ANAVRE has moved to Marina Mercante the many doubts of users (Photo Pedro Seoane)

A) VISITS TO THE ENVIRONMENT

Fases 0 and 1- The plan dated 30 April provides for the implementation of the plan from the start of Phase 0, scheduled for 4 May, and phase I with the following limitations:

One person per boat: we understand that that person must be the shipowner or, in its absence, a person authorized by the shipowner by the shipowner by writing to that effect. We are interested in clarification on this point. Only persons resident in the municipality where the boat or recreational vessel is tied. In this regard, we would like to refer to the considerations made in the letter of proposals submitted by ANAVRE on its own behalf and that of 16 other entities of the nautical community that collaborated in the drafting and endorsed the content of it.

In this regard, we believe that the conduct of these inspection visits is for security reasons and could therefore be included among the reasons for the movement between different municipalities of the province. To a greater extent, we find that the special configuration of our coasts means that, in many cases, the shipowners reside in municipalities other than those of the port of mooring of their ships. Even with situations of urban cores that cover more than one municipality, so a resident in them could find that, despite living in the same core in which he has his mooring point, he is in a different municipality.

There are also cases of sea bodies, such as bays, rías, etc... that cover different municipalities and there is the same case that we have just commented on. We are therefore interested in reconsidering this limitation, for the geographical reasons described above and, in particular, for safety reasons, since the lack of inspection and maintenance may lead to episodes such as the fire of recreational boats that took place this same week in Valencia, which not only endanger the integrity of the ships and pose a clear environmental threat, but also threaten the physical integrity of the staff of marines and members of the emergency services involved.

Fases 2 and 3 - We believe that both should, for the reasons already stated, allow for movements between different CAAs and between provinces of the same Autonomous Community.

We are interested in reconsidering and clarifying these limitations. In any event, we are interested in establishing a procedure for the justification of the movement, basically by the obligation of the shipowner or person authorized by the shipowner to carry out the visit to carry with him the documentation of the ownership of the vessel or ship and of the place where it is tied, either as a base port or in transit. And, where appropriate, accreditation of the authorisation or order of the shipowner in the event that the security visit is carried out by a person other than that.

Since, in many cases, the originals of the supporting documentation of ownership or base port are on board, or the authorized person may reside in a different municipality or province, we are interested that such documentation may consist of a copy of the originals and, in the case of the authorisations, it is considered sufficient that they be made by e-mail. We understand that it will be necessary to establish procedures to avoid agglomerations in ports, and we understand that these should be developed by the managers of the Náutico-sports facilities, taking into account their characteristics and capacity, and in this regard we would simply like to recall some of the ideas contained in our letter of proposals of 27 April 2020. We are therefore interested in clarification of this.

Finally, we note that no mention has been made of the possibility for shipowners to carry out maintenance work in port, as is the usual practice in recreational nautical. Work that has been interrupted with the establishment of the state of alarm in our country and whose resumption is also necessary for reasons of safety in the navigation, as well as to be able to disconnect the boats and allow them to host new ships. We ask for clarification about the possibility of resuming these tasks in the various stages of the deceleration.

In any case, we understand that the hours for carrying out these activities will be governed by the procedures established by the managers of the various national sports facilities, taking into account the measures ordered by the Government at each stage in this regard. We also request clarification.

B) REINITIO OF NAVIGATION

We refer here to points 10 and 11 of the letter of 27 April, submitted, inter alia, to the Ministry of Transport, whose copy was sent to this Directorate-General. In the interest of simplifying the task, we reproduce them... also, we interest that the shipowners whose boat is currently in the dry port in their base port be authorized to move it to their point of mooring, and the opposite case, that is to say, to move the boat from the mooring to the port, provided that the installation is in the same port and it is necessary to put it in dry for the maintenance or repair of the vessels.

In addition, and from the same date, we are interested in the authorization of the shipowners whose vessels had been left at the points of mooring or port of call outside their port of departure, to be able, with a maximum of three persons on board, to carry out the journey from those locations to their port of base, all of which after notification to the Maritime Captains or to the maritime service of the competent Civil Guard on the port of departure, justifying the current location of the vessel, as well as the documentation of which is that port of base; provided that the port is within the same CAA as the present location of the port of departure, in the case of the port of departure, in addition to be specified in the case of the ship, in the case of the port of departure.

We understand that these transports could be carried out under the exceptions provided for in the current regulation of the state of alarm and should, of course, be possible within all stages of the process of discontainment of the recreational nautical. This is because it is not just a matter of whims, but of a way to deconstruct port and transit places in seaports, to eliminate over-costs to shipowners, and to promote the activity of the maintenance and repair companies in the nautical sector and, thus, to restore an economy currently in a free recession.

We therefore ask for clarification and, if it is considered admissible to carry out such transfers, to establish a protocol for them. One possibility would be that these transfers between different ports would be possible by notification to the Departure Maritime Captains by enclosing accreditation of title, current port of stay, base port and crew list. In the case of transfers between the port and the port, we understand that no notification would be necessary.

BALEAR AND CANARY ISLANDS

In the explanatory note of 1 May 2020, express reference is made to the current situation of the closure of the ports in the Balearic Islands and the Canary Islands. Of course, in order to be able to implement the de-confinement plan of 30 April 2020, it will be necessary to amend this situation and to order the partial opening of ports in order to enable the permitted navigation activities to be carried out at the various stages. This opening, in the current situation, can only be decreed by the Government of Spain, and we ask for clarification as to whether it will be carried out simultaneously with the start of the deceleration plan in its phase 0. Phase 0.

In this phase only individual navigation in the waters of each island (and we understand that of each province) will be permitted for federated athletes resident in the same municipality in which the boat is located. In this regard, a number of issues have been raised on which we understand that an express clarification is needed: this announcement, together with the measure that comes into force today by authorizing the practice of sport individually (whether or not it is federated) on the public road and at restricted times, has caused situations such as that the Balearic Federation of Vela emitise a statement according to which, the sportsmen who have been established on the same day can only carry out sailing training from 06: 00 to 10: 00 hrs, and from 20: 00 to 23: 00 hrs, which are hours in which there are normally no time in which there are no more of the sport, but which would be no more than it would be no longer be possible to practice, in the matter of the sport, which would not be no longer be possible, in the sport, and which would be no longer be in the matter of sailing.

The logic dictates that, as it is sports practiced by non-professional federated athletes, and to develop in circumstances in which the safety distance is more than assured, the nautical sports could be practiced in a range of times conducive to them, and for periods long enough to be able to take into account the times necessary to leave the port waters, assembly and disassembly of gear, candles, etc.... We are therefore interested in clarification on this particular.

Fishing to use: except for cruise navigation, it is very common for federated athletes to use rowing or sailing boats, among others, belonging to nautical clubs, sailing schools, etc... with which they normally train. We therefore ask for clarification as to whether those non-professional federated athletes who wish to practice water sports may do so with vessels other than their own, or that of sailing clubs or schools, etc.... and, if the response is positive, the procedure is established to ensure safe access to such vessels, as well as for their assembly and disassembly, understanding that it is best to leave the organization of such tasks to the water sports clubs and schools, which are best aware of their facilities and capabilities. Displacement: once again, in view of the measures that come into force today, there are doubts about this.

For example, we have received consultations such as what happens in case my port is more than 1 km from my home, can I move to it? Can I use the car to move to the port?, if I have a light sailing or rowing boat, can I take it to the port with a car and a trailer? In addition, we want to make the same consideration with regard to the difference between the municipality of residence and the municipality in which the vessel to be used is found that we have made when talking about the basic security visits. We therefore request clarification on these points.

Fases 1 and 2 - We group these phases because the considerations and points we understand need clarification are applicable to both.

Composition of the groups: Since in phase 1 the opening of terraces, as well as of hotels and tourist accommodation, we believe that the groups that go out to sail should not necessarily be by people from the family core or living in the same house. While, in the event that the exit involves overnight on board, in phase 1 certain regulations could be established to those who can spend the night on board, or the distribution of the cabins. We request clarification on this point for phases 1 and 2. Displacement: Given the distribution of the ports in our geography, and that in phase 1 the opening of hotels and tourist accommodation for guests of the same province is expected, we believe that users should be able to travel to the ports even if they are in another municipality, but within the same province or island in phase 1.

In phase 2, the movement to other islands or provinces could already be allowed within the autonomous scope. We also request clarification on this point. Scope of navigation: The very nature of recreational navigation makes it virtually impossible to restrict its scope to the waters of a single municipality, sometimes a single province. For example, on a single board through the Bay of Palma we can sail through adjacent waters with waters of Calviá, Lluchmajor and Palma de Mallorca; or in cases like that of the river of Arousa, in a dyeing with five or six bords we could change from province so many times. We therefore believe that, depending on the phases, the possibility of touching land first in ports of the same municipality, then island or province can be restricted.

Phase 3 - At the same time, the landing on the coast should be governed by what is established for the opening of the beaches. However, it should be possible to land without going down any place on the island or province and then from the autonomous community or other islands, until it reaches phase 3. We therefore request clarification on this point.