Ship Registry Information

Summary

A request for detailed data on Isle of Man Ship Registry fee changes and pleasure yacht registration statistics was largely fulfilled with eight documents, though specific income estimates were withheld.

Key Facts

• The Department for Enterprise released eight documents including fee comparison tables, consultation responses, and registration extracts.
• Specific information on estimated income generated by fee changes was exempted under Section 30 of the Freedom of Information Act 2015.
• The exemption was applied because disclosure could prejudice the commercial interests of the Ship Registry by aiding competitors.
• The Minister's signature was redacted as personal data under Section 25(b)(iii).
• The request covered registration figures for pleasure yachts from 2015 to 2019 across various length categories.

Data Disclosed

• £250
• £500
• £1,000
• 1 April 2019
• 1 April 2015
• 1 April 2016
• 1 April 2017
• 1 April 2018
• 12m
• 24m
• Part 1 of the register
• Small Ships Register
• October 2018
• January 2019
• Section 30
• Section 25(b)(iii)

Exemptions Cited

• Section 30 of the Freedom of Information Act 2015 (Commercial interests)
• Section 25(b)(iii) of the Freedom of Information Act 2015 (Personal data)

Original Request

Information on changes to Ship Registry fees, particularly in relation to pleasure yachts.

Data Tables (1)

Full Response Text

Freedom of Information Co-ordinator 1st Floor, St Georges Court Upper Church Street, Douglas Isle of Man IM1 1EX

Telephone: (01624 685375) Website: www.gov.im/ded Email: steven.tallach@gov.im

Our ref: 817765 31 May 2019

Dear ###

We write further to your request under the Freedom of Information Act 2015 (“the Act”) which was received on 9 May 2019 and which was as follows:

"Where the word "department" is used below it is intended to mean both the Department for Enterprise and any body (eg the Ship Registry) holding information for the Department for Enterprise. A copy of any document or information used or presented to the department as an analysis of the prices charged by other Ship Registries for the registration of pleasure yachts where that document or information was intended, or used, to inform the decision to introduce the new £250, £500 and £1,000 fees for the registration of said vessels in the island. A copy of any responses to the consultation on the introduction of revised Ship Registry fees. A copy of any document, circular or presentation advising any party external to the department of the change or intention to change ship registry fees prior to the 1 April 2019. Figures detailing the number of pleasure yachts which were: a) Under 12m and registered on Part 1 of the register on 1 April 2015 b) 12m-24m and registered on Part 1 of the register on 1 April 2015 c) 24m+ and registered on Part 1 of the register on 1 April 2015 d) Under 12m and registered on Part 1 of the register on 1 April 2016 e) 12m-24m and registered on Part 1 of the register on 1 April 2016 f) 24m+ and registered on Part 1 of the register on 1 April 2016 g) Under 12m and registered on Part 1 of the register on 1 April 2017 h) 12m-24m and registered on Part 1 of the register on 1 April 2017 i) 24m+ and registered on Part 1 of the register on 1 April 2017 j) Under 12m and registered on Part 1 of the register on 1 April 2018 k) 12m-24m and registered on Part 1 of the register on 1 April 2018 l) 24m+ and registered on Part 1 of the register on 1 April 2018 m) Under 12m and registered on Part 1 of the register on 1 April 2019 n) 12m-24m and registered on Part 1 of the register on 1 April 2019

o) 24m+ and registered on Part 1 of the register on 1 April 2019 Figures detailing the number of new pleasure yacht registrations on Part 1 during the periods: a) 1 April 2015-31 March 2016 b) 1 April 2016-31 March 2017 c) 1 April 2017-31 March 2018 d) 1 April 2018-31 March 2019 Details on the number of Pleasure Yachts leaving Part 1 between 1 April 2019 and the date on which this Freedom of Information request is processed. Figures detailing the number of vessels which were on the Small Ships Register on a) 1 April 2015 b) 1 April 2016 c) 1 April 2017 d) 1 April 2018 e) 1 April 2019"

I have enclosed copies of the following information:

1) Paper for Department meeting, October 2018 – Ship Registry Fees 2019 2) Private Yachts – Fee comparison table 3) Yacht Fees Comparison – post-consultation note 4) Merchant Shipping Fees Regulations 2019 – response to consultation 5) Briefing for IOM Maritime Executive 6) Submissions to Treasury: Appendix A – submission to Treasury Board October 2018 Appendix B – submission to Treasury Board January 2019 including copy of the draft Merchant Shipping (Fees) Regulations 2019; and Appendix C – submission to Treasury Board, update January 2019 7) Submission to Council of Ministers 8) “MAVIS” extract – Yachts on Register by length by year While our aim is to provide information whenever possible, in this instance some of the the information, namely specific information on estimated income generated by the changes to the fees, is exempt from disclosure under section 30 of the Act as disclosure would be likely to prejudice the commercial interests of the Department for Enterprise, as release of specific information on the extent of income generated or lost through changes to the Ship Registry's fee structure is likely to harm the Ship Registry's ability to compete with competitor ship registries. As section 30 is a qualified exemption, it is subject to a public interest test. The public interest must be something that is of serious concern and benefit to the public at large.

Factors in favour of disclosure The Ship Registry is a public body and therefore there is an interest in understanding how it determines the level of fees to be paid for provision of its services.

Factors in favour of withholding Release of the information will enable competitor ship registries to see how much income is generated in relation to particular services and is likely to undermine the Registry's ability to compete; Most of the information sought through this request is being released, including the overall projected increased income generated by the fee increases.

In taking these factors into account the the Department for Enterprise determined that the factors in favour of maintaining the exemption outweigh the factors in favour of disclosing the information. The signature of the Minister has also been redacted as we consider it to be absolutely exempt personal data under section 25(b)(iii) of the Act.

Please quote the reference number 817765 in any future communications.

Your right to request a review

If you are unhappy with this response to your freedom of information request, you may ask us to carry out an internal review of the response, by completing a complaint form and submitting it electronically or by delivery/post.

An electronic version of our complaint form can be found by going to our website at https://services.gov.im/freedom-of-information/Review . If you would like a paper version of our complaint form to be sent to you by post, please contact me and I will be happy to arrange for this. Your review request should explain why you are dissatisfied with this response, and should be made as soon as practicable. We will respond as soon as the review has been concluded. If you are not satisfied with the result of the review, you then have the right to appeal to the Information Commissioner for a decision on; 1. Whether we have responded to your request for information in accordance with Part 2 of the Freedom of Information Act 2015; or 2. Whether we are justified in refusing to give you the information requested.
In response to an application for review, the Information Commissioner may, at any time, attempt to resolve a matter by negotiation, conciliation, mediation or another form of alternative dispute resolution and will have regard to any outcome of this in making any subsequent decision. More detailed information on your right to a review can be found on the Information Commissioner’s website at www.inforights.im. Should you have any queries concerning this letter, please do not hesitate to contact me. Further information about freedom of information requests can be found at www.gov.im/foi.

I will now close your request as of this date.

Yours sincerely