Annex F - Structural options considered for UK port security authorities

 

Model type

Description

Pros and Cons

Centralised

The PSA is TRANSEC, a single PSP is developed for the entire UK covering baseline measures and response.

Pros - Could give a statutory footing to the PFSIs, would not require industry to take on board any more roles. Requires little effort on part of industry.

Cons - The regulator would be regulating itself in implementation of the PSP, The PSP would not adequately reflect local nuances in port operations, and the PFSIs would cease to be a flexible guide and become overly prescriptive.

Regionalised

A series of regional PSAs could be established, with statutory powers for the PSA and the PSO.

Pros - introduces an intermediate tier of tactical communication between strategic TRANSEC as focal point/competent authority, and PFSOs at operational level. Requires some effort on part of industry.

Cons - would require complicated funding arrangements, would be introducing additional bureaucracy, would require statutory powers to influence facilities, would require statutory powers to influence, may not adequately reflect local nuances. Difficult to forecast the potential overheads to industry after implementation.

Localised

PSAs are identified at a local level, using existing identifiable structures such as Police force areas, MCA areas, Geographical boundaries or Unitary Authorities.

Pros- would introduce intermediate communication tier. Most suitable for integration with other response plans (i.e. Civil Contingencies etc). Requires some effort on part of industry.

Cons - some difficulties over funding, would require statutory powers to influence, may not reflect local nuances, could result in people without direct maritime or ISPS knowledge/experience having key roles. Difficult to forecast the potential overheads to industry after implementation.

Flexible carry over

Most PFSOs become PSOs, most PFSPs become PSPs and any additional extra measures identified from the assessment are incorporated into an Annex initially and in due course a fully revised PFSP. However, 'Strategic Authorities' i.e. those who play a key part in the water or land based operations of the 'port' may become the PSA, and nominate a PSO to chair a single committee to fulfil the requirement for a PSA.

Pros - maintains independence of PFs, minimises additional bureaucracy, minimises further administrative burden, PSA able to exert some influence over its 'port' possibly backed up by statutory powers. Requires minimal effort on part of industry.

Cons - Will require a high degree of collaboration between PFSOs and industry, and may require heavy arbitration by TRANSEC. Issues around recovery of costs incurred by PSO/PSA, possibly addressed through system of civil fines/fees levied for non-compliance with PSD?

Direct carry over

All PFSOSs become PSOs, all PFSPs become PSPs, and all PFSCs become the PSA. Any additional extra measures identified from the assessment are incorporated into an Annex initially and in due course a fully revised PFSP.

Pros- maintains independence of PFs, minimises additional bureaucracy, minimises further administrative burden, PSA able to exert full influence over its 'port'. Requires Minimal effort on part of industry.

Cons - misses opportunity for formal co-operation at local level, results in potentially 600 'port security authorities' in UK, does not bring anything new to ISPS. Will not achieve integration with other plans. Doubtful whether majority of unitary port facilities have resources to complete security assessments etc.