NFA position reporting

The NFA supports proposal for introduction of position reporting for all Norwegian fishing vessels

The Norwegian Fishermen’s Association supports the proposal to introduce requirements for position reporting for all Norwegian fishing vessels.

The National Board has dealt with the case and the consultation response with input from the NFA member teams has been sent to the Directorate of Fisheries.

In Fiskarlaget’s consultation response, it is pointed out, among other things, that we have a differentiated fishing fleet from the largest with 24/7 operation and 15-20 men on board an open one-man boats that go ashore every day.

There is thus great variation in staffing, operating patterns and finances. The users’ prerequisites must be emphasized, we point out and believe that schemes must make sense for the various groups.

In the same way, it is pointed out that Fiskarlaget cannot see that the Directorate of Fisheries’ consultation proposal to impose on the fleet less than 15 meters similar reporting obligations as the fleet over 15 meters will provide the research with significantly more information than can be obtained from catch reports containing position data from AIS.

The Norwegian Fishermen’s Association is also clear that we understand the increased expectations that come from society to be able to document sustainability, legality, conditions surrounding the practice of fishing and where the fish come from. And we see the value of increased data collection can provide a basis for better land management, research, statistics, regulation and be able to provide better resource control.

            

Introduction

The Norwegian Fishermen’s Association refers to the Directorate of Fisheries’ consultation memorandum of 29 May 2020 on reporting of activity and position data from all vessels under 15 meters, as well as changes for vessels over 15 meters.

Expectations from society to be able to document sustainability, legality, conditions surrounding the practice of fishing and where the fish come from are increasing. Furthermore, increased data collection will provide a basis for better land management, research, statistics, regulation and be able to provide better resource control.

The Norwegian Fishermen’s Association therefore recognizes that there is a need to make regulatory changes that can contribute to strengthening the overview of resource extraction and the practice of fishing. It is in the industry’s interest to move away from the recurring spotlight on resource crime and regulatory circumvention in the fishing industry. In the same way, it is in the industry’s interest that good resource management is facilitated, and that knowledge is built about the fishing resources and fishing fields that enable the fishing industry’s interests to be safeguarded in a reassuring way in discussions about the disposition and use of coastal and marine areas.

At the same time, it is essential that the requirements to be set are adapted and dimensioned for the respective fleet groups and fishermen. The economic and practical consequences of requirements to be set must be weighed against the utility value to be achieved. We have a differentiated fishing fleet from the largest with 24/7 operation and 15-20 men on board an open one-man boats that go ashore every day. There is thus great variation in staffing, operating patterns and finances. The users’ prerequisites must be emphasized. In the smaller fleet in particular, there are a number of older fishermen, who must be taken into account when assessing which technological solutions are suitable and sufficient. It must be avoided to set requirements that allow technical possibilities on the respective vessels, costs with necessary equipment,

The need to differentiate the requirements according to vessel size is therefore strongly present, which means that equal requirements must not be set for all Norwegian fishing vessels.

The Norwegian Fishermen’s Association can not fail to emphasize that it must still be weighing related to the vessels’ landing / delivery that must be the basis for quota settlements / resource accounts. It is therefore necessary to strengthen landing controls. This can be solved in various ways, for example by using new technology in addition to traditional quay control. If the actual landing and weigh-in on the quayside is ensured, and is correct, then the need for a number of other measures will disappear.

Position reporting

The Norwegian Fishermen’s Association supports the proposal to introduce requirements for position reporting for all Norwegian fishing vessels. An acceptable and simple solution for the industry, which can also meet the authorities’ expectations, is that requirements are set for installed AIS on all fishing vessels under 15 meters. This must also apply to the recreational vessels that sell catches through the sales teams. Many fishing vessels under 15 meters have already installed such equipment on board.

Reporting of position data can also give the fleet a better current overview of the activity on the individual fishing grounds. This can make it easier to plan fishing operations and prevent any conflicts between fleet groups. In order for the new reporting requirements to have such an effect, it is a prerequisite that technical solutions are chosen where the position data becomes visible to the entire fleet, and not just to the authorities. It must be possible to grant exemptions for requirements for AIS in certain fisheries for vessels that have installed VMS on board, cf. the conditions given in § 11 of the regulations on fishing for wrasse in 2020.

In some individual coastal fisheries, where pots / trays etc. are used, however, alternative tracking equipment for AIS, which is not open to the public, must be able to be used. 

In addition to contributing to the mapping of the fleet’s movements, expanded requirements for AIS will have an important safety aspect.

Catch and activity data – vessels under 15 meters – landing report

The Norwegian Fishermen’s Association believes that it has not been documented that it is required to introduce requirements for electronic reporting for fishing vessels under 15 meters, corresponding to what currently applies to vessels over 15 meters, and can thus not support this proposal.

Today’s reporting via the catch app for vessels under 15 meters works satisfactorily. An extension of this reporting obligation in the smaller fleet groups should provide a significantly expanded overview of fishing.

The fishing team can therefore support the introduction of landing notification requirements for all vessels under 15 metres, as vessels between 13 and 15 metres have today. The fishing team is fundamentally concerned with keeping manual registration obligations to a minimum.

Given that the current coastal fishing app does not have the capacity to handle all vessels under 15 metres, the Norwegian Fishermen’s Association believes that there is a need to further develop this reporting platform. This should be done in close cooperation between the authorities and the sales teams who have extensive experience of receiving landing reports.

In addition to the above requirements for position reporting for all vessels under 15 meters, a landing report will provide good and sufficient information both about where the vessel has been and how much it has brought ashore. Control measures must be seen in context. What is necessary to require of the fishing fleet must be seen in connection with what is also done by tightening in relation to resource control and registration of catch in connection with the landing situation.

Position information from AIS, information registered in the coastal fishing app and information from the final note are available to the authorities and should be able to be coordinated to achieve a better overview of the resource extraction and to strengthen resource control. This will provide a basis for improving land management, research, statistics, regulation and resource control, at the same time as the requirements and costs are in proportion to the vessel’s size and operation.

The consultation memorandum states that the proposal is also justified by the need to provide better fisheries-dependent data for stock research. The Fishermen’s Association cannot see that the proposal to impose on the fleet less than 15 meters corresponding reporting obligations as the fleet over 15 meters will provide the research with significantly more information than can be obtained from catch reports containing position data from AIS.

The fishing team assumes that catch reporting / landing report is phased in step by step for the entire fleet under 15 metres as outlined in the consultation memorandum.

Catch and activity data – vessels over 15 meters – Notification of port departure (DEP)

It is now proposed that notification of port departure shall be sent before the vessel leaves land, while the current provision requires that notification be sent no later than 2 hours after port departure, but before fishing begins. The purpose of sending a notification of port departure before the vessel leaves land is to ensure that the notification arrives well in advance of the catch operation, and shall serve as an advance notice of a planned activity.

The fishing association does not see that there is a need that necessitates such a change in the reporting requirement for port departure. In this connection, it is requested that the 2-hour rule be continued. 

Requirements for reporting the individual capture operation

With regard to the requirement for reporting catches after the individual catching operation, this has been applicable to large parts of the sea-going fishing fleet since regulations on position reporting etc. came in 2009, except for net and line vessels that can report once a day.

With the proposed change, all vessels in the fishing fleet that fish with passive gear will now report after each catch operation. This reporting requirement can be extensive if it is to be reported after each line stub or yarn link. The Norwegian Fishermen’s Association questions whether such frequent reporting is strictly necessary to ensure sufficiently good catch and activity data from the fleet. Fishing with nets and line takes place within the same day in a limited geographical area. A requirement to report 10 to 12 times per day for these tool groups will not have increased utility value for HI.

For the vessels in question, however, such a requirement will increase the workload and prevent an efficient implementation of the fishing, and increase the risk of incorrect reporting. For the industry, it is important that catches are estimated and reported as accurately as possible, and schemes that increase the risk of incorrect estimates in catch reports cannot be accepted.

Requirement to state quantity and type of fuel on board the vessel

The Norwegian Fishermen’s Association believes that for large parts of the fleet it is not practically feasible to report fuel consumption through the ERS system so that this will form the basis for a compensation scheme for CO2 tax. The fishing fleet consists of both large and small, old and new vessels, and only a small proportion of these vessels have the equipment or prerequisites to be able to report fuel consumption through the ERS system.

However, such a reporting requirement may be feasible on larger and newer vessels.

Increased frequency of position reports

It is proposed that the frequency for sending position reports be increased from once per hour (½ hour outside 40 km of the baselines in the Skagerrak) to every 5 minutes, and every 10 minutes when the vessel can only communicate such messages using. satellite.

The fishing team assumes that an increased frequency for position reporting can be implemented through technical changes in the ERS, and that this does not impose additional work or additional costs on the business actors.

As is well known, the fishing fleet over 15 meters is already subject to extensive reporting obligations, not only to the Directorate of Fisheries, but also to other public authorities. It is therefore very important that the reporting requirements that are introduced are well thought out, necessary and sufficiently substantiated before a decision is made to introduce them.

Finally, the Fishermen’s Association requests that current and future reporting requirements be coordinated between the authorities. This is to ensure that the reporting requirements do not become more extensive than necessary. It is pointed out here that the Directorate of Fisheries initially points out in the consultation memorandum that it is important to look holistically at the administration’s need for data, so that the same reporting solution can serve several purposes (the Once Only principle).

The Norwegian Fishermen’s Association has conducted a hearing on this matter in the organization, and statements from the individual member associations are attached (edit note: In the letter in the directorate) for information. Here are various assessments related to the proposals in the consultation memorandum that the authorities should be aware of. “

Source

Brian J McMullin Solicitors
MMG Welding Killybegs

NFA supports proposal for position reporting for all Norwegian fishing vessels

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