fisherman
Well-Known Member
Yes, MCA wanting improvements to old Thames boats, impossible to carry out. Oh, but the Marchioness....well if any ‘improved’ boat was run down by the Bow Belle it would still sink.
The end of owner maintenance ...
- Thread starter rszemeti
- Start date
Kurrawong_Kid
Well-Known Member
I think there is some duplicity here. When this post first appeared I contacted the CA and alerted their appropriate Committee Chairman who thanked me, then contacted other members of the group and who I believe have sent a response. I got the impression it was the first they had heard about the consultation! My guess is that the MCA is now saying they consulted the CA because they have had a response. No knowledge of the RYA situation.
Tomahawk
Well-Known Member
This is from the email I got from the MCA:-
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.
Can I suggest that you contact your colleagues in the CA and try and find out exactly what "significant stakeholder engagement" they were involved with. If someone in the MCA is not telling the truth, it needs to be the subject of official and formal disciplinary procedure.
Kukri
Well-Known Member
The MCA told the RYA that they had been “consulting with suppliers” but not with “members organisations”!
They also told the RYA that they had consulted with the CA when they had not done so.
Anyway, here’s my effort:
Dear Sirs,
I am not going to respond as requested. You have already received many responses pointing out the numerous errors in your draft documents.
I want to make three different points
First, the time allowed for this consultation is inadequate. To illustrate, the Regulation and Technical Services Committee of the Cruising Association (“CA”) meets on the third Thursday of each month. Your timing gave the RATS Committee one of the leading sources of knowledge in this field, precisely two days to respond.
You should extend this.
Next, I am reluctant to accuse a Government agency of lying, but you informed the Royal Yachting Association (“RYA”) that you had consulted with the CA when in fact you had not done so. I would prefer to think that this was an honest mistake on your part, in which case you are merely incompetent rather than mendacious.
This does not assist your case for putting forward “guidance”
Finally, and much more important, your draft MGNs represent the very first attempt by the MGA or its predecessors to assert any jurisdiction over private pleasure craft. You are trying to do so through the back door but it by no means clear that you have any right in law to do so. Your claim that your general duty to promote safety at sea gives you the right, let alone the powers, to do so is specious.
You have already said in response to others who have written to you that you are not making regulations, merely “offering guidance as to best practice”. This is in itself devious and specious.
You do not have knowledge or experience in private pleasure craft, and your draft MGNs make this abundantly clear, as they are full of mistakes that others have already pointed out to you.
All you can do it to regurgitate advice already available (and well known) from the voluntary bodies which currently arrange education training and dissemination of expertise in the private pleasure sector.
The safety record of private pleasure craft in Britain is extremely good; the RoSPA data supplied to you by others makes this very clear,
Britain’s record in safety in private pleasure craft is almost certainly as good as, if not indeed better than, that of other nations - the USA and France for example - which use Government regulation of private pleasure craft.
Britain leads the world in yachting thanks to a very well run and entirely voluntary system of safety promotion and training run by inter alia the RYA, the CA, the RORC and many others.
You yourselves benefit from your co-operation with the RYA in the large yacht sector. This sector depends on the private pleasure sector in boats of less than 13.7 metres register length, which feeds it.
There is therefore no good reason for your attempts to assert influence over private pleasure craft. You are likely to do more harm than good. You should stop now.
We all know the background to this, your failed prosecution in the Cheeki Rafiki case and the criticisms of the MCA made in that case, your consequent “loss of face” and the arrival of an activist Chief Executive from the subsidised housing sector who is no doubt thinking of the Grenfell Tower disaster have caused you to rush in where for the past two centuries angels have feared to tread.
Because the owner of a yacht used for training made use of his ability to treat his training yacht as a private pleasure craft you have most unwisely sought to extend your remit into private pleasure craft when the more natural approach would be to restrict the ability of commercial operators to treat their vessels as private craft from time to time.
I am copying this to the merchant ship Register section of the MCA because I persuaded my Board of Directors to put half a million tons of merchant shipping under your flag ten years ago and I have just been asked by them for my opinion on their operations.
I am at present in the middle of replacing these ships and the question of flag has come up thanks in part to “Brexit”.
I was about to respond that I have been entirely satisfied, indeed delighted, with the UK Register of Ships. when my attention was drawn to your so-called “Consultation”.
That the MCA is prepared to behave in the way in which you are conducting yourselves makes me re-consider whether the UK flag is indeed going to be appropriate for my employers’ fleet in the future.
I have no comment to make on the commercial sector which you already regulate. That is between commercial operators of small commercial vessels and yourselves.
I strongly urge you to reconsider your position and to exclude private pleasure craft from your “draft guidance”.
To say as you repeatedly have said that these MGNs - the first ever issued for private pleasure vessels- are “advisory only” is not good enough.
To put it more bluntly - Brian Johnson needs to get his tanks off our lawn.
Yours
They also told the RYA that they had consulted with the CA when they had not done so.
Anyway, here’s my effort:
Dear Sirs,
I am not going to respond as requested. You have already received many responses pointing out the numerous errors in your draft documents.
I want to make three different points
First, the time allowed for this consultation is inadequate. To illustrate, the Regulation and Technical Services Committee of the Cruising Association (“CA”) meets on the third Thursday of each month. Your timing gave the RATS Committee one of the leading sources of knowledge in this field, precisely two days to respond.
You should extend this.
Next, I am reluctant to accuse a Government agency of lying, but you informed the Royal Yachting Association (“RYA”) that you had consulted with the CA when in fact you had not done so. I would prefer to think that this was an honest mistake on your part, in which case you are merely incompetent rather than mendacious.
This does not assist your case for putting forward “guidance”
Finally, and much more important, your draft MGNs represent the very first attempt by the MGA or its predecessors to assert any jurisdiction over private pleasure craft. You are trying to do so through the back door but it by no means clear that you have any right in law to do so. Your claim that your general duty to promote safety at sea gives you the right, let alone the powers, to do so is specious.
You have already said in response to others who have written to you that you are not making regulations, merely “offering guidance as to best practice”. This is in itself devious and specious.
You do not have knowledge or experience in private pleasure craft, and your draft MGNs make this abundantly clear, as they are full of mistakes that others have already pointed out to you.
All you can do it to regurgitate advice already available (and well known) from the voluntary bodies which currently arrange education training and dissemination of expertise in the private pleasure sector.
The safety record of private pleasure craft in Britain is extremely good; the RoSPA data supplied to you by others makes this very clear,
Britain’s record in safety in private pleasure craft is almost certainly as good as, if not indeed better than, that of other nations - the USA and France for example - which use Government regulation of private pleasure craft.
Britain leads the world in yachting thanks to a very well run and entirely voluntary system of safety promotion and training run by inter alia the RYA, the CA, the RORC and many others.
You yourselves benefit from your co-operation with the RYA in the large yacht sector. This sector depends on the private pleasure sector in boats of less than 13.7 metres register length, which feeds it.
There is therefore no good reason for your attempts to assert influence over private pleasure craft. You are likely to do more harm than good. You should stop now.
We all know the background to this, your failed prosecution in the Cheeki Rafiki case and the criticisms of the MCA made in that case, your consequent “loss of face” and the arrival of an activist Chief Executive from the subsidised housing sector who is no doubt thinking of the Grenfell Tower disaster have caused you to rush in where for the past two centuries angels have feared to tread.
Because the owner of a yacht used for training made use of his ability to treat his training yacht as a private pleasure craft you have most unwisely sought to extend your remit into private pleasure craft when the more natural approach would be to restrict the ability of commercial operators to treat their vessels as private craft from time to time.
I am copying this to the merchant ship Register section of the MCA because I persuaded my Board of Directors to put half a million tons of merchant shipping under your flag ten years ago and I have just been asked by them for my opinion on their operations.
I am at present in the middle of replacing these ships and the question of flag has come up thanks in part to “Brexit”.
I was about to respond that I have been entirely satisfied, indeed delighted, with the UK Register of Ships. when my attention was drawn to your so-called “Consultation”.
That the MCA is prepared to behave in the way in which you are conducting yourselves makes me re-consider whether the UK flag is indeed going to be appropriate for my employers’ fleet in the future.
I have no comment to make on the commercial sector which you already regulate. That is between commercial operators of small commercial vessels and yourselves.
I strongly urge you to reconsider your position and to exclude private pleasure craft from your “draft guidance”.
To say as you repeatedly have said that these MGNs - the first ever issued for private pleasure vessels- are “advisory only” is not good enough.
To put it more bluntly - Brian Johnson needs to get his tanks off our lawn.
Yours
Last edited:
Tomahawk
Well-Known Member
I would suggest Mr Johnson needs to seek an alternative career.
Robert Wilson
Well-Known Member
Well said Minn.
Thank you for taking the time to construct and communicate such a wholly appropriate response.
R
Thank you for taking the time to construct and communicate such a wholly appropriate response.
R
Hot Property
Well-Known Member
+1, a very good response thank you Minn.
Balbas
Well-Known Member
Agreed.
I especially enjoyed the open threat. Unfortunately I suspect that this is likely to stiffen resolve. It often does with prickly characters.
Hot Property
Well-Known Member
And control freaks........
capnsensible
Well-Known Member
Wow, Minn, I enjoyed that!
A threat to throw half a million tons of teddies outa the pram! Brill.
Im sure though that the Agency response to that will be far more controlled and professional than my knee jerk reaction....
A minor (very in the grand scheme of things) but would it be prudent to delete the named person and insert an anonymous substitute on a public forum? Genuine question.
A threat to throw half a million tons of teddies outa the pram! Brill.
Im sure though that the Agency response to that will be far more controlled and professional than my knee jerk reaction....
A minor (very in the grand scheme of things) but would it be prudent to delete the named person and insert an anonymous substitute on a public forum? Genuine question.
Kukri
Well-Known Member
I think you can find the name of the Chief Executive of the MCA rather easily, on several public websites.
capnsensible
Well-Known Member
No, not him. The chap who's name you put up regarding a recent court case.
Kukri
Well-Known Member
Ah. Sorry. Good point. Edited.
You will I am sure appreciate that my half million tons out of the pram is a device to get another and more “weighty” part of the MCA to ask their colleagues what they are up to.
Last edited:
capnsensible
Well-Known Member
Absolutely! :encouragement:
rgarside
Well-Known Member
Perhaps we should be submitting FoI requests to the MCA to find out what enquiries they addressed to the RYA and CA.
This seems to describe the process:-
https://ico.org.uk/your-data-matters/official-information/
Kukri
Well-Known Member
That’s a very good idea indeed. Let’s keep the pressure on!
sailaboutvic
Well-Known Member
I don't see any responds from CA members what's are the CA saying if any thing?
Tomahawk
Well-Known Member
Who is a member of the CA to ask questions from the inside?
Kukri
Well-Known Member
I am a CA member and I have been in touch with the RATS Committee of the CA which is why when Stuart Carruthers of the RYA was told by the MCA that they had consulted the CA I immediately checked with the CA who said that they had not been consulted. I’m not on the RATS Committee and I don’t know what their final submission said nor do I know what the RYA said.
Tomahawk
Well-Known Member
I can make an FoI request, as a follow up to the email I recieved, but I suspect it will be rejected on grounds of confidentiality of correspondence between two separate parties. Far better in my opinion that the CA respond in light of the email I recieved.
I suppose I could fork out and join the CA so it becomes an internal matter?
I suppose I could fork out and join the CA so it becomes an internal matter?