• July 3, 2015


The United Kingdom Ministry of Defence has responded to our query about adherence to IMO safety rules (relating to fishing trawlers) by Royal Navy submarines. However their reply leaves several questions unanswered.

We wrote to all NATO countries and the Russian Federation in January asking what steps they took to ensure submariners complied with IMO resolution A709 (17) and asked if specific training was given.

To date only the German Navy had responded and indicated a training regime is in place (see links):

Submarine Threat to Fishing Safety Governments Challenged

German Assurance of Strict Application of IMO Safety Mode

The MOD response (after follow-up correspondence on May 30th) is set out below:


“Navy Command HO Policy Secretariat
Mailpoint 1.4
Leach Building
P02 8BY

29th June 2015

Dear Mr Moffatt

Thank you for your letter of 30 May to the Secretary of State for Defence regarding the steps taken by the Government to ensure the safety of fishing vessels in United Kingdom waters. Your correspondence has been forwarded to Navy Command Headquarters and I have been asked to respond.

I can assure you that, while operating in both British and International waters the Royal Navy (RN) takes its responsibility to ensure the safety of other vessels very seriously. The RN adheres to a safe and comprehensive code of practice for conduct in the vicinity of fishing vessels, this ensure (sic) the safety of both our platforms and others.

You may wish to be aware, since 1993 the RN has adhered to “The Code of Practice for the Conduct of Submarine Operations in the Vicinity of Fishing Vessels”, which was agreed by the Fishing Industry Safety Group. To support the Code there are regular consultation meetings between the RN and fishermen’s associations in the Clyde, West Coast of Scotland, Irish Sea and Portland/Plymouth regions.

In addition the RN has a Fishery Liaison Officer to provide a central point of contact with the UK Fishing Industry.

Yours sincerely,

James Phillips”

Pointedly the MOD/RN does not say that specific training is given in relation to IMO resolution A709 (17) which was the point of our query. The go to great lengths to emphasise their liaison with the UK fishing industry which was something we were already aware of but there is no indication that such liaison extends to trawler men of other EU states such as the crew of the MFV Bugaled Breizh which sank suddenly of the Lizard in January 2004 during a Nato naval exercise.

It is also unclear if the RN liaison extends to information on the movements of other NATO countries submarines when in transit to or on exercise in UK waters. For example in April when the Ardglass trawler MFV Karen was snagged submarines from other countries (including Norway and Turkey ) were active in UK coastal waters off Western Scotland and in the Irish Sea . What guarantees are their that this ‘cosy’ industry/RN liaison extends to them?

Related links:

Fisheries Special: Minister O’Neill Calls for Clarity over Submarine Incident (Down News)

Submarine Trawler Issue IOM Urged to Act

J B Moffatt (Mr)
Director of Information
Celtic League


(Please note that replies to correspondence received by the League and posted on CL News are usually scanned hard copies. Obviously every effort is made to ensure the scanning process is accurate but sometimes errors do occur.)


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