ANAVRE communiqué

Today, we have gathered representatives of ANAVRE and ANEN to discuss the draft order that the EQUIPMENT OF SAFETY AND PREVENTION OF THE CONTAMINATION OF RECEIVED ENVIRONMENTAL.

The meeting found that criteria were consistent in the need to simplify and modernise the requirements of the draft and the sanctions regime.

There are differences in the scope of its application, since ANAVRE understands that its application to foreign flag vessels is in violation of national and international law.

Both associations have agreed to request a further extension of the time limit for claims, taking into account the Director's vacancy in the Directorate General of the Merchant Navy, in order to draft an alternative consensus project that will contribute to the modernization of the regulation of the Spanish leisure nautical.

21 / 05 / 2018: ANAVRE and ANEN shall submit to the State the allegations together

Information that ANAVRE has sent us today

Today there have been discussions between the President of ANAVRE and the Secretary-General of ANEN in which they have agreed to request the Administration to extend the deadline for allegations to the draft reform of the order governing the safety and pollution prevention teams of recreational boats.

In this way, representatives of nautical companies and recreational sailors hope to be able to meet with each other and with the Administration to produce a text as consensual as possible.

From ANAVRE we highlight the good willingness of ANEN to seek to approach positions with the navigators.

18 / 05 / 2018: ANAVRE expresses its unease and surprise to ANEN for its support for the "Security Project"

We have received today in Digital Nautics, the detail of an email sent by ANAVRE to ANEN, we simply play notaries of the present and we reproduce it as it has come to us. Obviously, Digital Nautics reserves its opinion on this, from an unambiguous, impartial position and with the utmost respect to both entities.

Mail sent by the President of Anavre to his ANEN counterpart

Att. Sir Don Carlos Sanlorenzo
Secretary-General of ANEN

Dear Carlos.

I contact you, to show you the surprise and discomfort of ANAVRE as representative of our country's recreational sailors, for the support they make from that employer to the "Project of the O.M. that will replace the current Order FOM 1144 / 2003," which is totally anachronistic.

I am aware that from ANEN support a project, which instead of moving forward and drawing up rules more in line with the countries of the rest of Europe, which would result in the promotion of the nautical of recreation in our country, while at the same time encouraging the Spanish sailors not to be forced to change their ships in order to be able to navigate with a more coherent standard -, announcing it ANEN to pump and dish as a great
achievement for the Recreation Nautics.

Slowly.
Gustavo J. Navarro Panga.
President of Anavre.

Also inform you that we have enabled a mail account to submit allegations to this project, the address is: proposals.

16 / 05 / 2018: ANAVRE Press Release on the safety regulation project

Press Release on the Public Consultation Notice on the Draft Order regulating the Security and Pollution Prevention Team of Recreation Embarges

Yesterday, 15 May 2018, the announcement of public consultation on the draft order on safety equipment and pollution prevention of recreational craft was published, once again, the DGMM has ignored Anavre's suggestions, as well as the considerations made by this association and a number of entities that joined them in connection with the previous public consultation on this matter.

We understand that, as with the so-called royal decree of megayates and the reform of the titles, despite the many meetings and proposals made by the users, the DGMM has preferred to work in collaboration with a sector of the employers of companies in the nautical sector, taking advantage of a real opportunity to modernise our legislation and make the Spanish flag an attractive flag not only for Spanish, but also for citizens of other countries that use our ports and coasts as a permanent basis for their ships.

First, it highlights the non-compliance with the agreement that was reached after months of negotiations with the balsas review stations and the previous DGMM, Ms María Isabel Durántez Gil, who announced it at the Barcelona Nautical Hall in 2011, according to which life rafts would be reviewed according to specifications and recommendations of the manufacturer, without maximum time. Not only have it taken years to implement an agreement that linked them, but the current DGMM team has altered it, we assume giving in to pressures of a business nature.

On the other hand, we believe that the intention to extend the application of this regulation to any vessel in Spain owned by a natural or legal person resident in Spain not only contravenes Spanish law, where higher-ranking rules provide that the vessels are governed by the legislation of their flag, but also the international treaties signed by Spain in this area, and even the principle of equality established in article 14 of the Constitution, all of which are already violated by the additional provision of the fifth Royal Decree of degrees for the management of recreational vessels.

We also believe that the opportunity has been missed to make progress in modernising our rules by not including the possibility of replacing emergency pyrotechnic signals with led and laser equipment that have already shown their effectiveness and are accepted by other EU states. thus releasing crews from carrying on board genuine explosive devices, whose recycling is also extremely complicated.

The reason that many Spanish shipowners have changed the flag of their vessels is not that their legislation is more lax or permissive as stated in the explanatory statement of the text, in which we consider it an intolerable insult to Spanish shipowners, but that these regulations are more flexible and allow the shipowner to equip his boat according to its criteria in the choice of material, establishing logical review deadlines that allow for avoiding unnecessary costs and thus to be able to increase the level of effective investment in safety and prevention on board, in addition to allowing access to state-of-the-the-art equipment which are often not available in our country or in the Spanish flag are not considered to be insufficient in the specific procedures that have been installed in the previous GMM;

Approval requirements that not only increase equipment, but often prevent access to the Spanish market. The sailors are a responsible collective, not a flock in need of constant guidance and supervision. We have to remind the DGMM that the lives at stake at sea are ours, and also that they have been in breach of their commitment to make it easier for Anavre to disaggregate the casuistics of accidents and incidents in the recreational nautical so that we can all contribute to its prevention.