The end of owner maintenance ...

Just a remind that there is only 36 hours left to email your views. Closes Midday 18th July 19 and after that they will publish their guidance.
 
anoccasionalyachtsman said:
OK folks, more emails needed. Our Commodore sent me this today. They've broken the Government's own rules. Among other things, 12 weeks is the suggested minimum consultation period.

https://assets.publishing.service.g...ads/attachment_data/file/100807/file47158.pdf

Please, if you've already written, write again.
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Actually, they haven't 'cos that document is out of date. They have followed the latest Cabinet Office guidelines as explicitly stated in the introduction document (the 2016 guidelines do not state a minimum consultation period)
 
Bru said:
Actually, they haven't 'cos that document is out of date. They have followed the latest Cabinet Office guidelines as explicitly stated in the introduction document (the 2016 guidelines do not state a minimum consultation period)
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Good spot, thanks.

The 2016 guidelines contain the following points:-

D. Consultations are only part of a process of engagementConsider whether informal iterative consultation is appropriate, using newdigital tools and open, collaborative approaches. Consultation is not justabout formal documents and responses. It is an on-going process.

E. Consultations should last for a proportionate amount of timeJudge the length of the consultation on the basis of legal advice and takinginto account the nature and impact of the proposal. Consulting for too longwill unnecessarily delay policy development. Consulting too quickly will notgive enough time for consideration and will reduce the quality of responses.

F. Consultations should be targetedConsider the full range of people, business and voluntary bodies affected bythe policy, and whether representative groups exist. Consider targetingspecific groups if appropriate. Ensure they are aware of the consultation andcan access it. Consider how to tailor consultation to the needs andpreferences of particular groups, such as older people, younger people orpeople with disabilities that may not respond to traditional consultationmethods.

G. Consultations should take account of the groups being consultedConsult stakeholders in a way that suits them. Charities may need more timeto respond than businesses, for example. When the consultation spans all orpart of a holiday period, consider how this may affect consultation and takeappropriate mitigating action.



Most of which has been ignored.
 
I just got this today

Dear Mr Tomahawk,

Thanks for your email and for taking the time to provide feedback on the consultation MGNs. Apologies for the delay.

Firstly I would like to stress that the MGN’s are non-mandatory guidance that the owner of a pleasure vessel does not need to follow and they do not prevent an owner from carrying out maintenance on their own vessel. We have agreed to make this statement clear in the summary box of each MGN.

In addition to this, to address previous comments we have received, we are looking to tone down section 2.5 to be re-phrased to, “Unless specifically trained, experienced and/or qualified to do so…”.

The specific text of carrying out maintenance and using a marine professional is written with the wide number of pleasure vessel owners in mind who have a diverse range of experiences and competencies. We have not tried to differentiate between the two ends of this spectrum of knowledge but instead have given generic guidance – as an owner if you think this does not apply to you for a certain element of maintenance then you are able to apply your own safety standards.

With regards to the timescales for consultation, we have carried out a significant stakeholder engagement exercise in the lead up to the MGNs where representative bodies such as the RYA and the Cruising Association were consulted upon in the drafting stages. At no point did any stakeholder raise any objection to the text or the MGNs and therefore we went to a reduced consultation period which is normal in these circumstances and is appropriate given the non-regulatory nature of the MGNs.
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So it seems that the RYA is at odds with boaters who are not RYA members. I am not surprised as the RYA sells training courses and stands to benefit from a more regulated environment.

However the changes to text to specifically say leisure boat owners do not need to follow the MGN and the change to paragraph 2.5 is welcomed. .. at least by me
 
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'tis all a "bugger's muddle" if you ask me (which you probably didn't ;)).
I totally distrust the MCA's protestations of these Guidance Notes not being mandatory for owner operators - unless operator is significant in that it implies an owner operating a boat for some sort of gain or reward; as opposed to the likes of me who just sails my craft for my own and non-paying guests' pleasure.

In my submission I stated most emphatically that I regard the whole process the thin end of a wedge and that onerous (prohibitive?) restrictions will apply at some time in the future (short or longer term).
The response I received from the MCA was wishy-washy at best and did not address the many points I raised.

What do we do now? Especially as the RYA appear to be accepting/agreeing with the proposals?
 
Tomahawk said:
I just got this today



So it seems that the RYA is at odds with boaters who are not RYA members. I am not surprised as the RYA sells training courses and stands to benefit from a more regulated environment.

However the changes to text to specifically say leisure boat owners do not need to follow the MGN and the change to paragraph 2.5 is welcomed. .. at least by me
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Not sure how you reach that conclusion about the RYA, the position expressed on their website:-
https://www.rya.org.uk/knowledge-ad...nsultationonyachtandpowerboatsafetyatsea.aspx

shows concerns about the MGN's similar to many expressed here, and encourages members and "supporters" to make their own responses to add their voices. Not much sign of supporting a more regulated environment.

The MCA suggest that they contacted the RYA and CA prior to the consultation, but I have not seen any of the dialogue they state took place.
 
rgarside said:
Not sure how you reach that conclusion about the RYA, the position expressed on their website:-
https://www.rya.org.uk/knowledge-ad...nsultationonyachtandpowerboatsafetyatsea.aspx

shows concerns about the MGN's similar to many expressed here, and encourages members and "supporters" to make their own responses to add their voices. Not much sign of supporting a more regulated environment.

The MCA suggest that they contacted the RYA and CA prior to the consultation, but I have not seen any of the dialogue they state took place.
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Giving their reason for the short consultation period, it's intriguing that in their standard letter sent to those of us who have responded to the consultation, the MCA say. "At no point did any stakeholder raise any objection to the text or MGNs......."

At this late stage, the RYA is showing some concern. Were they asleep before?
 
NormanS said:
Giving their reason for the short consultation period, it's intriguing that in their standard letter sent to those of us who have responded to the consultation, the MCA say. "At no point did any stakeholder raise any objection to the text or MGNs......."

At this late stage, the RYA is showing some concern. Were they asleep before?
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The fact that the MCA appears to have contacted just the RYA and Crusing Association says it all really....

The world works in a different way now and when I emailed the MCA I suggested that they should have posted a direct thread on this forum which must surely be the largest one in the UK with many thousands of (mostly) knowledgeable owner drivers.

As to what can be done once the "regulations" have been published I think a (crowd funded) legal challenge may make them sit up and listen if the regulations are not significantly altered.

As owners we need to front up to unnecessary regulation or suffer the consequences in the years to come....
 
rgarside said:
Not sure how you reach that conclusion about the RYA, the position expressed on their website:-
https://www.rya.org.uk/knowledge-ad...nsultationonyachtandpowerboatsafetyatsea.aspx

shows concerns about the MGN's similar to many expressed here, and encourages members and "supporters" to make their own responses to add their voices. Not much sign of supporting a more regulated environment.

The MCA suggest that they contacted the RYA and CA prior to the consultation, but I have not seen any of the dialogue they state took place.
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Curiouser and curiouser... something does not add up given the MCA say. "..... At no point did any stakeholder raise any objection to the text or the MGNs" ..... Someone is not telling the truth.
 
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