Hearing: Draft regulations relating pilotage services in Svalbard

Transcription

1 Kystverket Postboks Ålesund Your ref: 2011/6178 Our ref: Longyearbyen, Hearing: Draft regulations relating pilotage services in Svalbard Reference is made to your letter of February 6 th 2012 with announcement of the proposed regulation for pilotage service in Svalbard. AECO and expedition cruise activity in Svalbard; numbers The Association of Arctic Expedition Cruise Operators (AECO) is an international association for Arctic expedition cruise operators dedicated to managing responsible, environmentally-friendly and safe tourism in the Arctic. The association presently has 23 members, including 16 vessel operators and ship owners. Approximately 20 expedition cruise vessels involved in Svalbard operations are associated with AECO. This represents close to 100% of the expedition cruise activity in Svalbard. Expedition cruise itineraries vary a great deal. Embarking in Longyearbyen circumnavigating Spitsbergen and Nordaustlandet (when ice conditions allow) - and disembarking in Longyearbyen are probably the sailing plans most often carried out. The following are some examples of other expedition cruises commonly operated in Svalbard: Embark Tromsø Bjørnøya East Svalbard North Spitsbergen Longyearbyen South Spitsbergen disembark Reykjavik Embark Tromsø South Spitsbergen disembark Longyearbyen Embark Longyearbyen northwest corner and north Spitsbergen Hinlopen/Sjuøyane disembark Longyearbyen Embark Longyearbyen northeast Spitsbergen east Greenland disembark Reykjavik The cruise length also varies. Only one vessel has for several seasons carried out a 3.5 day cruise on the west-coast of Spitsbergen. The rest of the vessels conduct cruises lasting from one weeks (7 24 days). Members of AECO brings app visitors to Svalbard annually. This may represent a capital turnover of more than NOK 200 mill in local and national economies. Association of Arctic Expedition Cruise Operators P.O. Box 103 N-9171 Longyearbyen - Norway Phone Fax Cellphone frigg@aeco.no Org. no

2 Representation When considering this draft regulation AECO has discussed if individual comments from each affected operator and vessel owner should be submitted in separate letters to Kystverket. This is to underline the serious consequences this regulation would have for our industry and the individual operators. We have decided to submit comments on behalf of all members but ask that Kystverket recognizes the 23 affected parties and voices behind these comments, whose names are listed under the signature. We will also touch issues related to conventional cruise traffic as the regulations this part of the industry will be subject to, will influence on the tourism industry as such, as well as the local community in Svalbard. Preliminary comments AECO does not object to regulations aiming at safeguarding life, safety and the environment in Svalbard as long as the regulations are necessary and introduced after a thorough process including dialogue with affected parties, consideration of consequences and balancing of costs and effects. This is not the case for this proposal. This draft regulation will have very serious and for many, perhaps devastating consequences for the expedition cruise industry in Svalbard if introduced as proposed. We will demonstrate some of the consequences in the sections below. We will however start by expressing our concern and surprise over the lack of involvement of the industry and consideration of consequences prior to the public hearing. We are not under the impression that this is due to reluctance from Kystverket s side and we are appreciative of the meetings held on our initiative. But this proposal is extremely hasty and lacks a serious and thorough consideration of consequences. AECO, who has previously been informed that introduction of the Pilot Act in Svalbard would have minor impact for the expedition cruise industry, was presented with the first draft regulation at a meeting January 5 th There had not been any dialogue between Kystverket and AECO ahead of the meeting, nor had any information in writing reached AECO. We would also have expected requests for information from our side, but had not been asked to provide any facts or statistics in this regard prior to the proposal. On AECO s request a telephone conference between Kystverket and AECO took place January 16 th We were taken very by surprise at the meeting January 5 th and immediately made a new contact for further dialogue with Kystverket. The telephone conference resulted in some adjustments before the draft regulation was sent on public hearing February 6 th, but not close to what is needed if a continuous expedition cruise industry is still welcomed in Svalbard. The draft regulation had been presented to the Ministry of Fishery and Coast and for the Inter- Ministerial committee on Polar Affairs between our conference January 16 th 2012 and the hearing February 6 th We are amazed by how fast such a major proposal could be handled by all these authorities, as this all happened within a couple of weeks. Adding that the final decision is due by June, and the regulation to be put into force by July this year, it is an extremely hasty process and one that probably is not justifiable. 2

3 AECO suggested that that cruise industry was invited to an information-meeting and such a meeting took place in Oslo, March 21 st 2012 The interest for the meeting with between 20 and 30 international delegates from the cruise industry demonstrates the seriousness of the matter. The meeting also revealed the great need for information, as very many of the delegates had not fully understood the proposal. The concerns expressed by the attendances are valid and further add to our great worry. At the meeting, representatives from Kystverket, at some point gave information that could give the impression of a practical handling of the regulations which does not quite correspond with what we understand from the written proposal. It is not clear to us whether a different practice is based on an extensive use of exemptions or has another background. It is however difficult for an industry like ours to base our activity on practical handling that is different from the written regulations and which we are not familiar with. Our comments are therefore based solely on the written proposal. The proposal includes a description of anticipated administration and cost of a Pilot service in Svalbard. It does not, however, describe which consequence it will have for the affected parties. These will be consequences not only on an individual level but regard full industries and most likely communities. We are greatly concerned that if this information is not made available for the decision-makers, the full picture and the consequence of their decision will not be understood before it is too late. We would also like to add that the proposal, even before enforced, has consequences. Shipping companies are unable to complete new contracts as they cannot guarantee Pilot Exemption Certificates (PEC) for their navigators. As the costs of operations without PECs are unbearable for expedition cruise operators, companies are already planning for changed itineraries and operations elsewhere than Svalbard. For the conventional cruise vessel operators the situation is similar and the pilot requirement has emerged simultaneously with a heavy fuel oil prohibition making voyages to Svalbard non-viable. Applying the same regulations as in mainland Norway An objective for this proposal is to apply the same regulations in Svalbard as in mainland Norway with some local adjustments. We believe this should have been subject to a much more careful consideration before proposed. Svalbard is in many ways very different from mainland Norway. Coastal waters in Svalbard counts for almost square kilometers whereas coastal waters in mainland Norway counts for approximately square kilometers. The sailing distance around Svalbard is 650 nautical miles. This is the same distance as sailing between Brønnøysund and Kirkenes and longer than half of the Norwegian coast. Norway has 3 pilot centers and 16 pilot stations. Except for a station connected to the coal transportation from Sveagruva, one pilot station is proposed in Svalbard. This may be enough given the traffic in Svalbard, but far from enough to cover the geographical area in question in a user-friendly and cost efficient way. As cargo vessels and coal transportation finds place in specific marginal areas, navigators on these vessels will probably not have major problems with either obtaining PECs or meeting 3

4 the costs of pilots. The fishing fleet is less than 70 meters long and the inspection vessels probably qualify for PEC. The drastical consequences of this regulation hit the cruise industry. This is an industry with a sailing pattern that is quite different from the above mentioned and the expedition cruise sailing patterns in Svalbard are not very comparable with sailings patterns in mainland Norway. The cruise season in Svalbard is short. The main season is between mid June and mid August or approximately two months. Only a few have itineraries after August. This short sailing season presents challenges both in regards to building up practical experience to apply for PEC and in regards to pilotage services capacity during a hectic season. It also questions the capacity to conduct PEC practical tests. Drift ice is normal in Svalbard waters, also during summer. The proposal includes sailing corridors around the archipelago. These corridors will only be possible to follow as long as the waters are ice-free. Drift ice moves quickly and it will be impossible to avoid ice and keep to the corridors at all times. This also concerns the pilot s service onboard. Once in ice, the master takes over navigations. Overall review of present Norwegian pilotage service The Norwegian Government has recently decided to carry out an overall review of present pilotage services in Norway. Various circumstances call for such a review and the Government would like to focus on a future-oriented, costs-efficient and user-friendly pilotage service in Norway. It is acknowledged that present pilotage service in mainland Norway has major challenges. A working-group, with representation from interest groups has been given the assignment to complete an Official Norwegian Report (NOU) due by late It is not reasonable that a pilot service that in mainland Norway already under review due to major challenges, is introduced in Svalbard. Suggestion AECO would like to propose that introduction of the pilotage regulations in Svalbard is postponed until the Norwegian pilotage service has been evaluated and the NOU has been submitted. Qualified pilots and capacity problems In mainland Norway the demand for pilots has lately been higher than Kystverket can meet. Kystverket informed about the situation on their own web-site June 29, 2011, stating: Kystverket is experiencing challenges in regards to meeting all needs for pilots. The situation varies from region to region, but in regions with high activity, the challenges are relatively large. 4

5 The proposal is based on using pilots from mainland Norway in a situation where there already are capacity problems. In addition, these pilots will need to time to sail up experience to pilot in Svalbard waters. An issue is also that Kystverket has based the proposal on a future where the expedition cruise vessels will not be needing pilots but have PECs. If the expedition cruise industry will not qualify for PECs, the dimension of pilot service may be very much too small. On the other hand, as we will explain in a later section; if the expedition cruise industry will not operate with PECs and the regulation is put into force, there will be little left of the expedition cruise industry in Svalbard. Suggestion Again we would like to appeal to a postponement and further investigations and consequence analyses before introducing these regulations. There are so many question-marks and hesitations that need considerations before the regulations can be passed. A postponement would also give time to build up the pilot s competence. If a dialogue is established with the cruise industry we are under the impression that the industry would be willing to co-operate in this regard. Pilot exemption certificates (PEC) We have been informed that it is an objective to provide the expedition cruise industry with PECs. The proposed requirements to apply for PEC include: An applicant for a pilot exemption certificate must hold a deck-officer certificate which is valid for the vessel or vessels to which the application for a pilot exemption certificate relates. The applicant must have at least one year s effective service as a duty navigator in Polar waters whereas at least 6 months includes the waters or areas to which the application for a pilot exemption certificate relates, or where the certificate shall apply, or Have completed the midshipman pilot exemption certificate programme for the waters or areas to which the application for a pilot exemption certificate relates, or Been responsible, during the two last sailing seasons, for navigation during a total of at least six voyages in each direction in the waters or areas to which the application for a pilot exemption certificate relates. The voyages must have been undertaken with the vessel or vessels to which the application for a pilot exemption certificate relates, or with an equivalent vessel. The applicant shall demonstrate that he/she has sufficient knowledge of ice navigation and the weather conditions on Svalbard. The applicant shall demonstrate that he/she is sufficiently skilled in ice navigation. We have some questions related to these provisions: The nature of expedition cruising in Svalbard is mostly circumnavigations. Except for sailings in and out fjords, how does Kystverket picture that the industry can comply with at least six voyages in each direction? 5

6 What is considered one voyage? The time spent in one general area can vary a lot from one vessel/operation to another. Will a voyage lasting two weeks count the same as a voyage lasting one week if they sail the same general areas? What is the definition of polar waters in regards to sailing experience? How does one demonstrate sufficient knowledge of ice navigation and weather conditions? How does one demonstrate sufficient skills in ice navigation if there is no ice in close vicinity? Expedition cruising by nature includes itineraries changes from one voyage to another. If a navigator has sailed six voyages during the last two seasons, it is likely that the route has been different from voyage to voyage. After the meeting in Oslo, AECO asked our members to list their navigator s competence to clarify if they will be able to comply with the requirements as proposed. We have also added a question related to general consideration of the navigators competence given that they are unable to meet the requirement for PEC. The expedition cruise industry is not able to comply with the regulations as proposed. This table represents navigators connected to 14 expedition cruise vessels in Svalbard. They are of the most experienced polar navigators in the industry. Captain/navigator Months of experience in polar waters Alternative 1 Alternative 2 Months of experience in Svalbard waters Number of sailings in the area PEC is required during the last two seasons Does this persons experience meet the requirement for PEK as described? Captain A yes Captain B yes Chief Off. C yes Chief Off. D no yes Chief Off. E no no 2nd Off. F no yes 2nd Off. G no yes 2nd Off. H no yes Master I > no yes Master J > yes Master K 48 0 new vessel 0 no yes Master L yes Master M 42,5 42,5 14 yes Master N 42,5 42,5 14 yes Captain O 9,5 9,5 n.a. no yes Chief P 6 6 n.a. no yes Chief Mate: Q 6 6 n.a. no yes Captain R 36,5 3,5 2 no yes Captain S no yes Captain T no yes Captain U 22,5 2,5 2 no yes Chief Off. W no yes Chief Off. X 8,5 1 0 no yes Chief Off. Y no yes If the formal requirements cannot be met, in your opinion does this person still qualify for sailings in Svalbard waters? 6

7 Chief Off. Z no yes Chief Off. AA no yes Captain AB no yes Captain AC yes Captain AD yes Captain AE yes Captain AF no yes Chief Mate AG yes Captain AH no yes Capt AI no yes Capt AJ no yes C.O AK no yes C.O AL no yes 1.off AM no yes 1.off AN no yes Nav off AO no yes Nav off AP no yes Capt. AQ 36,5 3,5 2/1 no yes Capt. AR no yes Capt. AS no yes Capt. AT 22,5 2,5 2/1 no yes Chief Officer AU no yes Chief Officer AV 8,5 1 0 no yes Chief Officer AX no yes Chief Officer AY no yes Chief Officer AZ no yes Important to note: If the requirement will be voyages in each direction, none of the above navigators will be compliant. The table shows that of 50 navigators only 11 fulfill the proposed requirement for PEC ( each direction not regarded). This can but does not necessarily mean that they are qualified for all areas. As the table also shows, they have extensive polar experience and in the industry s opinion all but one are qualified to sail in Svalbard waters. By the nature of expedition cruising, these vessels operate in areas not only in Svalbard that are not well charted. The experienced navigators depend on their diverse experience and knowledge to navigate safely in these areas. The navigators are given many tools to reduce the risk in these areas and e.g. sonar as well as zodiacs fitted with depth sounders that can help detect unknown objects around the vessels are commonly in use. They also share charting information and perform extensive passage planning with risk assessments and mitigation measures. A concern for those who are qualified for PEC in certain areas is how can they built up experience in additional areas, e.g. in Eastern Svalbard within a reasonable administrative and economic frame? Another concern is the number of PECs needed to carry out a voyage with the officer rotation and the risk of illness among officers. For medium size vessels at least four PECs will be needed to meet the requirements. Adding to the concern for present navigator s ability to meet proposed requirements, we are deeply concerned about the future. New navigators, new vessels and new operators will not be able to build up competence to meet these requirements. With this proposal and associated pilot costs, even for a shorter period of time, this is prohibitive for most of our members. 7

8 The smaller the vessels are the more difficult it will be to comply with the regulations, both in regards to the number of navigators with PEC needed, and in regards to building up competence among new navigators. Suggestions subject for further discussions Given the limited time to consider potential solutions and lack of discussions with Kystverket, AECO does not have a categorical opinion on which solutions could work. An alternative which could be further discussed is that the formal requirement to be eligible for Pilot Exemption Certificate in Svalbard waters could be divided into two main steps; personal and operational Personal requirements: o 12 months effective service as a duty navigator in Polar Waters, of which at least o 2 months effective service as a duty navigator in Svalbard Waters, or o 3 voyages; responsible for navigation during a total of at least three (3) voyages within the area for the PEC during the two last sailing seasons. Operational requirements; o Voyage plan for the intended cruising route under ideal ice conditions, including a map showing the area. o Risk assessment document for the intended cruises o Vessel particulars and equipment list specific for polar water operation (to be verified during the test) o Polar Water Operation Manual (to be verified during the test) The detailed voyage plan, in the form of a map or chart for an intended optimum cruise will clearly specify areas for the PEC. The risk assessment will indicate what knowledge the operators have of the hazards in the area concerned and what mitigation steps are taken to minimize the risks. Svalbard waters require special knowledge both from the navigator and ship operators to fully mitigate from all the risks. Therefore it might be worthwhile for the operating company together with the deck officer to apply for a PEC as a group. This procedure would be in line with the ISM code where the integration between vessels and home office is vital for safe operation. Even if Svalbard waters are unique the same navigation techniques are used there as in all other polar waters. There are many common issues and therefore a well established safe navigation routine for polar waters works very well in Svalbard. 8

9 PEC application and test The PEC-application requires documentation of previous experience. To some extent navigators may have challenges in getting documentation if they have changed employers and not at least if the employer has ceased to exist. The practical test requires a pilot onboard. It is a problem if such a test will interfere with schedules and the income for an operator. If a vessel for example looses a day or has to sail long detours, it could have tremendous impact on profit. Furthermore, if the test requires the pilot to stay onboard for more than hours he or she will be entitled to a cabin. For the small expedition cruise vessels every cabin represents a source of income. Even if the pilot will only need the cabin for one day, the cabin will be unsellable for the full cruise and income lost for an average of two guests for the full cruise. This represents between NOK and NOK in income. The problem grows as the vessels shrink the smaller the vessel the larger a problem. Adding to this is the only one pick-up/drop-off area in Isfjorden. If the vessels is scheduled to leave Isfjorden while the navigators conduct the test, the vessel will have to return to let off the pilots which will interfere with the itinerary and of course cost the company. Several of our members have already stated that there is no way they can carry such costs. Suggestions subject for further discussions Again, given the limited time to consider potential solutions and lack of discussions with Kystverket, AECO does not have a categorical opinion on which solutions could work. But alternatives for further discussions could be: With well prepared documentation of the application for the PEC the practical test would be a confirmation topic, a survey, and should not require more than a few hours onboard for the examining pilot. This test could be executed during a stop in any Norwegian port, most likely in Tromsø for most operators when the Pilot Act is in force. Initially most of the operators could apply for this PEC the season before the final implementation of the act and then it could be done in Longyearbyen. Pilotage expedition cruise vessels As illustrated and explained above, the expedition cruise industry is unable to meet the requirements for PEC as proposed. The alternative is to carry a pilot. It is our understanding that the proposal (and the picture of administrative and economical consequences) is based on a presumption that the expedition cruise industry will qualify for PECs. If the expedition cruise industry needs pilots, the description in this proposal will not correspond with the reality. The number of pilots needed will be quite different than has been anticipated. 9

10 The expedition cruise industry s sailing pattern and nature is explained in the introduction of this letter. From the description it can be seen that if the expedition cruise vessels must carry pilots, the need will be two pilots 24/7 as long as the vessel is sailing in Svalbard waters. The table below does not include the pilot readiness fee or other fees, but is based on cost of the pilot(s) only. The costs are also calculated with the assumption that the minimum 12 hours use of pilot per day is what is necessary. If the vessel needs more pilotage, the costs will be higher. The cost per season is based in an average of 45 days in Svalbard waters, but we would like to emphasize that the sailing season is longer for some and shorter for others. All vessels connected to AECO with operations in Svalbard are listed. Vessels Pax Meters GT 12 hours 1 Pilot 1 day 2 pilots Cost per season Polar Pioneer Bremen Hanseatic National Geographic Explorer Noorderlicht (veteran)? Antarctic Dream Ortelius Plancius Stockholm Quest Ocean Nova Nordstjernen Southern Star Shorter than 24 m Expedition Akademik Sergey Vavilov Fram Silver Explorer Antigua (veteran?) Clipper Adventure Albarquel 8 Shorter than 24 m Significant costs from lost sale of one cabin are additional. If you use Plancius as an example and assume that the 45 days represent 5 cruises, the total costs for Plancius will be: 45 days with pilots: Pilot readiness fee 27,90 x 3434 BT :2 (Svalbard short season): Loss cabin which cannot be sold TOTAL COSTS These costs must be shared by the passengers cruise ticket. Plancius can carry 116 passengers and an average of 100 passengers can be expected (also due to single cabins). A total of 500 passengers (5 voyages x 100 passengers) must share the costs if the vessel uses full capacity. 10

11 Under optimal circumstances and 100 % berths filled, the extra cost each passenger has to carry is close to: If the use of berth capacity is, for example 70 %, the extra costs will reach NOK per ticket. NOK per ticket For small vessel with maximum capacity 30 passenger the extra costs will be more than NOK per ticket We hope we by this have made it very clear that this industry is unable to carry the costs of a pilot service as proposed. A solution with PEC is the only alternative for a future expedition cruise industry in Svalbard. Suggestions We are back to the previous sections and our proposal to postpone the introduction of the Pilot Act and give time to discuss practical solutions for the PEC scheme. Pilot readiness fee Kystverket has acknowledge a short sailing season in Svalbard and therefore proposed a 50% reduction of the Annual pilot readiness fee. Again we point to the fact that the cruise season in Svalbard for most operators is shorter than three months. This is only three months for the operators to earn income to cover the costs. We ask that the pilot readiness fee be calculated in accordance with the actual need. A question related to the pilot readiness fee is what the industry actually is paying for. Given the distances in Svalbard and only two pilot stations, how fast and how can the pilots respond if the vessel is in, for example, Eastern Svalbard? Sailing descriptions NCA has presented a map with sailing-descriptions for Svalbard. We believe that a comprehensive voyage plan could serve better than just referring to a map with lots of traditional pilot routes that unfortunately are not relevant in ice covered polar waters. The traditional route Freemanssund -westside of Edgeöya - Hopen is missing If Svalbard should have any description it would perhaps be better to define regions with specific circumstances. If this is something Kystverket would like to discuss further, we could come up with suggestions based on extensive sailing experience from the areas in question. 11

12 Pilotage conventional cruise vessels The largest vessels organized by AECO are smaller than any conventional cruise vessel. The conventional cruise traffic has a different sailing pattern and different needs than the expedition cruise vessels. Typical sailings with conventional cruise vessels last 2 2,5 days and include a call in Magdalenefjorden and perhaps one of the settlements, most likely Ny-Ålesund or Longyearbyen. With the proposed pick up/drop off areas in Isfjorden only, these vessels will be subject to significant extra sailing hours and costs if pilots are required in Magdalenefjorden. These requirements come simultaneously with a heavy fuel oil prohibition which is expected to have major consequences for the cruise traffic to Svalbard. When a similar heavy fuel oil prohibition went into force in Antarctica, the decline in visits from conventional cruise vessels were calculated to more than 60%. We urge the authorities to reconsider the Pilotage requirement at this point in time. A major decline in the conventional cruise traffic to Svalbard will have significant effects on the local communities (loss of income in all settlements; Ny-Ålesund, Barentsburg og Longyearbyen). Ny-Ålesund s loss of income from cruise traffic will probably need to be covered by larger allocation over the national budget. Suggestions The main objective with this proposal is to ensure safety when sailing in Svalbard waters. If the authorities would like to also ensure reasonable framework for the cruise industry there are other options. By establishing pilot free corridors to Longyearbyen/Barentsburg, Ny-Ålesund and Gravneset in Magdalenefjorden, some industry needs can be met. If deemed necessary, other measures can be implemented. This includes instructions, limitation, sailing marks and the request for equipment such as forward looking sonars. Other issues of concern The consequence for the expedition cruise industry will also be significant if the conventional cruise traffic to Svalbard declines drastically. Costs connected to harbors in settlements will most likely be transferred to other users, and largely to the expedition cruise industry which is a frequent user. Many jobs and services will be affected. This includes not only transportation such as airline regularity, local transportation, pubs/restaurant, hotels and attractions, but also related jobs at shops, service providers and in administration. Tourism is one of the desirable industries in Svalbard, which has been repeatedly stated in white papers over the last decades. Coal mining is another. It is also an issue that the future of coal mining in Svalbard is uncertain. It is questioned if there will be new mines opened and if not, the end of the coal mining history in Svalbard is only years ahead. If so, 12

13 there will be an even higher need to ensure adequate conditions for the other industries in Svalbard, tourism being one of the most important. The expedition cruise industry has during the last five years been subject to a number of new regulations which has had varying effects. Some of them have involved costs and made a marginal industry even more marginal. Recent years the so-called Eastern Svalbard issue has been critical for the industry. The matter has yet to be concluded. In addition the International Maritime Organization (IMO) is presently working on a proposal for a mandatory Polar Code. Norway is chairing this working-group. The Polar Code will also have major consequence for all the passenger vessels sailing in polar areas, but will also add to safety. An additional effect of introducing this regulation as proposed with the described consequences will be the lack of a future for AECO. A crucial part of AECO s income comes from cruise operations in Svalbard. Without these operations and members the association will not have a future. The concern for such a development is not related to employment, but to the loss of cooperation in this industry which among other things has lead to a number of self-imposed regulations, routines and coordination safeguarding the environment as well as safe maritime and terrestrial operations in Arctic areas. We also believe that the competence the navigators listed above and others within our industry have (including the few with competence in Eastern Svalbard) - and the presence of these vessels in the Norwegian Arctic, are of value. A changing climate will lead to more traffic in Arctic regions. We urge the Norwegian government to help safeguarding this experience and this industry and not locking the door on present and future activities. We kindly ask that Kystverket and superior authorities recognize the challenges of this industry and appreciate the arguments raised. As mentioned introductorily, we do not object to necessary regulations ensuring safety. But it must be reasonable, balanced, and as a result of thorough work and consideration. We are very interested in discussing solutions. Summary Postpone enforcement of the pilotage regulations in Svalbard. - And Wait for the NOU regarding the pilot service in Norway - Then Collect more data and facts about the different industries Consider alternatives to transferring the legislation from mainland Norway Acknowledge local condition including distances Consider industry consequences of alternative regulations Discuss potential solutions with the industries. 13

14 Lastly we would like to stress the fact that this proposal already has consequences for the cruise industry with reluctance to sign new contracts. At the same time we have been informed that operators already are planning for alternative geographical areas in case this regulation is passed as proposed. We therefore kindly ask that any changes in regards to time schedule or content are communicated as early as possible. This may be more than important to parts of our industry. Thank you for the opportunity to comment on this hearing. Kind regards, Frigg Jørgensen General secretary Representing: Aurora Expeditions Hapag-Lloyd Kreuzfahrten Lindblad Expeditions Oceanwide Expeditions Origo Expeditions Polar Quest Expeditions Spitsbergen Travel 69 Nord G-Adventures Quark Expeditions Hurtigruten Silversea Cruises Tallship company Albatros Travel Albarquel Expeditions Heritage Expeditions Pole Position Poseidon Expeditions Äventyrsresor Beluga Adventures Eyos Expeditions Scandinavian Bunkering ISP Cc: Governor of Svalbard Ministry of fishery and coastal affairs Ministry of justice and public security polar affairs department Ministry of foreign affairs special advisor polar affairs Ministry of trade and industry European Cruise Council (ECC) Cruise Liners International (CLIA) Cruise Norway Svalbard Tourism Svalbardposten 14