Vedlagt høringsuttalese fra Svalbard Integrated Arctic Earth Observing System.
Longyearbyen, 22 April 2022
Innspill til høring av forslag til ny forskrift om sikkerhet i felt mv. på Svalbard og forslag til ny forskrift om pakkereiselovens anvendelse på Svalbard (New field regulations in Svalbard)
To whom it may concern,
we appreciate the possibility to comment on the proposed new field regulations in Svalbard.
Svalbard Integrated Arctic Earth Observing System (SIOS) is an international partnership of research institutions studying the environment and climate in and around the Norwegian archipelago Svalbard to develop an efficient observing system, share technology, experience and data, close knowledge gaps and decrease the environmental footprint of science.
The proposed field regulations will have a considerable impact on research activities in Svalbard and as a Norwegian lead consortium with many international members we regret that the Ministries made the decision to not translate the consultation document into English as this excludes a large fraction of the research community in Svalbard from contributing to the hearing.
We would like to highlight special aspects of two important research locations and at the same time acknowledge that the document opens for ‘local adjustments’ (§2 second paragraph):
The planning area 10 is currently used as the boundary determining when research activities are subject to permit. Thus, m any research activities are currently located in planning area 10. We call for a better impact assessment of the removal of planning area 10 in connection with research activities, e.g.
Comments to specific suggested changes:
The definition ‘individual travellers’ for researchers and students that have non-work related activities outside inhabited areas poses a challenge to most scientific field groups, as it in reality would prevent recreational activities for participants of field campaigns irrespective of the duration of their field stay. Since participants of scientific field activities generally have conducted systematic safety training, we suggest that the use of framework permits in this contest could be a good solution.
§11 Protection against polar bear attacks
§13 Requirements for individual travellers’ traffic, activity, and other stay outside planning areas
§14 Search and rescue insurance
There are many uncertainties (availability of relevant insurance products in different countries, costs and who will cover those, validity and overlap of insurances (when does a work activity start and end), etc.) connected with the distinction of activities by research group participants between field activities and individual travelling (see also comments to §3) and the proposed requirements for insurance. It seems unlikely that these uncertainties can be clarified in the short time frame anticipated (implementation of the new regulations in January 2023). We, therefore, suggest to revise this section and/or allow transitional arrangements until all implications of the proposed new regulations are clarified in detail.
§15 Application for permit of travel, activity or stay
The proposed requirement for permit applications for all activities outside areas with an approved area plan will heavily increase the number of applications for scientific field activities and will increase the bureaucratic workload of research institutions. The requirement to apply 8 weeks ahead of fieldwork is unrealistic for most of research activities as their timing depends on fast changing environmental conditions, as e.g. weather and snow conditions.
We welcome the usage of electronical application portals, but would like to stress the importance of easy access to such a portal also for non-Norwegian citizens (e.g. alternatives to the usage of Bank ID and similar as login).
§24 Implementation and changes
In the light of the uncertainties described above and the need to clarify those, especially in connection with the research stations in Ny-Ålesund and Hornsund, we see the ambition to implement the new regulations already January 2023 as unrealistic. We are also concerned that the large amount of expected additional permit applications cannot be met in a timely manner due to lack of resources at the Governor’s office, resulting in the need to cancel already planned field activity if permits are not received in time – which may jeopardise both long-term measurements as well as field campaigns.
Longyearbyen, 22 April 2022
Innspill til høring av forslag til ny forskrift om sikkerhet i felt mv. på Svalbard og forslag til ny forskrift om pakkereiselovens anvendelse på Svalbard (New field regulations in Svalbard)
To whom it may concern,
we appreciate the possibility to comment on the proposed new field regulations in Svalbard.
Svalbard Integrated Arctic Earth Observing System (SIOS) is an international partnership of research institutions studying the environment and climate in and around the Norwegian archipelago Svalbard to develop an efficient observing system, share technology, experience and data, close knowledge gaps and decrease the environmental footprint of science.
The proposed field regulations will have a considerable impact on research activities in Svalbard and as a Norwegian lead consortium with many international members we regret that the Ministries made the decision to not translate the consultation document into English as this excludes a large fraction of the research community in Svalbard from contributing to the hearing.
We would like to highlight special aspects of two important research locations and at the same time acknowledge that the document opens for ‘local adjustments’ (§2 second paragraph):
The planning area 10 is currently used as the boundary determining when research activities are subject to permit. Thus, m any research activities are currently located in planning area 10. We call for a better impact assessment of the removal of planning area 10 in connection with research activities, e.g.
Comments to specific suggested changes:
The definition ‘individual travellers’ for researchers and students that have non-work related activities outside inhabited areas poses a challenge to most scientific field groups, as it in reality would prevent recreational activities for participants of field campaigns irrespective of the duration of their field stay. Since participants of scientific field activities generally have conducted systematic safety training, we suggest that the use of framework permits in this contest could be a good solution.
§11 Protection against polar bear attacks
§13 Requirements for individual travellers’ traffic, activity, and other stay outside planning areas
§14 Search and rescue insurance
There are many uncertainties (availability of relevant insurance products in different countries, costs and who will cover those, validity and overlap of insurances (when does a work activity start and end), etc.) connected with the distinction of activities by research group participants between field activities and individual travelling (see also comments to §3) and the proposed requirements for insurance. It seems unlikely that these uncertainties can be clarified in the short time frame anticipated (implementation of the new regulations in January 2023). We, therefore, suggest to revise this section and/or allow transitional arrangements until all implications of the proposed new regulations are clarified in detail.
§15 Application for permit of travel, activity or stay
The proposed requirement for permit applications for all activities outside areas with an approved area plan will heavily increase the number of applications for scientific field activities and will increase the bureaucratic workload of research institutions. The requirement to apply 8 weeks ahead of fieldwork is unrealistic for most of research activities as their timing depends on fast changing environmental conditions, as e.g. weather and snow conditions.
We welcome the usage of electronical application portals, but would like to stress the importance of easy access to such a portal also for non-Norwegian citizens (e.g. alternatives to the usage of Bank ID and similar as login).
§24 Implementation and changes
In the light of the uncertainties described above and the need to clarify those, especially in connection with the research stations in Ny-Ålesund and Hornsund, we see the ambition to implement the new regulations already January 2023 as unrealistic. We are also concerned that the large amount of expected additional permit applications cannot be met in a timely manner due to lack of resources at the Governor’s office, resulting in the need to cancel already planned field activity if permits are not received in time – which may jeopardise both long-term measurements as well as field campaigns.