiveness.

20.10.36 Any conflicting information needs to be reviewed to bring clarity and accuracy to

enable clear decision making. This requires the right people around the table or dialling in, to progress actions, answer questions and provide clarity of what they are doing, where and how it may impact others.

Observation O12: Develop clear guidance to ensure topics being discussed have the right people available in person or via other medium prior to decisions being made.

20.10.37 During the final TCG meeting the EA advised that they had identified 53 potential

disposal sites in Lincolnshire’s Plan, but these had not been formerly assessed or agreed, and as such considered a major oversight.

20.11 P&O Ferries

20.11.1 P&O Ferries is a British company that operates ferries from the United Kingdom to Ireland and Continental Europe.

Objectives

20.11.2 To test internal and external communications 20.11.3 To test delivery of passenger manifests to internal and external stakeholders 20.11.4 To text working relationships with external partners (SARS – Lloyds stability *

service, Media – New Century Media). 20.11.5 To test stability transfer information from Ship to Shore – NAPA software.

Evaluators Introduction

20.11.6 GREY SEAL was the third exercise P&O participated in during 2016, having conducted the company drill in April 2016 and a National Security Exercise in September 2016. As such P&O involvement was reduced to free management up after the heavy demands of the two previous drills.

20.11.7 The use of the ABP building in Grimsby would be difficult to match and. ABP is

to be congratulated on their involvement and support. 20.11.8 In the early stages of the exercise, active communication came from the vessel

Pride of Hull. On site in Grimsby two Masters attended with the company Designated Person Ashore, while in Dover one Safety Manager represented the company Emergency Management Team (EMT). The P&O Media manager and external communications company were also involved.

20.11.9 The attendance of a Master on leave with knowledge the route and the vessel at

ABP Grimsby, was realistic and provided support and advice to the SCU. 20.11.10 P&O will endeavour to send a management representative as soon as possible

to any National Response involving one of their vessels. However this could take some hours due to the physical distance and P&O being centrally managed from Dover.

20.11.11 The exercise was very complex and the months of planning resulted in a

beneficial exercise. The complex nature of a multi-agency, multi user group exercise should not be underestimated.

Most Effective

20.11.12 Use of a real vessel, in part real time, gave an element of reality and the associated “confusion” that would be experienced in a real situation.

20.11.13 Given the pre-planning distribution of LO’s worked well. In real time this could

take longer. With three P&O staff in Grimsby, including two Masters this was pitched at an appropriate level.

20.11.14 Use of an emergency e-mail address to members of the EMT. Some of these

were being auto filed into the "manifest drop box". The use of an e-mail feed worked very well and allowed the Master to focus on other tasks.

20.11.15 Use of “WhatsApp” to share information with all P&O Fleet Managers was used

for the first time. This was found to be effective in the early stages of the exercise when managers are in many locations and travelling. Photos, maps, text were shared in this way.

Observation O13: Consider the use of applications to effectively share information between internal response personnel and external responders.

Least Effective

20.11.16 Given the complexity of the exercise it was difficult to keep other parties inside P&O’s structure updated given the scale of the drill.

20.11.17 Across the P&O business there are literally hundreds of third party contingency

response plans (ports, local authorities, emergency services and government agencies etc.). Add to this P&O’s operation in a number of European countries, then the number of these plans increases, and awareness is a challenge and managing them difficult however the exercise was useful in increasing P&O’s knowledge of these plans.

20.11.18 Ship owners have a vested interest in the steps taken with their vessel. The

impression given is ship owners hand all control to agencies and step back, but the reality is the Master’s will look to their owners for instructions. The transfer of incident control from owners to government agencies is little understood by Master’s, Owners and others.

Observation O14: Consider a request to government agencies/departments to provide a presentation to Masters and response personnel within P&O on the role and responsibilities of government during a major maritime incident response.

20.11.19 P&O would have gained more from the exercise with greater management

involvement. However the demands of normal operations and repeated exercise commitments meant that pragmatically this resource was not available. This can be termed as “exercise fatigue”.

20.11.20 Although P&O were ready to go, but were not asked for crew and passenger

manifests which are vital in the event of a major incident involving a passenger vessel. P&O (and other shipping companies) have a duty to be able to deliver these manifests to authorities in under 30 minutes.

20.12 Shell6

20.12.1 Shell provides commodity futures trading services for crude oil and related

products. The company also manages a fleet of tankers and chartering vessels.

Objectives

20.12.2 Exercise responding to a Tier 3 ship source spill incident in UK waters. 20.12.3 Practice and strengthen STASCO’s understanding of the UK government’s roles

and expectations for a ship source spill incident and demonstrate Shell’s capacity to successfully manage a Tier 3 shipping incident.

20.12.4 To better understand how the Shell Incident Management System (IMS) can

liaise and work within the UK SOSREP incident management framework. 20.12.5 Exercise the COP with particular attention to remote “read only” access in multiple

locations and to remotely gather and deliver data from field personnel in “real time” for inclusion in the COP.

Evaluators Overview

20.12.6 The initial incident response activation from Shell went well and according to established plans and procedures and pre-identified incident response objectives (people first).

20.12.7 The default Shell incident management procedure, ICS, was utilised by the team

to good effect with an initial incident report being prepared as use as a handover and situation information tool.

20.12.8 Shell’s plans call for an on-site team to be established if required, and escalation

to a larger team utilising their Global Spill Response Network of additional personnel should it be warranted.

20.12.9 This escalation went per plan and involved real time deployment and transport of

the team. Evaluators felt that if this a real incident the process for escalation would have been more effective if supported with checklists to ensure continuity of response was maintaining during transition periods.

Observation O15: Shell to consider development of checklists to assist in maintaining continuity of response during transition periods.

20.12.10 With the on-site team established, the integration of the Shell Incident Command

Post with the agencies commenced and, as would be expected, took a little time to embed and normalise.

20.12.11 This normalisation period extended due to the multi-agency response nature and

the use of different, and not complementary, IMS. The evaluators noted some

6 The evaluation was conducted by a third party contractor appointed by Shell

initial lack of understanding of how the GSRN utilised the other non ICS systems and NCP effectively but this was an initial normalisation process.

20.12.12 The use of the Shell COP across the organisation was noted as most effective to

all groups who utilised it and provided a common element of incident situation management to the integrated response. The evaluators noted a good level of leadership, decision making, communication (external and internal) and incident specific technical skills (oil spill response, casualty response etc.) amongst the Shell ICP responders.

20.12.13 Also of note was the effective technical capability (telecoms, data, internet,

display and welfare) of the on-site ICP set up by Shell to accommodate the on-site team and GRSN. Even though this was set up a little in advance, as it was an exercise, the capability was most effective and robust.

20.12.14 The evaluators noted the comments from players that the experiment was most

valuable and would help them to prepare. Many noted a desire for skills to be further honed and more opportunities afforded to practice in a UK multi-agency response.

Most Effective

20.12.15 The exercise provided the Shell with the opportunity to experience and learn from a national response, participating in the many diverse components and locations required by the UK NCP.

20.12.16 It also enabled the regulators and SOSREP to see first-hand the capability in

resources (Incident Management Plan, COP, equipment, contractors and in depth subject matter knowledge) that Shell can bring to a national incident.

20.12.17 The escalation process from an initial response in London to a full GSRN manned

ICP in a remote location (Grimsby) went well and verified their ability to successfully carry out such a response.

20.12.18 Being able to transmit the COP to all cells and locations in Exercise Grey Seal

was the first widespread test of the Shell COP to locations not controlled by Shell. Shell would be interested in the feedback from others as to the value of this in the final report. Note that Shell offer further familiarity with this system to the UK response agencies.

Least Effective

20.12.19 The NCP does not officially recognise any Shipping Company / Owner in the organisational chart for Shipping Incidents. Major Shipping Companies / Owners have a significant contribution to make, either in support or as lead. As such the operational and emergency response capability that Shell, or other Companies / Owners has available, should be formally recognised as a role and response cell within the NCP Shipping section, with responsibilities and expectations documented.

Recommendation R28: MCA to review the current NCP organisational response cell framework, or develop a new framework diagram, to include the incident source and the links between all responders

20.12.20 Where a capability such as Shell’s is available it is felt that it could be better

utilised by having LO’s from the regulators and authorities within Shell’s ICP. Equally Shell should be represented by its own LO’s at Government response cells. This would improve response coordination.

Recommendation R29: Discuss and develop the use of Liaison Officers, including their roles, within industry and government response cells and update the NCP as/if appropriate.

20.12.21 Shell recognised the importance of liaison and would like to see a role description

in both Government plans and Shell’s own plans. This is of particular relevance to the MRC where the understanding of roles and capability between MRC and Shell staff could have been improved by both parties having improved awareness and familiarity.

20.12.22 Response cells should be unified and co-located to promote coordination. Shell

would recommend further development in this area.

Exercise Director Comment: The government response cells are established in the most appropriate location for shipping incidents within the UK EEZ. Ship owners/managers/insurers etc. are not necessarily based or represented in the UK other than, perhaps, an agent acting on the owner’s behalf if the vessels destination was in the UK. There is scope for co-location however incidents will be assessed on a case by case basis and the location of cells established accordingly.

20.12.23 Whilst the exercise scenario had progressed to Day three in terms of injects and

work streams, essentially were Shell were at Day one in terms of their response, leading to some artificialities. If it were a real event at the Day three point Shell’s organisation would have been settling down and normalising. Future exercise design and planning should recognise this artificiality.

20.12.24 Additionally the exercise required significant scripting at the end of Day one to

enable Day three to work effectively. It was felt that the volume of input required to achieve this was underestimated and future exercise design and planning should recognise and allow additional resource / planning to achieve the level of scripting required.

Exercise Director Comment: Artificiality is part of any exercise, all main players were represented on the planning team and all potential artificialities were recognised. There will always be elements of an exercise that will not necessarily run smoothly however all planning team members were aware of the workload and difficulties associated with projecting an exercise and scripting the ‘missing’ day. Other than the ‘missing’ day no script was involved it was a free flow exercise, the test was for response teams to think and make decisions as if it were a live incident.

20.12.25 Shell were aware of response plans and processes utilised by the SCU, but not

to the same degree for the MRC, TCG and SCG. 20.12.26 The omission, at the planning stage, of the response plans led to some initial

gaps in understanding. A better awareness of these plans in the future would be of value.

Observation O16: Shell to consider arranging familiarisation sessions for response personnel to ensure an understanding of UK National Contingency Plan and response cell organisation.

21. Conclusion

21.1 The National Contingency Plan is a strategic document designed to provide guidance to all UK stakeholders on how the Government responds to incidents of marine pollution from shipping and offshore oil and gas operations. The plan has been tried and tested over many years through incidents and national exercises and has proved to be an effective document.

21.2 Exercise GREY SEAL provided a further opportunity to test and evaluate the plan

under controlled conditions to its full capacity; covering salvage, at sea and shoreline responses, to which the overall aim of the exercise and individual organisation’s objectives were achieved.

21.3 As documented within this report, there have been some valuable and useful

recommendations, observations and notes of good practice with two overall conclusions:

21.4 The NCP is a fit for purpose document, providing a strategic overview on how the UK

manages marine pollution incidents however it should be updated as appropriate with consideration given to the recommendations, observations and notes of good practice from the exercise to enhance the UK’s preparedness and response.

21.5 All stakeholders should ensure continuous familiarisation of this dynamic plan and

conduct training as appropriate. Interfacing documents should be regularly tested and responders regularly exercised to ensure a collaborative and appropriate multi-agency response to marine pollution and / or salvage incidents.

22. ANNEX A – Participating Organisations

The following list identifies the participating organisations and Companies:

ABP Humber Meteorological Office

Adler and Allan MOD Donna Nook

Bahamas Flag State Natural England

Belgium Competent Authority Netherlands Coastguard, Den Helder Braemar Howells

Casualty Wildlife Netherlands Competent Authority Centre for Environment, Fisheries & Aquaculture

Science (CEFAS) Norton Rose

Centrica Renewable Energy Limited Oil Spill Response Limited

Cetacean Stranding's Oostend MRCC

Clarksons Platou P&O Ferries

ConocoPhillips P66 Police

Department for Communities and Local Government Port of Rotterdam

Department for Environment, Food and Rural Affairs PREMIAM

Department for Transport Ministers Public Health England

Environment Agency Reconnaissance Ventures Limited (RVL) European Maritime Safety Agency

Fendercare Marine RNLI Humber

Food Standards Agency RSPCA

Humber Nature Partnership RSPB

Humber VTS Sea Alarm

Hydrographic Office Secretary of State’s Representative (SOSREP) Inshore Fisheries and Conservation Authorities

International Oil Pollution Compensation Fund Shell International Trading Company Limited International Tanker Owners Pollution Federation

Local Authorities: Lincolnshire, Humberside, East Yorkshire, Norfolk

Safe STS

SMIT Salvage

Lloyds Teekay Marine

Marine Accident Investigation Branch The Standard Club

Marine Management Organisation

MARINT

Maritime & Coastguard Agency:

Coastal Resources

Counter Pollution Branch

CGOC Humber

Marine Casualty Officer

Survey & Inspection

NMOC

Receiver of Wreck

SAR Flight

23. ANNEX B – Other participating organisations’ comments

23.0.1 Participating organisations who were not formally evaluated during the exercise, were requested to provide feedback on their experience. Amongst the feedback there was some useful observations which responders may find valuable to consider when planning and responding to incidents.

23.0.2 We have therefore endeavoured to summarise the feedback and highlight areas

of Good/Best practice, Observations and Recommendations.

23.1 Phillips 66 – Tetney Oil Terminal

23.1.1 The exercise was very helpful in raising the profile of the SOSREP and creating discussion at higher levels within Phillips 66 of the problems that such a situation could potentially cause at the Tetney Oil Terminal/Humber Refinery.

23.1.2 The timeline of the exercise was a little confusing and day one seemed to carry

on without crucial decisions having been made regarding the fate of the Witham Shield.

23.1.3 Shell could have been a little more accommodating with the information we

requested from them regarding the tanker prior to the exercise. (This could have caused issues had the Witham Shield been directed to the Tetney Monobuoy as Phillips 66 would have had to verify all sorts of limiting criteria for our operation which we would normally have had to hand).

23.1.4 There were some ‘odd’ requests during the exercise regarding waste oil

reception/processing at Tetney and acceptance of barges at the buoy or at the Immingham Oil Terminal for offloading of waste oil. For various reasons these ideas were unfeasible leading Phillips 66 to the thought that if an incident of this nature occurred for real, representatives from possibly affected installations should be called upon immediately for their in depth knowledge and advice.

23.1.5 This could save valuable time and help steer an incident towards a more

satisfactory and feasible conclusion, a thought probably shared by the representatives from the Immingham Oil Terminal also.

Good Practice GP09: Ensure organisations / installations who have the potential to be affected during an incident are approached as soon as possible to draw upon expertise and knowledge.

23.2 HM Coastguard Coastal Operations

23.2.1 The SCG briefly considered Port Closure (Operation Stack and associated traffic issues) as well as impact to COMAH sites that abstracted water and key sites that supported the UK. However because the SCG only sat once it did not discuss in greater detail the challenges that may have been faced with a port closure and planning required for it as well as the pressures from Central Government, local business, environmental groups with opposing interests.

23.2.2 Due to the Humber SCG following an hour after the Lincs. SCG the MCA

representative had to leave mid meeting. This is a common problem for national agencies like the MCA who cover a large patch and link into several LRF areas.

23.2.4 Communications flow between the various cells did not appear to work well. They

seem to sit as a group throughout and don’t break or come together at set times. Therefore it is extremely difficult to get a brief on what’s happening and feed back into the TCG/SCG.

23.2.5 The Senior Coastal Operations Officers attending TCG’s struggled to get timely

information from the CGOC for input to the TCG and could not get hold of the Duty CPSO when it would have been useful to clarify the situation at the SCG.

23.2.6 There is not a sufficient number of trained coastal representatives in the role of National LO’s. There would be some benefit to conducting an MCA wide training course / session to recruit more LO’s. The NCP does not need to be descriptive but some clarity on how these liaison roles should work would be useful and clearing lines.

Recommendation R30: MCA to identify and train personnel to act as Liaison Officers to the LRF, including contact details, to ensure resilience during incident response.

Recommendation R31: The role of Coastguard Liaison Officers to the LRF’s should be clarified and considered for inclusion in the NCP.

23.2.7 Briefing protocols appear to be unclear as to where the responsibilities lie for

arranging and conducting briefings, i.e. should the TCG or SCG rep be responsible?

23.2.8 Coastal officers should be informed by the CGOC in good time particularly if a

CRT is likely to be required or a TCG/SCG is likely to be formed.

Good Practice GP11: In the event of an SCG or TCG forming, or the potential to form, for a maritime incident the coastal officers should be notified as soon as possible to allow for a pre-brief and mobilisation.

23.2.9 All persons attending any TCG/SCG should be in possession of a full briefing prior to any meetings, e.g. a telephone call confirmed by a copy of SITREP’s, etc.

Recommendation R32: CGOC staff to be provided with a briefing on the role of CG officers within a TCG/SCG during incident response.

23.2.10 POLREPs and SITREPs occasionally missed some addresses. For example,

Lincolnshire County Council were not on the first POLREP address list. 23.2.11 Local partner agencies need to be informed quickly by the CGOC of an incident

that may affect them irrespective of whether a major incident has been declared or not. For instance, the police had been receiving calls from worried members of the public about a ferry collision in the North Sea long before they were advised by the CGOC.

23.2.12 It would be useful for an officer at the CGOC or the NMOC to maintain a running

log of key events / issues that can be regularly passed to LO’s attending external meetings.

Recommendation R33: Consider development of a method of ensuring representatives in a TCG/SCG are regularly provided with the latest up to date information.

23.2.13 The MCA system BOSS is now less useful to those on the coast with numerous

system messages, text in colour that is hard to read, inability to read any associated messages such as SITREPs/POLREPs etc.

23.2.14 It would be beneficial to have an incident logging system that enables response

personnel working, remotely from the operations rooms to input updates and view attachments i.e. POLREPs.

Exercise Directors Comment: There is no scope to change BOSS through

the life of the current incident command system, and no contractual leeway to make any amendments.

23.3 Centrica Renewable Energy – Inner Dowsing Windfarm

23.3.1 Centrica Marine Control called Humber CGOC, informing them that Centrica had

heard there was a collision between two vessels. Humber CGOC instructed that this was the case and that an oil spill had occurred with the potential to impact the windfarm. On receipt of this information Centrica advised them that the turbines would be evacuated as a precaution.

23.3.2 Although content with the internal response Centrica were not wholly satisfied

with the level of information being received from outside agencies. 23.3.3 Communications with all entities proved successful but earlier identification of the

extent, consistency and timing of the slick is needed. 23.3.4 Briggs and Centrica would have been able to make more succinct decisions had

the information from the pollution control team at the MCA been better and aided the clean-up strategy.

23.3.5 An email group for the Incident Management Team (IMT) is needed as this was

a slow motion event where everyone could have been advised and updated earlier.

Observation O17: Consider the development and introduction of a Centrica IMT email group to facilitate good communications

23.3.6 The IMT was a very positive process and worked very well for the following

reasons:

o All available IMT members contributed in the formed team.

o Answers to issues were very quickly answered (even though it was an

exercise).

o The possible scenarios were quickly created and decisions based on the

outcomes made very quickly.

23.4 Marine Management Organisation

23.4.1 Overall the exercise was really valuable, it is definitely the way forward for MMO

in the event of a real incident to have MCT and communications in the same room with a screen tracking media and social media as things develop. We both found it incredibly helpful and feel much better prepared for a real incident response.

23.4.2 MCA social media updates could have been more frequent in terms of the issue

of statements – putting these out would have prevented much of the social media chatter especially regarding the lack of updates from MCA.

Recommendation R34: MCA to consider developing a social media rolling brief.

23.4.3 The Environment Group acted only as a portal to provide updates ‘one way’

without giving the opportunity for individual organisations to feed in and as a result some information was lost.

23.4.4 Accurate information on potential oil loss was slow. If we had known the size of

the two tanks and max capacity they held we could have at least planned for worst case scenario if the total volumes of the two affected tanks were lost.

23.4.5 Mail boxes became congested with many emails attached with documents of big

file sizes. 23.4.6 The use of the media cell, Triton etc. certainly added to the realism. 23.4.7 The MMO were not invited to the first EG meeting and surprised that the lack of

MMO representation was not queried particularly when dispersant options were still in discussion at that point.

23.4.8 Overall it was a positive experience with some key lessons learned and very

useful exercise.

23.5 Royal Society for the Protection of Cruelty to Animals (RSPCA)

23.5.1 The RSPCA submitted a full report following the exercise which contained a

useful insight into their experience of the event. Unfortunately we are unable to include the entire report within this report however we have endeavoured to capture the key points raised.

23.5.2 The RSPCA was supposed / expected to be informed about the emergency by

midday on the 22nd, but no such call was received. It subsequently became apparent that Shell, had contacted OSRL who then took over oiled wildlife operations, but didn’t contact any of the wildlife response teams as would have been expected.

23.5.3 The RSPCA is the response agency named in the NCP for dealing with oiled

wildlife. Previously, the RSPCA’s role had been considered as part of the Environment group, a group of statutory agencies and NGOs whose job is to advise the MCA and others about the environmental impact of the spill. However, as an advisory group, they are not “hands on” and so not that useful for helping RSPCA to direct its operations on the ground. It was suggested that one representative should be placed in the operational cell in Lincoln and another would represent the RSPCA in the EG.

23.5.4 There were two computer programmes available showing the path of the oil,

which was confusing as both models showed different scenarios and it appeared different participants were looking at different models rather than the same one.

23.5.5 Any impact from this incident would have affected at least two of the RSPCA

Inspectorate Groups. There was confusion during the exercise through discussions particularly with the Wildlife Trusts that the presence and trajectory of the oil slick differed in location depending upon which software was being used to track the movement of the oil.

23.5.6 It was unfortunate the RSPCA nor the Wildlife Trusts had individual access to

Resilience Direct despite this again being requested by RSPCA in the Operational Cell on the day it couldn’t be granted.

23.5.7 This lack of access was made significantly worse as emails were received from

the Environment group advising RSPCA to look at the movement of the oil on Resilience Direct assuming everyone did have access. We were able to view some map outputs but in one set the oil was predicted to land on the coast around Skegness and the entrance to the Wash, whilst the other prediction was it would land significantly further north toward Donna Nook and Spurn Point to the north of the Humber Estuary.

Observation O18: Consideration should be given to allowing for ‘additional’ access to Resilience Direct for agencies/organisations involved in incident response.

23.5.8 By mid-morning RSPCA had received no injects from the Environment Group nor

anyone else advising them of any oiled wildlife being affected but continued with RSPCA preparations as it was inevitable these would occur.

23.5.9 In the event of actual or probably wildlife casualties, the responsible organisation

i.e. RSPCA should be updated on the situation and necessary action plan. 23.5.10 Enquiries were made with the OSRL representative in the Operational Cell, who

also advised RSPCA that Sea Alarm (our European Partners) had also been advised the previous day and were enroute.

23.5.11 A request was made as to who had been contacted at Sea Alarm but that

information was not available. In the exercise planning and in reality the RSPCA would contact Sea Alarm and this had been prepared for, however it appeared RSPCA had been bypassed. After a lack of information and it being stressed to RSPCA, Sea Alarm had been notified, I emailed Sea Alarm directly who advised me they had not been informed but were on stand- by for the RSPCA and available to respond.

Exercise Director Comment: This appears to be due to exercise artificiality,

Sea Alarm were contacted regarding the exercise during the planning stages and were welcome participants, contacts and actions should have been as for a live incident.

23.5.12 All volunteers and staff would be registered and then undergo training in line with

the POSOW course ( Preparedness for Oil Polluted Shoreline Clean Up and Oiled Wildlife - a European equivalent of our oiled bird course) delivered by the Wildlife Officers along with Safe System of Work and Risk Assessment awareness. This would have been delivered at the Beach Head Collection Point. No one would have been allowed to work with the RSPCA nor go onto the beach if not registered and trained. All volunteers deployed would have been under the management of the Wildlife Officer and accounted for at all times. Refreshment breaks would be organised and co-ordinated. No work would be conducted after darkness with a view to resting staff and volunteers overnight to recommence at first light

Good Practice GP18: The RSPCA, should ensure that wildlife response plans and preparations are communicated and co-ordinated with the local authorities.

23.5.13 The Major Incident Plan proved very useful and effective in management of the

incident along with the National Oil Spill Contingency Plan. These plans are key to moving forward with these incidents and that the RSPCA accepts the Wildlife Officers are a trained specialist response team to assist local regional management to deal with such incidents wherever they may occur in the country.

23.5.14 As the European Oiled Wildlife Response Assistance Module (EUROWA) project

has come to an end, a training course should be arranged in 2017 for all the Wildlife Officers to cover the Preparedness for Oil-Polluted Shoreline clean-up and oiled Wildlife Interventions Project (POSOW) Course and Advanced Responder course written during this project to assist them in their preparation for these incidents. All Wildlife Officers need to be in a position to deliver the POSOW course to volunteers at an incident. This will ensure the Wildlife Officers are trained to the same standard as our European colleagues.

Observation O19: Consider training courses for Wildlife Officers to cover the POSOW course and Advance Responder course to help build resilience in the UK.

Exercise Director Comment: The RSPCA were represented at the Exercise review and debrief, it was reemphasised there is a need for resilience and of potential to develop a Wildlife Response STOp Note to aid response – O27 refers.

23.6 Food Standards Agency (FSA)

23.6.1 In general there was a lack of information received during the exercise, which led to conflicting messages, which in turn proved difficult for the FSA to provide an accurate risk assessment.

23.6.2 There appears to be some disconnect between cells and the connection with the

SCG and PREMIAM is unclear and baseline data was lacking during the exercise.

Good Practice GP20: Local Authorities in collaboration with key environmental agencies, should ensure they have baseline data to work from to aid response making decisions.

23.6.3 Participants have asked if the FSA should be a core member of the Environment

Group, this would ensure that food was always considered.

Observation O20: Standing Environment Group Chairs to consider whether the FSA should form part of the core SEG membership

23.6.4 Resilience Direct did not provide notification when information was uploaded.

23.7 MCA Beverley Marine Office

23.7.1 Access to Duty Rosters – whilst the HQ Duty Roster would appear to have been circulated to the Duty Surveyor, it would appear not to be circulated for the general info of the Marine Office.

Exercise Director Comment: An Exercise Duty Roster was created of

personnel actively participating in the exercise and issued to those personnel in an attempt to ensure that only those taking part would be contacted. A review of exercise duty rosters will be taken on board.

23.7.2 It was noted that P&O correspondence to the Marine Office included a media

organisation (New Century Media) in cc: This was questioned with P&O but highlights the need for MCA staff to be vigilant when dealing with email traffic, as to who’s in copy and is all the content within the correspondence string appropriate.

Exercise Director Comment: It appears the issue of the address list

compilation rests with P&O not the MCA Press Office. 23.7.3 There was some really good feedback / dialogue with P&O. There was no

dialogue with Shell regarding the tanker but this may be expected depending what’s in their casualty procedure. If the vessel was to move to the Humber for refuge, then there would be an expectation that dialogue in this respect would have increased dramatically.

23.7.4 There was some good response / interaction with the Dutch PSC authority ILenT

regarding the Pride of Hull. 23.7.5 Whilst there was good communications between the duty surveyor and the

Marine Office, this may in part have been due to the fact, the both were in the MO at the time of the exercise.

23.7.6 The MO had good interaction with the MCO during the incident and provided

logistic / local knowledge assistance were required.

23.8 Joint Nature Conservation Committee

23.8.1 One day one, there appeared to be a lack of room discipline with personnel arriving with no formal introductions and no team briefings, leading to contusion and lack of situational awareness. It was felt that a lot of decisions were being made by JNCC and NE rather than as a group – which could be as a result of limited team briefings / structure.

23.8.2 After some discussions at the end of day two it was felt these issues had begun

to be addressed 23.8.3 Albeit a pre-exercise decision, the EG lacked the presence of some key response

agencies / organisations i.e. MMO, Shell and the MCA. This proved how valuable their input would be during a live incident.

Exercise Director Comment: The NCP takes into account the EG and STOp

2/2016 section 3 suggests a minimum core membership which includes the MCA however due to staff absences permanent attendance in the EG was not achievable. As the first day of the exercise was being played in real time Shell acted as they would for real and responded from London initially, mobilising to the EG location overnight to be in place for the second day of the exercise.

23.8.4 It was a bit of a memory game remembering who to include on updates / emails.

The EG would have benefitted from a formal mailing list to ensure key personnel / organisations were included on distribution list.

Observation O21: Standing Environment Groups should consider standard distribution lists for their areas.

23.8.5 It would beneficial if all members/potential members of the EG had access to a

generic mailbox that so that members were able to see all information relating to the incident/exercise. This may also assist with mailbox file size limitations which could possibly be adjusted for incident working.

Observation O22: Standing Environment Groups to consider the potential to establish a generic mailbox that all core members and invited members can access with consideration to mailbox file size limitations.

23.8.6 DEFRA appeared to be unclear on the EG remit and resulted in some duplication

of effort and needs to be addressed.

Observation O23: Discussion should take place between environmental bodies with regard to Defra involvement during incident response and where the responsibilities lie

23.8.7 The EG needed a breakout room for extension calls, teleconferences etc. this will

assist with privacy and ‘break out’ sessions

Exercise Director Comment: Two rooms on the ground floor were identified

specifically for break-out conversations and teleconferences however this information may not have been distributed to or within the EG.

23.8.8 The exercise would have benefitted from being three days long as appose to two.

This would have allowed for more time to be spent on mapping coastal sensitivities and planning for impact.

24. ANNEX C – Exercise Review and Debrief

24.0.1 An exercise review and debrief was held on Thursday 23 March 2017 at the Lincoln Hotel, Lincoln.

24.0.2 The event was attended by the MCA Director of Maritime Operations, the

exercise planning team and 45 representative of 20 different organisations and authorities who actively participated in the exercise.

24.0.3 The aim of the event was to provide an opportunity for exercise participants to

give feedback and comment on how they felt their role in the exercise developed, and if any lessons identified for learning could be taken forward to improve their incident response mechanism. The delegates were also provided with a list of the draft observations and good practice.

24.0.4 Representatives of the key NCP response cells were invited to provide an

overview of the exercise from a responder’s viewpoint highlighting areas that went well and areas that required some improvement.

24.0.5 An open forum was held to allow representatives from other response cells to

provide similar reports. 24.0.6 Feedback from delegates gave a valuable insight into the exercise response from

organisations who were not formally evaluated and individual members who had participated.

24.0.7 The comments provided a basis for some good discussion between the various

delegates, cumulating in the addition of further observations and good practice that otherwise would otherwise have been missed, had a debrief not been convened.

24.0.8 Areas for improvement identified during the debrief event: 24.0.9 The EA suggested that the end of the exercise was reached without the issue of

waste management being tested, an area that is not often exercised.

Observation O24: EA and the MCA to consider development of a table-top exercise, based on GREY SEAL, one month after oil reaches the shore to test all areas surrounding waste management including storage and transportation.

Exercise Director Comment: The testing of waste management issues was

the subject of an observation following the 2014 NCP Offshore Oil and Gas Exercise DRAGON however persons assigned to the exercise development left their respective organisations prior to the exercise being fully developed and executed.

24.0.10 The LRF representatives raised the issue of communications connectivity.

Although IT Wi-Fi systems were considered adequate for normal operations within their respective SCG and TCGs, the system was not able to cope with the large amount of responders attempting to gain access.

24.0.11 The difficulty of accessing Wi-Fi networks was also emphasised by other response agencies. It is considered an area to be developed by individual response agencies and organisations to ensure a robust Wi-Fi infrastructure is in place, sufficient to cope with the multiple usage associated with incident response.

Observation O25: All incident response agencies and organisations to consider reviewing their Wi-Fi status to ensure numerous incident responders are able to gain access to a robust reliable system.

24.0.12 The availability of communication systems to share information between

response agencies, such as Resilience Direct, was discussed. It was agreed that common information sharing mediums would be beneficial to all participating agencies and organisations. This area should form part of all exercise planning team’s agenda to ensure discussions relating to a common communications platform commence early in the development of an exercise.

Observation O26: Communications to be considered as a standing agenda item for all planning teams when developing exercise scenarios.

24.0.13 There did not appear to be a consistent POLREP address list. Organisations were

in receipt of some POLREPs but not others. This may have been attributed to the handover of coordination from CGOC to the NMOC and vice versa during the exercise. It should be ensured that all CGOCs/NMOC are utilising the mandatory POLREP address list appropriate for the incident area.

24.0.14 Humber CGOC SMC stated that shortly after Exercise Grey Seal an incident

occurred for which they were the coordinating authority. The incident was dealt with effectively with staff able to draw on their experience from participation in the exercise.

24.0.15 ABP Grimsby stated they benefitted from playing the exercise as they would for

a real event and were able to effectively prove their systems for the duration of the exercise.

24.0.16 The RSPCA suggested that resilience would be an issue for large scale

protracted incidents and that it may be beneficial to develop a Wildlife Response STOp Note to aid response.

Observation O27: Consider discussion between RSPCA and MCA CP Branch to assess the benefits of developing a Wildlife Response STOp Note.

25. ANNEX D - Summary of Recommendations

25.0.1 The rationale behind the recommendations has been consolidated and should be read in conjunction with the overall report and not in isolation.

25.0.2 HMCG Standards Branch are the custodians of the recommendations and will monitor progress, implementation and closure. 25.0.3 The Assigned Owners are invited to consider the recommendations given below.

No. Recommendation Rationale Assigned Owner

01

Planning Team An exercise email account to be created when the MCA planning team has been assembled to store documentation relating to the exercise providing access to all internal planning team members.

An email account was created for all exercise play related emails, the use of an exercise account would be beneficial to include exercise planning.

Future Exercise Director

02

Planning Team A Deputy or Assistant Exercise Director to be considered for future National Contingency Plan exercise planning team to support the Exercise Director.

There was little resilience for the Exercise Director and during incident response it was noticeable due to lack of information being disseminated at certain stages of planning. It would have been beneficial to have an additional person working closely with the Exercise Director so ensure continued progress of the planning during periods of Exercise Director absence. The assigned person must be a representative of the MCA.

Future Exercise Sponsor

03

CGOC Humber OmS procedures, SMC and JESIP training should be reviewed to ensure they encourage thought processes of engaging with partner organisations at the earliest opportunity.

Post Exercise Note: The MCA’s Major Incident Plan has been revised, and ‘Operation WAYPOINT’ developed, which provides a clear unambiguous route to informing other emergency services and authorities that may be required to put in place arrangements for dealing with a maritime incident that has the potential to move shore side. This revised Plan and Operation Order will become live in the Spring of 2017.

Whilst the nature of maritime incidents quite often precludes the need for other emergency services to become involved, in this case a clear opportunity was missed. It is vitally important that the SMC and command team have the foresight and inclination to predict an impact on the public or environment at large and therefore a need to alert or notify other emergency services or authorities in an appropriate timeframe.

HMCG Maritime Operations Commander

04

CGOC Humber

A review of procedures and protocols to be conducted to ensure cohesion during division of responsibilities and assigning roles during incident response.

On one occasion, there was a lack of division of responsibilities when moving responsibility for coordination of coastguard functions within zones between stations.

The proper use of the Zone Flexing process would have prevented this from occurring. Once the error had been identified, it was quickly rectified.


05

CGOC Humber

Rationalisation of formal reports to be discussed, with due consideration given to timings of submission and possible duplication.

With a various formal reports required to support operational activities, the workload on HMCG and potential to confuse end users is significant in a major incident. It is suggested that a review of formal reports such as SAR SITREP, POLREP, DEFREP and EU SITREP etc. is conducted to determine if the number of formal reports used can be rationalised in any way.


06

NMOC

Coastguard Liaison Officers positioned in response cells to be provided with training on roles and responsibilities to ensure up to date information is disseminated to other operational cells/stations.

HMCG Command decisions focussed on Coastguard operations, with no sharing of information or consideration being given to the SCG’s, TCG’s or with other NCP response cells. This was also the same in reverse, with decisions from the NCP response cells not being fully communicated to Coastguard strategic commanders.


07

NMOC

The SCG should be the main coordinating group for shoreline response to maintain the collective strategic oversight and direction of the incident. This capability should be clearly established within operational doctrine.

As Above


08

NMOC

Consider development and implementation of an updateable and expandable recording format.

An updateable and expandable recording format is required to provide visibility and understanding to all. This also needs to have compatibility with external agency command process, whereby overall shared situational awareness can be facilitated.


09

NMOC

Consider implementing training for support staff to compile OBNs/statements on behalf of the Commander prior to sign-off and distribution.

The Commander’s Operational Briefing Note (OBN) is an important briefing tool used to cascade communications to DfT and Ministers. However the OBN required significant tactical and strategic level resourcing to compile, causing an adverse effect on command activities. Other staff could be provided to collate the information releasing the Commander to concentrate an overall strategic view of the situation.


10

NMOC

Consider convening a discussion to assess the appropriateness of using IIMARCH JESIP template for SITREPs and briefings.

Current Mission Conduct utilises the SMEAC process for briefings. It may be more efficient to utilise the IIMARCH JESIP template (http://www.jesip.org.uk/IIMARCH-template) to organise internal / external operational-tactical-strategic briefings which would suit up, down and across communications.


11 NMOC

Identification of personnel within the MRC to act as Deputies when key members of the team are absent.

Reinforce the need for the Chair to quickly identify priorities and task appropriate MRC members to undertake key roles such as Deputy Chair and assistant Scientific Advisor.


12 MRC

Assess the staffing levels and resilience requirement in the MRC.

There appeared to be a lack of resilience in a number of roles, the MRC team in general would have benefitted from additional administration support.

MCA Head of Counter Pollution and Salvage

13

MRC

Consider development of appropriate formal electronic logging system to incorporate action assignments and decision making

White boards were an adequate medium on this occasion and in the room allocated, the MRC’s record keeping, event logging, document sharing, action updates and incident updates must be made available electronically.


14

MRC

Review the process of “central modelling information”, discussion should be ensured with other relevant parties to discuss any differences with modelling predictions which is critical to responders, advisors and for public assurance.

There were obvious issues with the oil pollution modelling outputs, which were not always in the evaluator’s opinion of the best quality and had to be ignored on at least one occasion, and therefore provided at times little or no confidence when setting out a counter pollution strategy.


15

MRC

Consideration to be given to convening a meeting to clarify the MCA and OSRL roles and responsibilities including the requirement for production of an IAP.

There was tension within the cell between OSRL and the MCA regarding roles and responsibilities. What was lacking was an Incident Action Plan (IAP), which OSRL / Shell would have worked up and shared, for integration with MCA actions. OSRL preparations didn’t correlate with the developing scenario.


16

MRC

Consideration should be given to provision of a room manager for the MRC and a programme of training and development for the role.

The MRC should have a ‘room manager’ (common practice amongst other Cat 1 Responders), and Standing Operating Procedures (SOP) and Action Cards should be developed for key roles.


17

MRC

Consideration be given to a review of the current MRC structure with regard to sub cell structure, activity and responsibilities.

The MRC should convene more structured sub cells: Air Cell, At Sea Response, Modelling and Environmental, Logistics and Cost Recovery, with representatives from relevant contractors.


18 MRC

Consider the development and use of Action Cards for key roles within the MRC membership

Briefing notes or action cards for external contractors and liaison officers participating in the MRC would be a useful aid to improve understanding and expectations and help to improve information flow between cells.


19

MCA Communications:

MCA Communications team to be provided with appropriate technology to enable active monitoring of social media.

It is imperative that MCA press officers have full access to social media during a major incidents, not having it makes managing the media very difficult. More active monitoring of social media should take place during incidents to ensure that questions are responded to and that any risky or inappropriate behaviour is discouraged.

MCA Head of Communications

20

MCA Communications

MCA press officers must to be able to make international calls from all devices without restrictions.

MCA press officers and DfT press officers were unable to make international calls, and this created frustration for our international journalists who were leaving messages with the pager service, but never receiving call backs.


21

OCCE

Consider development of a communication protocol for exchange/update of time critical information by verbal and electronic means.

The information exchange between the OCCE and DfT and back again was predominantly conducted via electronic mediums. The use of verbal mediums was not evident

MCA Head of the Office of the Chairman and Chief Executive

22

DfT

The OCCE, Press Officers and the DfT Maritime Resilience Team to build personal relationships and engagement so that a better understanding develops about the nature of incidents that should be reported and how best to do that.

Whilst it is correct that MCA’s primary concerns must be the safety of life and protection of the environment it should not overlook the importance of keeping Whitehall informed.


23

DfT Consider development of e-mail distribution and telephone contact lists for various scenarios that can be readily utilised to ensure that fast and effective communication takes place between MCA and the DfT.

Consider the application of generic email addresses whereby all duty officers are able to access a single account.

The MCA needs to ensure that rapid communication of major incidents to DfT takes place and should include the development of e-mail distribution lists for various scenarios.

Exercise Director Comment - Embedded email group accounts/distribution lists can be flawed as personnel can change on a regular basis thus rendering them out of date quickly and often. The use of generic email addresses that can be accessed by all duty officers, assigned access to the account, alleviates the requirement to constantly update them

DfT Head of Maritime Resilience

24

DfT

Consider development of a protocol assigning a ‘lead’ during incidents responsible for informing appropriate identified personnel on receipt of an incident

All members of the Resilience Team should immediately ascertain via all means possible who is available when an incident occurs and ensure that a lead is appointed. They should develop an established procedure for immediately advising senior colleagues, Transport Security Operations Centre (TSOC), press officers and Ministerial teams on notification of an incident.


25

DfT

Develop a procedure between MCA and DfT for providing regular updates and briefings at an agreed timescale.

There was no established timescale for the provision of updates from the MCA Chief Executive’s office.

There should be an agreed procedure between MCA OCCE and the DfT Maritime Resilience Team; important information ought to be immediately notified but an agreed timescale should ensure that at least a “nothing further to report” update is sent to DfT.


26

DfT

Agree a method of ensuring the most recent information is displayed in a readily identifiable format when briefings are submitted.

Communications between or by the press teams should automatically be copied to the MCA OCCE’s team and the DfT’s Maritime Resilience Team. The briefings from the MCA did not readily identify new information which meant time was lost trawling through old briefings trying to identify changes to the situation.


27

MCA

The MCA should consider maintaining a team of staff who are trained in Emergency Planning and briefing Ministers who are capable of deploying to the scene to provide administrative support to the SOSREP.

It should be ensured that trained personnel are available to provide briefings and updates, on behalf of the SOSREP. Also that abbreviations and acronyms used are explained so that operational matters can be understood by the policy staff and Ministers who may have to brief across Whitehall.



28

Shell / MCA

MCA to review the current NCP organisational response cell framework, or develop a new framework diagram, to include the incident source and the links between all responders.

Major Shipping Companies / Owners have a significant contribution to make, either in support or as lead. As such the operational and emergency response capability that Shell, or other Companies / Owners has available, should be formally recognised as a role and response cell within the NCP Shipping section, with responsibilities and expectations documented.


29

Shell

Discuss and develop the use of Liaison Officers, including their roles, within industry and government response cells and update the NCP as/if appropriate.

Where a capability such as Shell’s is available it is felt that it could be better utilised by having LO’s from the regulators and authorities within Shell’s ICP. Equally Shell should be represented by its own LO’s at Government response cells. This would improve response coordination


30

Coastal Operations

MCA to identify and train personnel to act as Liaison Officers to the LRF, including contact details, to ensure resilience during incident response.

The coastal officers would not be sufficient in number to take on the MRC/SCU liaison role and feed the TCG/SCG framework unless it was a single county incident.

HMCG Standards Branch

31 Coastal Operations

The role of Coastguard Liaison Officers to the LRF’s should be clarified and included in the NCP.

The NCP does not need to be descriptive but some clarity on how these liaison roles should work would be useful and clearing lines”.

HMCG Standards Branch

32

Coastal Operations

CGOC staff to be provided with a briefing on the role of CG officers within a TCG/SCG during incident response.

The CGOC need to appreciate role of coastal officers attending TCG/SCG and the requirement for a full briefing prior to any meetings, i.e. a telephone call confirmed by a copy of SITREP’s, etc.

HMCG Head of Coastal Operations

33

Coastal Operations

Consider development of a method of ensuring representatives in a TCG/SCG are regularly provided with the latest up to date information.

It would be useful for an officer at the CGOC or officer at the NMOC to maintain a running log of key events/issues that can be regularly passed to Liaison Officers attending external meetings.

HMCG Head of Coastal Operations

34 MMO

MCA to consider developing a social media rolling brief.

MCA social media updates could have been more frequent in terms of the issue of statements – issuing them would have prevented much of the social media chatter especially regarding the lack of updates from MCA.


26. ANNEX E - Observations

26.0.1 During the exercise the evaluation team and exercise participants were welcomed to provide feedback on their experience of the exercise.

26.0.2 Amongst the feedback there was some useful observations which responders may find it beneficial to consider when planning

and responding to incidents. 26.0.3 As mentioned at the beginning of the document the MCA have no jurisdiction to impose recommendations on external authorities

and organisations however we have endeavoured to summarise the feedback and highlight the areas that have been identified by participants and evaluation team members.:

No. Observations Suggested Owner

01 Consideration to review the STOp Notice with regard to the role of LRF/Local Authority liaison officers in the MRC. MCA CP Branch

02 Environment Group Chairs throughout the UK should consider a review of their current administrative support levels to take into account the additional workload associated with a response to a major incident.

SEG Chairs

03 Consider development, or review current protocols, of a generic communications plan to ensure good communications links between relevant response cells. TCG, RG, MRC SMG

04 UK Local Authorities/Standing Environment Groups (SEG) consider the development of generic environmental information packs that can be readily available for pollution and other incidents where the environment is at risk.

UK Local Authorities/SEGs

05 Consider sharing and promoting the values and benefits of utilising Resilience Direct during incident response with other UK SEGs. SEGs/LRF

06 Consideration to be given to developing a training and/or familiarisation package to ensure members of staff within organisations likely to provide a ‘chair’ for a TCG are trained to undertake the task. LRF, LA

07 Consider producing TCG member introduction sheets or requesting all personnel introduce themselves and their role at the onset of a TCG meeting to ensure familiarisation with other members of the TCG. LRF

08 Consider the development of a familiarisation session for TCG members on other operational cells and/or organisations that would be expected to be participating in maritime incident response in conjunction with those found in the NCP

TCG

09 Consider updating current response plans/developing new ones to include how adjacent LRFs are able to effectively communicate during incident response. This may have UK wide implications for other LRFs.

LRF

10 Consider the use of administrative support during meetings with a specific task to record actions and provide a review at meeting closure thus ensuring actions are captured and assigned appropriately. LRF

11 When multiple LRF’s are involved in the same incident, consideration should be given to addressing the timings of the various meetings to enable a more streamline and manageable approach. LRF

12 Develop clear guidance to ensure topics being discussed have the right people available in person or via other media prior to decisions being made. LRF

13 Consider the use of applications to effectively share information between internal response personnel and external responders. P&O

14 Consider a request to government agencies/departments to provide a presentation to Masters and response personnel within P&O on the role and responsibilities of government during a major maritime incident response.

P&O

15 Shell to consider development of checklists to assist in maintaining continuity of response during transition periods. Shell

16 Shell to consider arranging familiarisation sessions for response personnel to ensure an understanding of UK National Contingency Plan and response cell organisation. Shell

17 Consider the development and introduction of a Centrica IMT email group to facilitate good communications Centrica

18 Consideration should be given to allowing for ‘additional’ access to Resilience Direct for agencies/organisations involved in incident response. LRF

19 Consider training courses for Wildlife Officers to cover the POSOW course and Advance Responder course to help build resilience in the UK. RSPCA

20 Standing Environment Group Chairs to consider whether the FSA should form part of the core SEG membership SEG Chairs

21 Standing Environment Groups should consider standard distribution lists for their areas. SEG Chairs

22 Standing Environment Groups to consider the potential to establish a generic mailbox that all core members and invited members can access with consideration to mailbox file size limitations. SEG Chairs

23 Discussion should take place between environmental bodies with regard to Defra involvement during incident response and where the responsibilities lie. DEFRA/SEG

24 Consideration be given to the development of a table-top exercise, based on Grey Seal, one month after oil reaches the shore to test all areas surrounding waste management including storage and transportation.

EA/MCA

25 Incident response agencies and organisations to consider reviewing their Wi-Fi status to ensure numerous incident responders are able to gain access to a robust reliable system.

All

26 Communications to be considered as a standing agenda item for all planning teams when developing exercise scenarios. All

27 Consider discussion to assess the benefits of developing a Wildlife Response STOp Note. RSPCA/MCA

27. ANNEX F - Good Practice

During the exercise the evaluation team and exercise participants were welcomed to provide feedback on their experience of the exercise. Amongst the feedback there was some practices that could be beneficial to specific response agencies/authorities, as identified below, and others that are more generic and can apply to many response agencies and worth considering when dealing with an incident.

No. Good practice

1 All response cells should check technical points that have been recorded for accuracy with relevant specialists prior to distribution

2 All briefings and situation reports should be cleared by a senior members of staff before being submitted ensuring that the terminology being used is supported by clear language.

3 Regular team briefings can only serve to be beneficial to ensure that all response cell members are up to date with the latest information and response actions.

4 Confirmation of accuracy of the most up to date information should take place prior to distribution of documents.

5 All agencies and authorities should assess the potential for incident response cell requirements and prepare accordingly.

6 All cells that do not currently use a formal agenda should consider developing an agenda that focuses on key areas of response, proposals/future plans and associated risks.

7 The use of liaison officers cannot be over emphasised to provide and share information to parent organisations. It should be ensured that sufficient staff are available to provide that function and are trained accordingly.

8 Responding agencies should consider the use of ‘applications’ to effectively share information between internal response personnel and external responders.

9 Ensure organisations / installations who have the potential to be affected during an incident are approached as soon as possible to draw upon expertise and knowledge.

10 Establishing communication and briefing protocols early in an incident will help with communication flow.

11 In the event of an SCG or TCG forming, or the potential to form, for a maritime incident the coastal officers should be notified as soon as possible to allow for a pre-brief and mobilisation.

12 Review of protocols for cascading of information to local partner organisations and authorities should be conducted and documentation to be updated appropriately.

13 All response cells/stations should ensure address/distribution lists for statements, briefings, updates etc. include all relevant organisations and authorities involved, or have the potential to be involved, during maritime incidents.

14 All response groups / cells should ensure they provide updates not only to their respective groups but also outside partner organisations involved in the response.

15 Organisations should consider the file size of documents such as pictures and maps prior to distributing to partner organisations and reduce the size if/whenever possible to ensure delivery.

16 Environment Group Chair(s) should assess which liaison officers, other than the core group, may be required to attend meetings, whether virtually or in person and issue an invitation based on the assessment to assist in developing an action plan.

17 Organisations and authorities should consider creating a generic inbox address for incident working that enables them to receive large documents and files.

18 The RSPCA, should ensure that wildlife response plans and preparations are communicated and co-ordinated with the local authorities.

19 Establishing good communication links at the onset of an incident is paramount to ensuring a good information flow.

20 Local Authorities in collaboration with key environmental agencies, should ensure they have baseline data to work from to aid response making decisions.

28. ANNEX G - Glossary of Terms

Title Abbreviation Description/Definition

Associated British Ports ABP ABP is a UK port operator, with a network of 21 ports across England, Scotland and Wales.

Action Coordinating Authority ACA The action station (NMOC/CGOC) with formal responsibility for coordination of the response to a maritime, coastal or where designated inland emergency or incident.

Air Operations AIROP’s The collective for Coastguards operating in the national network coordinating aeronautical and maritime search and rescue services.

Air Rescue Coordination Centre ARCC

The UK ARCC (a Coastguard Operation) provides aeronautical and maritime search and rescue services, supporting emergency services by tasking and coordinating SAR aviation assets in order to locate and retrieve persons in distress, potential distress or missing, provide for their medical or other needs and deliver them to a place of safety.

Civil Aviation Publication CAP 999 Helicopter Search and Rescue in the UK National Approval Guidance. Published to assist organisations in determining procedures and operations manual guidance to operate civil search and rescue helicopters in the UK.

Department for Business, Energy & Industrial Strategy

BEIS Ministerial department, supported by 47 agencies and public bodies bringing together responsibilities for business, industrial strategy, science, innovation, energy, and climate change.

Command, Control, Coordination and Communication

C4 The 4 key elements of the response structure and tasks associated with a response to an emergency or major incident.

Coastguard Liaison Officer CGLO A Coastguard officer deployed to the scene of an incident to establish a forward control point and / or to act as a co-ordination / communications link.

Coastguard Operations Centre CGOC

Strategically located operations centre, staffed by Coastguard as part of a UK-wide network of centres, monitoring the regional picture, adjusting to flexible work distribution controlled by the NMOC, coordination and communication functions for offshore or coastal emergency response.

Control of Major Accident Hazards (Regulations 2015)

COMAH Regulations applying to the chemical industry and to some storage sites where threshold quantities of dangerous substances, as identified in the Regulations, are kept or used.

Commander Commander

A Coastguard officer with strategic accountability for the integrity and discharge of HMCG maritime operations within the UK area of interest including the international arena and strategic command control and management of the HMCG national maritime operations network, considering the risks presented to UK interests and citizens in the marine and littoral areas.

Connect Call Connect Call A Coastguard communication practice that links VHF marine band radio and landline telephone callers through the ICCS system

Controller Controller

A Coastguard officer with tactical management oversight and responsible for the quality of Coastguard operations, in either the functionally within the UK area of interest or within defined sub area(s) of the national or international area of operation.

Common Operating Picture COP

A single display of information collected from and shared by more than one agency or organisation that contributes to a common understanding of a situation and its associated hazards and risks along with the position of resources and other overlays of information that support individual and collective decision making.

Common Recognised Information Picture

CRIP A single, authoritative strategic overview of an emergency or crisis that is developed according to a standard template and is intended for briefing and decision-support purposes.

Coastguard Rescue Officers CRO An individual Coastguard officer of volunteer status.

Coastguard Rescue Service CRS The voluntary arm of HMCG, circa 340 Coastguard Rescue Teams (CRT’s) made up of 5-12 Coastguard Rescue Officers (CRO’s)

Coastguard Rescue Team CRT Collective of CRO’s forming the team.

Command Support Manager CSM Leads the command centre support team.

Department for Communities and Local Government

DCLG Government Department that gives more power to local people to shape what happens in their area, e.g. emergency prevention, protection and resilience.

Duty Counter Pollution Salvage Officer

DCPSO A MCA officer during a period of duty responsible for technical and operational response to pollution and / or salvage incidents.

Defect Report DEFREP A report of a defect(s) to shipping made by HMCG through ViSION, to advise the DCPSO and others of an observed or reported accident or incident, which is not already the subject of a SAR SITREP.

Designated Person Ashore DPA Provides a link between the Company and those on board a ship, and has direct access to the highest level of Management.

Department for Transport DfT A UK Government Department responsible for transport.

Duty Operations Director DOD A MCA Officer responsible for the continuous on call support to the national maritime operations, CPSO and SOSREP during incidents, often being the MCA spokesperson utilised to brief Agency, Department and Ministers as appropriate.

Duty Press Officer DPO A MCA officer during a period of duty responsible managing media and public interest in maritime incidents being managed by the MCA.

Directing Staff DS Directing Staff (Exercise Directors) play a role in all types of exercises and report to the Exercise Controller. They have access to the whole exercise programme and ensure that it proceeds according to plan.

Group 1 Talk Group A Coastguard open command (communicating) line facilitated by ICCS that allows Commanders and their teams around the UK network to formally address operational matters.

Environmental Liaison Officer ELO Environmental liaison officer allocated to other response cells to provide a communication link for information sharing in and out of the EG.

European Union Situation Report EU SITREP

Used by EU member states to exchange reports in order to enhance the safety and efficiency of maritime traffic, improve the response of authorities to incidents, accidents or potentially dangerous situations at sea, include search and rescue and contribute to better prevention and detection of pollution by ships.

Facilities Manager FM Senior organiser, making sure that a place of work meets the needs of those using it or by managing all of the required services.

Geographic Information System GIS Computer based system that supports the capture, management, analysis and modelling of geographically referenced data.

Global Response Network GRN Forum to share information, improve spill response performance and provide centres of expertise in spill preparedness, response and recovery techniques.

Hydrogen Sulphide H2S Colourless gas with the characteristic foul odour of rotten eggs. It is very poisonous, corrosive, and flammable.

Humber Emergency Planning Service

HEPS

A team to ensure that the four unitary authorities meet their emergency planning responsibilities and have emergency management and business continuity arrangements in place to respond to any major incident in a swift and co-ordinated manner.

Her Majesty’s Coastguard HMCG The search and rescue division of the MCA.

Hootsuite A platform for managing social media. The system’s user interface takes the form of a dashboard, and supports social network integrations for Twitter, Facebook, Instagram, LinkedIn, Google+, YouTube, and many more.

Integrated Coastguard Communications System

ICCS

A platform that provides fully integrated touch panel control of all voice communication links coming into the CGOC / NMOC, in particular voice lines, radio circuits and signalling. There are additional functions such as recording devices, whilst telephone and radio communications can be linked through a connect call facility.

Incident Command System (Shell)

ICS

Incident management concept designed specifically to allow responders to adopt an integrated organisational structure equal to the complexity and demands of any single incident or multiple incidents without being hindered by jurisdictional boundaries.

Information Communication Technology

ICT Technologies that provide access to information through telecommunications.

IIMARCH Briefing Information, Intention, Method, Administration, Risk Assessment, Communication and Human rights compliance.

Information Management System IMS A platform that supports the management of incidents.

Incident Management Team IMT Shipping company team managing an incident.

Joint Communications Centre JCC A physical or virtual operation where staff representing all agencies involved in incident management activities coordinate and disseminate official, timely, accurate, easy to understand, and consistent information to the public.

Joint Decision Model JDM Joint emergency services model specified by JESIP as consistent method for Commanders to help bring together the available information, reconcile objectives and make effective decisions.

Joint Emergency Services Interoperability Programme

JESIP A programme aiming to improve the way in which the blue light services work together at major and complex incidents.

Joint Nature Conservation Committee

JNCC A public body that advises the UK Government and devolved administrations on UK-wide and international nature conservation.

Local Authority LA An administrative body in local Government

Lincolnshire County Council LCC A council authority that governs the non-metropolitan county of Lincolnshire in England.

Lexicon Glossary of terms.

Liaison Officer LO Liaison officer allocated to response cells to provide a communication link for information sharing in and out of the cell.

Lloyd’s Open Forum LOF Provides a regime for determining the amount of remuneration to be awarded to Salvors for their services in saving property at sea and minimising or preventing damage to the environment

Local Resilience Forum LRF A forum formed in a police area of the United Kingdom by key emergency responders and specific supporting agencies. It is a requirement of the Civil Contingencies Act 2004.

MAGIC MAGIC Multi-Agency Joint Incident Command programme. 3 day multi agency training course for Strategic (Gold) Commanders.

Maritime Operations MAROP’s The collective for Coastguards operating in the national network as coordinators of maritime safety and SAR operations.

Maritime & Coastguard Agency MCA An Agency of the Department of Transport.

Marine Casualty Officer MCO A MCA officer acting as SOSREP’s representative aboard the casualty vessel.

METHANE METHANE

Joint Emergency Services major incident reporting methodology specified by JESIP as consistent method of sharing incident information; Major emergency. Exact location. Type of incident. Hazards Access. Number of casualties. Emergency services.

Major Incident Plan MIP A plan for one or more types of emergency that requires the implementation of special arrangements by one or more of the emergency services ,and generally includes the involvement, either directly or indirectly of large numbers of people.

Mission An operation carried out by HMCG, which involves information gathering, development of a plan, a statement of intent, promulgation of instructions, associated record keeping and a post mission review.

Mission Logging Protocols MLP’s Action plans designed to guide Coastguard coordinators through a process or response, these will vary by incident type and are visible in ViSION.

Maritime Operations Officer MOO

A Coastguard officer responsible for carrying out the activities required to mount an effective, efficient and prompt response to incidents relating to the Coastguard missions, gathering and analysing information to inform the operational plan and enable delivery, and provision of safety information to prevent accidents.

Maritime & Coastguard Agency-Net

M-Net The MCA’s intranet accessible only by the Agency’s staff.

Marine Response Centre MRC A coordination centre established by the MCA in major maritime pollution cases requiring a national response. It may be co-located at a suitably equipped CGOC or port that supports the at sea response to a pollution and / or salvage operation.

Naval Architect Package NAPA On board ship software is designed for on board loading calculations, ship stability analysis, and emergency response.

Natural Resources Wales NRW A Welsh Government Sponsored Body providing advice and regulation to industry and the wider public and voluntary sector relating to the environment and its natural resources.

National Contingency Plan NCP A plan that ensures a timely, measured and effective response to Marine Pollution from Shipping and Offshore Installations incidents.

Natural England NE Government’s advisor for the natural environment in England, helping to protect England’s nature and landscapes for people to enjoy and for the services they provide.

National Maritime Operations Centre

NMOC

The main operations centre, staffed by Coastguard, located at Fareham in Hampshire. The NMOC sits at the hub of UK-wide network of operations centres, monitoring the national picture, adjusting work distribution throughout the network, and providing command, control, coordination and communication functions for offshore or coastal emergency response.

Office of the Chief Executive OCE The senior management branch in an organisation.

Operational Control Unit OCU

Established by the SOSREP during an offshore related incident to monitor the offshore operator’s response actions taken and / or proposed relating to containment activity and to ensure that such actions do not have an adverse effect on safety and the environment.

Offshore Renewable Energy Installations

OREI

Includes offshore wind farms, marine current turbines, wave generators and any other installation, with the potential to affect marine navigation and safety, proposed for United Kingdom (UK) internal waters, territorial sea or in a Renewable Energy Zone (REZ) beyond the territorial sea.

Operational management System OmS The authoritative source of reference and guidance for use by all operational Coastguard officers, including policy, operational procedures, operational detail and references.

Operational Standards Action Plan

OSAP HMCG depository of actions arising from OSPR’s and other sources recommending operational learning and improvements. Allows the monitoring of actions, action plans, action status through to evidencing completion.

Operational Standards Performance Review

OSPR HMCG internal process for measuring the quality, consistency and effectiveness of operational service delivery by HM Coastguard.

Oil Spill Response Limited OSRL Industry-funded cooperative which exists to respond to oil spills wherever in the world they may occur, by providing preparedness, response and intervention services.

Petrofac Petrofac Training Services provides competence consultancy, training and assurance services to the oil & gas industry and beyond.

Plan Additive The MCA plan for the augmentation of staff in an operational response, most likely an extended major incident or business continuity matter.

Public Health England PHE Executive Agency of Government that exists to protect and improve the nation's health and wellbeing, and reduce health inequalities.

Peninsular & Orient P&O P&O began life as “The Peninsular Steam Navigation Company”. In 1840 “Oriental” was added to reflect the company’s expanding services eastwards beyond the Iberian Peninsula to Egypt and the Orient.

Place of Refuge PoR

Where a ship in need of assistance can take action to enable it to stabilise its condition and reduce the hazards to navigation, and to protect human life and the environment. It may include a port, a place of shelter near the coast, an inlet, a lee shore, a cove, a fjord or a bay or any part of the coast. Because of the many variable factors involved, and the variety of risks, a decision to grant access to a place of refuge can only be taken on a case-by-case basis.

Pollution Report POLREP A report of any known or potential pollution made by CGOC’s / NMOC on receipt of a notification of pollution to ensure accurate and timely dissemination of information to relevant internal MCA and national authorities and organisations.

PREMIAM Programme bringing together 22 Government departments and agencies from across the UK with an interest in marine spill response and the protection of the marine environment.

Post Exercise Report PXR

The Exercise Controllers final report covering the aim, objectives, scenario, planning process and both positive and negative observations from the exercise concluding in recommendations for the future. It is also important that the recommendations are acted upon and a follow up report prepared no later than 6 months after the publication of the PXR noting what action has been taken and what is planned.

Recovery Coordinating Group RCG Strategic decision making body for the recovery phase once handover has taken place from the Police.

Resilience Direct RD

Resilience Direct is an online private ‘network’ which enables civil protection practitioners to work together – across geographical and organisational boundaries – during the preparation, response and recovery phases of an event or emergency.

Response Coordinating Group ResCG

Convened where the local response has been or may be overwhelmed and wider support is required, or where an emergency affects a number of neighbouring SCG’s and would benefit from coordination, e.g. to obtain a consistent, structured approach or enhanced support.

Surveyor Advice Note SAN A formal process for informing MCA Surveyors of work related advice.

Search and Rescue SAR The search for and provision of aid to people who are in distress or imminent danger.

SAR Tote SAR Tote

A Coastguard controlled process of accounting for all those onboard casualty ships or survival craft, whether they be crew, passengers or emergency services, embarking, embarked or disembarked to ensure a single account is kept and maintained of the number of people involved in an incident This will include figures for unharmed, injured, deceased and missing people.

Search and Rescue Situation Report

SAR SITREP A formal report issued by Coastguard to brief individuals and organisations of the current state and potential development of a SAR incident and the response to it.

Shoreline Cleanup and Assessment Technique

SCAT A systematic method for surveying an affected shoreline after an oil spill.

Sharepoint Sharepoint A web-based application that integrates with Microsoft Office primarily as a highly configurable document management and storage system.

Situation, Mission, Execution, Any Questions and Confirmation

SMEAC

A method by which a mission statement is comprised at the start of an incident to describe to those involved what has happened, is happening, what the mission is (Who, What, Where, When), how the mission will be executed, who is going to do what, any questions and confirmation. Mission statements evolve with the incident.

Shoreline Management Group SMG The Shoreline Management Group is responsible for over-seeing the shoreline clean-up response to the whole incident and is the primary point of interface with the EG. The group is made up of the chairs of the functional sub-groups.

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Strategic Coordinating Group SCG

A multi-agency group of strategic commanders that takes overall responsibility for the multi-agency management of the emergency and to establish the policy and strategic framework within which lower tier command and coordinating groups will work.

Salvage Control Unit SCU A unit established to support SOSREP during shipping and marine salvage incidents.

Standing Environment Group SEG

Responsible for a particular area of coastline, providing information and advice to SOSREP and the MRC for; conservation, fisheries, human health, best environmental practice to dispose of wrecked ships and spoilt cargo, how to deal with oiled wildlife and environmental monitoring.

Specific, Measurable, Achievable, Realistic and Time-bound

SMART SMART objectives help to prioritise work, monitor progress and celebrate people’s achievements.

Search Mission Coordinator SMC The Coastguard assigned to co-ordinate the response to an actual or apparent maritime distress situation, this function exists only for the duration of a specific SAR incident.

Subject matter expert SME An individual with a deep understanding of a particular process, function, technology, machine, material or type of equipment.

Secretary of States Representative for Maritime Salvage and Intervention

SOSREP

The Secretary of State for Transports representative with powers to intervene in major maritime emergencies by directing Masters, Owners, Operators and Harbours to take specific actions that preserve the safety of life and protection of the UK environment.

Shared Situational Awareness SSA The degree to which team members possess the same situational awareness on SSA requirements”.

Site of Special Scientific Interest SSSI A conservation designation denoting a protected area in the United Kingdom.

Scientific Technical Advisory Committee

STAC

Group of technical experts from those agencies involved in an emergency response that may provide scientific and technical advice to the SCG chair or single service Strategic (Gold) Commander.

Tactical Advisor TA / TacAd A specifically trained advisor who can guide on specialist capabilities including the implications and tactical options to help commanders make decisions when dealing with incidents and emergencies.

Tactical Coordinating Group TCG A multi-agency group of tactical commanders that meets to determine, coordinate and deliver the tactical response to an emergency. Note: the TCG may also be known as the Silver Group.

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Transport Security Operations Centre

TSOC Operations centre staffed by DfT, monitoring the national picture, responding to incidents / emergencies involving transportation modes throughout the UK and wider UK interests worldwide.

ViSION ViSION The Coastguard IMS that provides a single presentation of incident management information, including event log, resources, mapping, action plans and general information.

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Zone Zone

The concept of Coastguard operations requires the UK to be divided into manageable areas of operational responsibility. There are currently 36 geographic areas allowing HMCG to provide support and / or take operational control of resources and incidents within those zones.

29. ANNEX H – UK Search and Rescue Region Zones

The UKSRR Zone Map

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