The only specialised marine publication in Oceania that focuses on the maritime industry, from super yachts to small craft to large commercial ships, including coastal shipping, tugs, tow boats, barges, ferries, tourist, sport-fishing craft
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NZMTA NEWS SERIOUS TIMES AHEAD FOR INDUSTRY NOTE FROM THE PRESIDENT JEREMY WARD I welcome Margaret Wind as the new executive officer for the Marine Transport Association. For many, Margaret will need no introduction because of her experience and work in safe ship management and her past support for the MTA. I would also like to acknowledge Alan Moore, our outgoing executive officer, who is taking a step back to enjoy many of the fruits of his labours as both he and Jackie depart on a world cruise. We thank Alan for his efforts and commitment that has carried the association through some very challenging times. T he Marine Transport Association enjoyed a busy month throughout March, hosting the increasingly popular Marine Transport Operator Seminar in Taupo. Many of the country's top fleet and independent operators were in attendance and enjoyed an excellent line-up of speakers covering tourism, safe ship management issues, maritime law topics, the Rena, and foreign charter fishing vessels. These seminars are held two or three times a year and provide an excellent opportunity to network with peers and senior Maritime New Zealand staff. For many it was the first opportunity to meet the new Maritime NZ director, Keith Manch. Despite entering our industry in what some may term as a baptism of fire, his interest and knowledge of the issues facing our industry are refreshing and we look forward to a much-improved dialogue. Key developments affecting our industry at present are the QOL's and MOSS programmes. The director confirmed that both will be going out for consultation with the industry in the next few months with a targeted implementation date of April 1, 2013. This is a crucial development, and it is imperative that operators get involved in understanding the impact these rules will have on their business. The MTA will be looking hard at transition costs and timetables, with particular interest in the regulatory impact statements. These are key to most of us who operate commercial vessels. There is radical change ahead and we must ensure the proposed and significant cost increases will result in a tangible benefit for us all. MOSS Maritime NZ revealed a little of what is proposed in the transitional stage of SSM to MOSS and it could involve a maximum two year transition timetable and a cost of $2000 application fee per operator for a Marine Transport Operator Certificate. These will replace the SSM certificates and last for 10 years. There will however, still be a requirement and additional cost for the independent survey work to move from two yearly to two-and-a- half yearly and, a three-yearly audit by Maritime NZ. These are all chargeable visits and are in addition to the application costs for any exemptions, crewing documents, load line certificates etc. The apparent savings being promoted by Maritime NZ are in the area of surveying. However, this does not appear to be the case when you consider that surveyors will still need to cover their fixed costs and as a consequence of losing their audit income, will 66 Professional Skipper May/June 2012 BY MARGARET WIND, EXECUTIVE OFFICER, NEW ZEALAND MARINE TRANSPORT ASSOCIATION have no choice but to raise their hourly rate. MNZ and QOL: Innovator or used car salesman? After a lengthy consultation period the new QOL framework was announced on July 1. It was intended to replace an archaic and creaking qualifications framework that had remained largely unchanged since 2001. The purpose of QOL or QOLFs is laudable. The key selling points include relevance to industry and a focus on competence rather than sea service; all within a clear and logical framework. The transition involves a tidy up of legacy qualifications in terms of converting them to new ones. We are told that holders of existing qualifications will not be disadvantaged. So far so good. As is commonly said with large-scale change, the devil is often in the detail and in the case of QOLF the available detail contains an almost singular focus on the advantages of the new framework and precious little on the costs, transitional provisions and what those with the most common qualifications such as LLO/ILM might end up with, once the dust settles. This is a little like being asked to commit to the purchase of a nice looking car, but without being able to look under the bonnet and at a cost that the dealer makes up as he or she goes along. Would any sensible person agree to this? If nothing else, the QOL process thus far certainly seems at odds with current government regulatory policy. According to the government's Statement on Better Regulation, regulatory This raises the possibility that a number of skippers may lose their certificates and their livelihoods as a result. decisions should only be made when "all implementation issues, costs and risks have been fully assessed and addressed". In this regard, Maritime NZ appear to have usurped a ministerial prerogative in terms of their decision to implement QOLF from April 2013, and with seemingly scant regard for basic government regulatory requirements. Certainly, Maritime NZ will have to produce a set of draft rules and regulatory impact assessment at some point between now and next year for the purposes of public consultation, prior to implementation in April. Will this seemingly impossible timeline allow for a full consideration by the maritime industry of the hitherto unknown costs and risks associated with transitioning to the new framework? This seems highly unlikely. Perhaps we could just take things on trust? Arguably no, and here are some reasons why. As things stand, the transition provisions appear ponderous and fraught with risk. Maritime NZ claims it is going to process around 11,000 qualifications "individually" over a five year period. Why Maritime NZ have elected to adopt this peculiar and unwieldy process, rather than automatically transition the bulk of current certificate holders to a level that most closely matches their current privileges, and deal individually with special cases, is anybody's guess. Current certificate holders have every right to be deeply concerned over this process. For example, those transitioning