EIR request about Strangford Ferry
Here is the transcript of DFI 2024-0391, as provided in the uploaded document:#/
DFI/2024-0391
EIR Request (received 27 September 2024) – Reference: DFI/2024-0391
This is a Freedom of Information request in respect of Strangford Ferry service
Request
In reference to the various Noise Assessments carried out in respect of the ferries operating in Strangford Lough (Portaferry II and Strangford II), I would like to request the following information:
- WHO Compliance
The 2011 noise assessment stated that daytime external noise from the ferries exceeded WHO recommended levels, resulting in annoyance to residents (see Noise Survey 2011, 4.1.3 and 4.1.4). The 2018 survey gave similar results and reflected findings from the 2002 assessment.
Request: What action has the DfI taken to ensure compliance with the WHO levels?
- Defects in Noise Assessments
(a) The 2011 and 2018 assessments did not measure noise produced by the operation of the ramps, despite the 2002 assessment highlighting this as the single biggest noise source.
Request: Has any assessment been carried out for noise during ramp operation? If not, does DfI plan to conduct one?
(b) The operating speeds of the ferries were omitted in the 2011 and 2018 assessments, unlike the 2002 assessment.
Request: Why was this critical information excluded?
(c) No separate assessment of low-frequency noise was included, despite its known severe health impacts (per WHO).
Request: Why was low-frequency noise not assessed separately?
(d) The 2018 survey highlighted issues with anti-vibration engine mountings on Portaferry II, which could explain its noise issues.
Request:
What actions were taken in response?
Was a follow-up inspection conducted? If so, when, and what were the findings?
Did the faulty engine mountings cause vessel damage?
Are the original components still in use, or have they been replaced?
- Nighttime Operations
The 2011 and 2018 surveys deemed the ferries unsuitable for nighttime use due to noise levels exceeding WHO guidelines.
Request: Why does Strangford Ferry continue nighttime operations on Saturdays (11:00–11:30 PM)?
- Annual Refits
Given the ferries’ low annual mileage (6,400 nautical miles), annual full refits seem excessive.
Request: Why are annual refits conducted when not legally required?
- Usage of Strangford II
The Strangford II, introduced in 2016 following public consultation, was expected to be quieter and less polluting. However, it remains underused.
Request:
Why is Strangford II not the primary ferry?
Why is Portaferry II prioritized despite being noisier and more polluting?
Why is Strangford II underused when it can carry more vehicles?
Why has Portaferry II not been upgraded to a wet exhaust system?
Why is Portaferry II operated in foggy conditions despite its dry exhaust system, which worsens air pollution?
- Decision-Making Authority
Request: Who decides which ferry is used daily?
- Operating Costs
Request: What were the total operating costs for Strangford Ferry Service from April 2023 to April 2024?
- Strangford Ferry Committee
Request: Provide:
Minutes from the last five years.
Copies of all internal and external communications.
All reports/documents presented to the committee.
Response (Issued 25 October 2024)
Introduction:
The DfI determined that this request falls under the Environmental Information Regulations 2004 (EIR) rather than the FOI Act 2000.
Guide to the Environmental Information Regulations:
ICO Guidance on EIR
- Compliance with WHO Levels
MV Strangford II: Fans and intakes were relocated to reduce noise. High-capacity systems were installed to further reduce emissions.
MV Strangford: By 2018, this vessel was no longer owned/operated by DfI.
- Noise Assessments
Ramp Noise: The 2018 assessment included ramp noise (see para. 3.2.2).
Operating Speeds: Omitted as 2011 and 2018 assessments aimed to compare previous data for early-morning starts.
Low-Frequency Noise: No separate assessment was conducted as surveys sought to compare historical results.
Engine Mountings: No immediate action was deemed necessary. No damage to vessels occurred, and mountings remain per manufacturer guidelines.
- Nighttime Operations
Operations follow long-standing published schedules.
- Annual Refits
Refits adhere to MCA UK passenger vessel requirements, Lloyd’s Register inspections, and Health & Safety regulations.
- Strangford II Usage
Both vessels are used interchangeably to prevent deterioration. Upgrading Portaferry II is not cost-effective for a 25-year-old asset.
- Decision-Making Authority
Decisions are made by the Ferry Manager in consultation with the Maintenance Supervisor.
- Operating Costs
£3,520,000 for April 2023–April 2024.
- Strangford Ferry Committee
There is no such committee. Further details are required to clarify the request.
This transcript captures the request and response details for DFI 2024-0391.
The issues in the response letter suggest potential gaps in accountability and transparency, but whether this constitutes a cover-up depends on intent. Here’s a breakdown of the situation:
Indicators of a Possible Cover-Up
- Deflection of Key Questions
Several critical issues are dismissed or inadequately addressed, such as low-frequency noise assessments, pollution concerns, and decisions regarding ferry usage.
The repeated claim that actions were not taken because “mitigation measures were unnecessary” or “not value for money” lacks supporting evidence, which can appear evasive.
- Failure to Act on Known Issues
The 2018 noise survey identified issues with anti-vibration mounts and excessive noise. The lack of follow-up or corrective action, despite these findings, raises questions about whether risks were intentionally ignored.
- Absence of Detailed Evidence
No breakdown of costs, clear explanation for operational decisions, or supporting documents for justifications (e.g., why the Portaferry II remains in heavy use) is provided.
Requests for records related to the “Strangford Ferry Committee” are deflected without thorough investigation, which could imply withholding information.
- Environmental Non-Compliance Risks
Operating a ferry with higher emissions and noise pollution despite newer, greener alternatives could breach environmental regulations. Downplaying these issues might indicate an attempt to avoid scrutiny.
Counterarguments Against a Cover-Up
- Administrative Inefficiency vs. Malice
The poor quality of the responses may reflect administrative inefficiency or lack of expertise rather than deliberate concealment.
Limited resources or oversight within the DfI could explain some of the lapses.
- Transparency in Some Areas
The letter openly acknowledges issues like interchangeability of ferries and dry exhaust systems. While insufficiently detailed, these admissions do not align with a deliberate effort to hide facts.
- Regulatory Constraints
The DfI appears to rely on guidelines from regulatory bodies like the MCA or Lloyd’s Register. A lack of modern standards could limit the department’s ability to act, reducing culpability for perceived inaction.
Conclusion
The response letter reflects significant shortcomings in addressing public concerns, suggesting possible negligence or indifference. However, a clear cover-up would require evidence of intentional suppression of facts or deliberate misrepresentation, which is not explicitly evident from the letter.
Further investigation, including access to internal communications and unredacted records, would be necessary to determine if there is an active effort to conceal information.