The Association of Recreation Navigators meets with the Directorate of Merchant Marina

The Association of Recreation Navigators meets with the Directorate of Merchant Marina

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We are informed by the communication cabinet of the Association of Recreation Navigators, which took place a meeting between Anavre and the DGMMM in order to comment on the draft Ministerial Order, currently in the drafting phase, to replace the Order FOM 1144 / 2003 that currently regulates the equipment of safety, rescue, fire, navigation and discharges of dirty water on board the recreational boats, as well as the recent proposals of Anavre contained in the letter presented on 22 April and to which have joined, among others, the Association of Alkolea- Intxirri, Association of the Marine and the Association of the Náutico, the Club of the National Marine, the Association of the Association of the

The DGMM was represented by Ms Ana Nuñez, Deputy Director-General for Safety, Pollution and Maritime Inspection, and Mr Ivan Armenteros, responsible for the area of recreational nautical and, by Anavre, its President. Mr Gustavo Navarro, Vice President and in charge of training, Mr Guillermo Navarro Anería, as well as Mr Ángel Lopez Jubete and Jaime Darder, Secretary and First Vice-President of Anavre respectively, both lawyers and current officials of the Legal Department of the Association.

The meeting, which lasted more than two hours, took place in a cordial environment and was eminently technical in nature, and showed that both the navigators and the current DGMM team agree on the need to modernise and simplify the regulations that affect the recreational nautical.

It also showed that there are clear differences in the way in which this task is carried out, as Anavre continues to advocate the promulgation of a single specific regulatory body to replace the current policy shake, thus facilitating its knowledge and understanding by users. For its part, the DGMM is thinking of addressing this task gradually, reforming the different regulations one at a time. The important thing is that it is moving in the right direction.

Once it was confirmed by the representatives of the DGMM that the current regulatory amendment was to be made with the rank of Ministerial Order, and not through the Royal Decree as in the case of recreational nautical degrees, previously regulated by a FOM Order, it was clear that some of Anavre's proposals would not be feasible on this occasion, as they are contained in higher-ranking regulations, such as radio communications or sanctions, although they are recorded for future actions. The areas of action in this new Ministerial Order will therefore be:

  • On-board safety arm:
  • The annual review obligation will be amended and reviewed on the recommendation of the manufacturer, as agreed by the former Director General of the Merchant Navy, Ms María Isabel Durántez, with Anavre and raft review stations during his term of office in 2011, it is never too late if the bliss is good.
  • The possibility of removing the requirement that, if there is a raft on board, it is reviewed if the vessel is in an area where it is not mandatory (Area 4 or below) will be considered.
  • Pirotechnics: The possibility of empowering shipowners to replace them with LED or laser flares will be considered, Anavre has committed to collecting information about this type of equipment. The meeting provided a report on the current problems of the use of pyrotechnic flares on recreational craft, which is attached to this note.
  • Fire fighting equipment: requirements will be updated in accordance with regulations recently approved by the Ministry of Industry.
  • Other material: the list of equipment required on board shall be reviewed in order to remove obsolete requirements, etc.
  • The list of documents and books required on board will be reviewed.
  • Equipment type-approval requirements: although they are regulated in higher standards, it was explained that the methods of type-approval are being made more flexible in order to make them faster and less expensive for manufacturers and importers.
  • As regards vessels with electric engines, hybrid propulsion systems and LPG fuel, we are waiting for the draft regulations to analyse the proposals of the GFMD, given the technical complexity of these proposals which makes them not yet concrete in their final version to be submitted to the analysis of the various social actors.

In addition, Anavre's front opposition to the extension of the application of Spanish legislation to certain foreign flag vessels was again presented on the understanding that it not only violates our own legislation, but also the international conventions signed by Spain in maritime matters. On the other hand, while it was not part of the agenda for the meeting, Anavre discussed a number of problems with regard to qualifications which we consider to be a serious breach of the rules governing them. The meeting was followed by a report to those responsible for this matter, the copy of which is also attached to this press release.

So we see that, today, while they are in the preliminary study phase, the DGMM does not plan to modify in the short term such important elements as radio communications, navigation areas and inspection and punishment regimes in the field of recreational nautical. This is due to the complexity of the Spanish regulatory system, while making clear the need to create a specific authority for the regulation of Recreative Nautics, as well as a specific regulatory body for it, as Anavre has been demanding since its foundation. From Anavre we believe that, once again, we are facing a step in the right direction but clearly insufficient in view of the needs of the recreational nautical and its users, to which we represent.