Lock Gate Restrictions Announced
There will be severe restrictions on entering and exiting Sutton Harbour for many months between September this year and May next year. This is due to repair works to the lock gates, by the Environment Agency. The Sutton Harbour Group have released proposals for alternative landing and temporary berthing arrangements, which can be found at https://lockgates.info/wp-content/uploads/2023/07/SHG-Emergency-Landing-and-Berthing-Ops-Manual-03-07-23.pdf. We are concerned that these measures will be insufficient and that many unanswered questions remain. The PFSA has responded. Our response can be read in full below. We will continue to press for mitigating measures that will minimise the inevitable disruption and for the information needed to enable owners and skippers to make their own plans.
Sutton Harbour lock gates restricted access – mitigation measures
Initial comments and queries by PFSA
1. About every 10 years cyclical refurbishment and repairs need to be carried out to the lock gates at the entrance to Sutton Harbour. Because the lock gates constitute flood prevention measures the Environment Agency meets the cost of the works but looks to the Sutton Harbour Group (as the owner of the harbour and the statutory harbour authority) to provide mitigating measures to minimise disruption for users of the harbour.
2. Sutton Harbour Group (SHG) issued on 3rd July an operations manual for alternative berthing and landing facilities whilst the refurbishment and repair works are carried out to the Sutton Harbour. Bearing in mind that the works are cyclical and the disruption is predictable, It is disappointing that it has taken about a year to produce the proposed mitigation proposals and that these have been revealed only 9 weeks before the works are due to commence. Worryingly, there is a lot that remains unexplained and on which urgent clarification is needed in order that all the businesses affected can make their own plans.
3. Our focus is on ensuring, as far as possible, that the arrangements are practicable, fully minimise disruption to the commercial fleet as far as possible, and are clearly explained.
4. In a public announcement back in July 2022, jointly prepared by the Environment Agency and SHG, there was the firm assurance that mitigation measures will be in place to minimise disruption for harbour users during these essential works, working to support the continued operation of Plymouth’s fishing fleet. We ask that the Environment Agency and SHG honour that undertaking.
5. In our view, it is also important that the manual provides contains sufficient information as to be useful to vessel operators with as much detail as is possible. The detail matters a great deal and cannot be left to chance.
Principal concerns
6. We have three major and immediate concerns:
(i) The alternative arrangements are described as emergency berthing and landing provisions and are said to be for extenuating circumstances only. What constitutes an emergency or extenuating circumstances and who makes that judgement is not defined or explained. The manual emphasises that where possible all vessels should adjust fishing activity and timings to use the periods when access and exit is permitted during free flow. Our detailed analysis of the planned schedule of restricted access shows that fewer than 20% of these periods would permit the commercial fleet to operate within the constraints of normal fishing operations – and this assumes that there is no delay or disruption to the repair works. It is likely that the schedule will change, at short notice, as the works progress.
(ii) The manual repeatedly stresses that provision of the facilities is dependent upon SHG being given as much notice as possible. What is deemed to be possible or reasonable by the skipper, according to circumstances, might be different from the interpretation placed on this by SHG’s person on the ground – and what happens then? This could give rise to safety as well as financial issues for the vessel and its crew.
(iii) We doubt that the unloading and transport provisions will prove sufficient at busy times. To unload the fish boxes at Trinity Pier there will be one crane (a HIAB) with the same lifting maximum capacity of each one of the three davits in Sutton Harbour, and to transport the fish to the fish market SHG will arrange either a van or a low loader. If several boats arrive simultaneously there will be delays and quite possibly serious disruption.
7. It is essential, therefore, that:
(a) SHG recognise that vessels will need to make use of the alterative landing and berthing facilities considerably more frequently than is implied in the manual and that skippers are able to make use of those facilities whenever needed.
(b) The manual should be much clearer about the period of notice expected by SHG, to avoid any delay in landing assistance, transporting the fish and berthing. It also needs to explain how disputes (if they should arise) will be resolved between skippers and the first point of contact in SHG.
(c) Additional cranes should be provided, to avoid delays in unloading, and similarly the arrangements for transporting the fish to PTA should be strengthened to minimise delays in moving the fish to the auction house. Without cold storage on site there is considerable risk that the produce will rapidly deteriorate in quality if the measures prove to be inadequate.
8. On all these issues and others, there is a numerous sub-set of further queries and practical issues needing urgent consideration. These are covered below.
Additional clarification and information sought
Landing the fish and berthing
9. Please explain what is meant by “ SHG will ensure that an equivalent provision to that already in place at Sutton Harbour is made available at the emergency berthing and landing location”, on page 3. It seems to contradict the previous sentences and later explanation.
10. Also, on page 3 it is stated that “vessels landing scallop bags will be expected to arrange their own landing assistance (if required) and transport as they do already.” Will they be able to make their own arrangements for HIAB lifting gear at Trinity Pier and transport from Trinity Pier? Or, is the manual intended to mean that vessels landing scallop bags will not be permitted to use Trinity Pier – in which case it would be much clearer to say so. This should include explanation of what will happen when free flow access is not permitted or is severely restricted?
11. During part of the period when restrictions will apply, ferries will be operating in Millbay. The manual should state whether ABP will place any restrictions upon fishing vessels accessing or exiting Trinity pier, or other fishing vessel movements, whilst the ferries are operating – for example when the ferries are berthing or unberthing (we will be seeking clarification from ABP).
Trinity Pier
12. It would helpful (especially for visiting vessels) if the manual provided details of the drop from the quay at Trinity Pier, according to different states of tide, so that skippers can assess their ability to self-land and whether they are likely to have to make use of the HIAB.
13. Will the fishing fleet landing in Plymouth have exclusive use of Trinity Pier? On occasions flag vessels and other vessels (for example, tenders for cruise ships) have used Trinity Pier to moor. Will they continue to have access whilst Trinity Pier is being used as an alternative to Sutton Harbour?
14. What is meant on page 4 by the phrase “Self-landing facility for vessels who cannot enter Sutton Harbour at free flow due to unforeseen circumstances”. What constitutes unforeseen? There will be occasions when access is not possible for foreseeable reasons, such as the time of day and night when restricted free flow access is available.
15. Most vessels will not be able to self-land directly onto Trinity Pier, especially at low tide (i.e. when free flow is not available), which means that most vessels will need to use the pontoons for self-landing. What is the physical capacity? The manual offers no quantitative operational assessments, nor any indication of the planned speed of operation. What assumptions have been used by SHG in planning the landing arrangements?
16. The assisted lifting proposed is considerably more limited than is available in Sutton Harbour, whilst at times more vessels are likely to need to use this facility than in Sutton Harbour. This is because, even when vessels are able to self-land onto the pontoons, the manual requires that they must use the HIAB provided by SHG to move the boxes from the pontoons to Trinity Pier.
17. Will there be fork lift trucks available to move fish boxes at Trinity Pier and on the pontoons?
18. We have been asked whether it would be possible for a vessel owner to make their own arrangements for an additional HIAB to speed up unloading. Is this a possibility?
19. The manual does not mention crab landings. What will be the arrangements for landing and transporting crabs?
20. In some cases, the crabs are loaded straight onto lorries. If, for example, a vivier-crabber is unable to use free flow to access Sutton Harbour will they be able to transfer the catch to their transport vehicle at Trinity Pier?
21. Will fishermen be able to organise their own transport between Trinity Pier and/or Kings Point and Sutton Harbour. If so, will there be space constraints and, if there are how, will this be organised?
22. The manual states that vessels temporarily berthed at Trinity Pier must move to Sutton Harbour at the next available free flow. Taken literally this could mean vessels being required to move very late at night or the very early hours of the morning. The crew could have been on a long shift. Extending the working day as proposed, could raise health and safety issues and be non-compliant with working hours constraints. Common sense should prevail and ‘jobs worth’ demands and responses by supervisory staff avoided.
23. We do not accept that it is reasonable to expect vessels to remain crewed in all circumstances when berthed at Trinity Pier. The crew will very probably arrive at the end of a long working day (or longer) and once the fish have been unloaded will expect to be able to leave the vessel.
King Point Marina
24. Will it be possible to land fish at King Point Marina and operate vessels or is this to be used for berthing only? When the works were carried out last time, small vessels were able to land fish and operate at King Point which was of considerable assistance.
25. How many berths constitute a “limited number”? How does this match potential demand? Have SHG taken soundings?
Transporting the fish to Sutton Harbour
26. What will be the capacity of the van and low loader? How many fish boxes will each be able to carry? How long would it take to load and deliver, say, 100 boxes of fish? We know, from the experience last time major repair works to the lock gates were carried out, that limited transport provision was a serious problem.
27. How much notification will be required for the vehicles to be available immediately upon the vessels unloading their catch at Trinity Pier?
28. Will separation of boxes of cuttle from other species be possible? The need for this will be understood.
29. Some modern vessels store their catch on board in refrigerated fish rooms. The fish will need to be iced on landing (in Sutton Harbour the fish are moved directly into the chillers in PTA or iced to ensure the quality of fish is maintained). How might this be achieved at Trinity Pier?
30. If there are delays in unloading and transporting the fish, additional ice will be needed for all vessels unloading to preserve the quality of the fish – especially since the transport vehicles will not be refrigerated. Could a refrigerated trailer be made available as a temporary chiller?
31. If contractors are used to move the fish what will be the contractual position if fish boxes ‘disappear’ whilst being transported between Trinity Pier and Sutton Harbour?
Parking facilities
32. There is reference to limited parking provision at Trinity Pier. The manual should state clearly how much parking is available, how it will operate and whether there will be a charge.
Barbican landing stage
33. As the use of this landing stage is part of the mitigation measures to minimise disruption why should vessels needing this facility be expected to pay an additional charge, on top of the charges levied by SHG? The additional cost should be met by SHG or the EA (as part of the cost of the scheme).
34. What is the cost?
Communication
35. Skippers are asked to contact though VHS Channel 12 or phone 01752204732 – which is Sutton Lock - if they need to use the alternative facilities in Millbay. What will be the subsequent communication links within SHG to ensure that berthing, landing and transport arrangements operate smoothly and PTA is notified of when to expect fish boxes to arrive and the quantities involved. Who will oversee these arrangements?
36. Will the service be available 24/7? It will be essential that there are clear and efficient lines of communication at all times between all the parties involved.
37. Will it be SHG staff supervising the berthing and landing arrangements at Trinity Pier? The manual refers to “harbour staff” directing vessels, a “landing supervisor” and “shore staff”. Will these all be SHG staff? Will they be based at Trinity Pier or will they have to travel from Sutton Harbour, upon notification?
Emergency situations
38. The manual states that vessels are not permitted to undergo maintenance, repairs, dump or store gear whilst within the docks. Occasionally vessels are forced to return to harbour because of serious failures of one kind or another. In circumstances of force majeure, when access to Sutton Harbour is not available will vessels be permitted to use the alternative berthing facilities in Millbay and carry out emergency repairs?
Dependent upon the responses to these points and queries, we might seek further clarification.