Dato: 20.01.2020 My name is Andreas Niemann, I have been a visitor and friend of Norway from an early age and I feel disappointed that I have now become the victim of a gross generalisation. I am also the developer of FishReg.net, one of the catch registration systems available to tourist fishery businesses. This is my personal and professional opinion on this topic. To the powers that be: Rarely have I felt more affected by an example of where the uninformed masses of the populus have to be ignored for the greater economical and ecological benefit. I do not envy you for the political challenges you have accepted and hope you find the strength to do the right thing, even if it is not the most popular thing. I hope you have rational thinking people you can rely upon to aid you in making a decision. Regarding: Utførselsreguler Legislation should provide a legal way to keep bringing fish out of the country, regardless of the cut of fish. Nobody seems to have a problem with selling fish to foreign countries or tourists, so it should be made possible for tourists to "buy" and bring their own catch in whichever form they choose. The species and cut of fish can be factors to determine the price. This could present an opportunity to legalise exporting any amount of fish and also could help cover the costs of necessary technical implementations and enforcement. The amount of fish that any fisherman can catch is determined by a multitude of factors (area, time spent fishing, season, target species, etc.) Any legislation should reflect this fact. Ideally such a quota should be per week of stay, not per year. The suggested change of bringing only gutted and beheaded fish seems to have originated from a position of lacking information. Hopefully the pushback on this topic will be reason enough to forgo implementation of this mislead idea. Just have people pay for what they bring home and you ged rid of a lot of problems you are facing with every other suggestion. On a sidenote: It should have always been legal to bring fish stock (kraft) in addition to filet. How is this a fish product that is counted the same as filet? What do you expect the customs to do if someone arrives with 20kg of filet and 30 litres of fish stock? Under current legislation he would be fined ... hard. Regarding: Rapportering av fangst I may have a unique look on these suggested changes. First of all: Nullfangst registration seems pointless. It was never publically justified why this made it into the law. Would you mind elaborating? Also: Get rid of catches per trip, in practice it is a futile requirement. People note down/register catches mostly between 20:00 and 24:00 on the day of fishing or between 06:00 and 09:00 the following day. Obviously most of them are happy to even remember the accurate number of catches, nevermind how many they caught during which trip. So most people just sum up what they caught in a day - I can't blame them for it and neither should you. If this suggestion is implemented and set too low (1 day), all tourist fishery businesses will be de-facto forced to utilise a software for catch registration that has their guests report their catches digitally. There are plenty businesses out there that can not comply with this demand because tourist fishery is not their owners main job. These people have to work a full job for a living too, so they may be unable to comply with the law. Also: Be careful with the wording of the law, if you demand daily reporting to Fiskeridirektoratet you inadvertently make high-availability of the reporting service a legal requirement, you should probably as them before going ahead. The quality of the data that was sent to Fiskeridirektoratet in 2018 was generally pretty bad, it is no wonder that the continued release of all statistical data never really got going as intended (https://www.fiskeridir.no/Tall-og-analyse/AApne-data/AApne-datasett/Turistfiskedata). If you provide a non-ideal method of collecting data you are going to get non-ideal data. To that end daily reporting or even reporting instantly after a fish has been caught would do wonders for the data quality. Try avoiding the same mistakes as in 2018 when catch registration launched. Provide the proper tools for catch registration for free and keep in mind that not every operator of a tourist fishery business is tech-savvy. Reporting of catches always relies on the tourists providing accurate information, as such ideally it should be the tourists responsibility to report catches, not the owners of tourist fishery businesses. Wasn't the whole point of catch registration to get numbers to discuss future legislation if needed? What happened, surely nobody knows more now that they did in 2017, so why are you discussing legislative changes now instead of waiting on relyable data? Nærings- og fiskeridepartementet Til høringen Til toppen <div class="page-survey" data-page-survey="133" data-page-survey-api="/api/survey/SubmitPageSurveyAnswer" data-text-hidden-title="Tilbakemeldingsskjema" data-text-question="Fant du det du lette etter?"
