TKKD Raises Concerns Over Pilotage Tender Violations

Objection from TKKD to the İzmit and Nemrut–Aliağa Tenders: 'Internship' Claim

New model: 'regional service area' and 'highest public share'

The Turkish Association of Pilot Captains (TKKD) claimed that there are clear violations of the Regulation on Pilotage and Towage Services dated February 11, 2025, in the process of dividing pilotage services in the Kocaeli–İzmit Gulf and Nemrut–Aliağa Gulf and transferring them to private companies through tendering.

The basis of the debate in the sector is the new model that emerged with the regulations added to the Ports Law in 2024: service areas are structured 'regionally'; the operating rights are awarded through tenders, and the competition revolves around 'the highest public share.'

Tenders: Public share has reached the 80-90% band

The tenders reported in the maritime press have also made the 'mathematics' of the model visible. It was reported that in the Kocaeli-2 Regional Service Area pilotage tender, the highest bid was given with a public share of 90.5%; while in Kocaeli-1, the subsequent tender resulted in an 80% level.

A similar picture exists on the Nemrut–Aliağa side: In the Aliağa-1 pilotage tender, a public share bid of 89.75% stood out; it was reported that Turkuaz won the tender in Aliağa-2 with an 82% public share, and the process has passed through the Ministry's approval/contract stages.

Although these rates may appear to provide 'more share to the public' on paper, they have been a subject of long-standing debate due to the narrowing of the remaining share, which has created pressure on safety-related items such as personnel, training, shifts, boat/equipment renewal, and maintenance.

Critical line in the legislation: Application phase is different, transfer is different

To understand TKKD's objection to 'completing the staff with internships,' it is necessary to distinguish between two separate thresholds in the regulation:

The first is the tender application phase. The regulation stipulates that during the application, the bidder must present an employment contract/SGK registration or a notarized commitment with at least 20% of the minimum number of 'qualified pilot captains for the relevant regional service area.'

The second is the threshold before the contract is signed. The same regulation clearly states that the winning bidder must employ the minimum number of qualified pilot captains for the relevant region specified in Annex-1 before signing the contract.

Additionally, the regulation emphasizes that the service should be carried out with regard to the principles of independence and impartiality; it also includes administrative approval mechanisms and obligations regarding on-the-job training/working arrangements.

TKKD's claim: Incomplete staff is being filled with 'internships,' there is pressure

In its statement, the association (in summary) states: Despite the regulation and the written confirmations from the Administration, it has been observed that in some regions, the 'insufficient number of pilot captains' is being attempted to be completed through internships, and verbal pressure has been created on pilot captains who do not participate in this practice, leaving professionals facing unemployment concerns.

The association also notes that in the official responses to applications made to the Turkish Grand National Assembly, there are statements indicating that 'the number of required pilot captains will only be met through the employment of pilot captains who possess the relevant regional service area license' and that 'working rights will not be lost.'

At this point, TKKD's targeted issue is clear: The 'on-the-job training' (internship) mechanism cannot be used as a shortcut to replace the employment condition before the contract. Although the regulation states that on-the-job training must be provided to candidates as an obligation, it does not establish a personnel transformation formula that allows for 'completing the norm staff with interns.'

Debate on 'norm staff 29' in Nemrut–Aliağa and safety concerns

The association argues that following the division of the region, the norm staff in the Nemrut–Aliağa Gulf has been organized as a total of 29 pilot captains (14+15); whereas in the previous regulatory period, there were actually 40 pilot captains working, and this difference will result in at least 10 pilot captains losing their jobs in this region alone.

In addition to this claim, it is already a known fact that the Aliağa/Nemrut line has high traffic and facility density; previous evaluations in 7deniz noted that the Aliağa-2 area covers many ports in the Nemrut Gulf and is mentioned with approximately 3,000 ship traffic annually. TKKD's argument here is twofold: aside from the risk of job security loss, the increased workload on the remaining personnel transforms into a risk for navigation safety through 'fatigue and commercial pressure.'

İzmit Gulf: 'Why bring in external pilots when there are over 70 licensed pilots?'

TKKD states that there are currently over 70 pilot captains with regional licenses in the Kocaeli–İzmit Gulf; nevertheless, the desire to 'bring in pilots from outside the region through internships' without citing force majeure/personnel shortages/safety reasons raises questions.

The background of this issue from the sector's perspective is also clear: As the public share rates increase, the share remaining with the operator decreases; the first item that is often pressured by the narrowing share is human resources. Evaluations published in Denizhaber have also brought the discussion of declining pilot captain wages after the tenders and their impact on safety to the forefront. In other words, the 'highest public share' competition is not only a financial debate; it is a chain linked to safety discussions through personnel policy.

The issue of 'commercial pressure': International warnings and local knowledge

The framework emphasized in Cahit İstikbal's analyses in Denizhaber is also this: When pilotage/towage services are left to the classic logic of free market competition, it may pose a risk to safety; although it is said that the new model's single operator structure limits 'price-cutting' competition, the public share competition in the tender may increase internal cost pressure on companies.

The transformation of this pressure into expectations of 'commercial speed/cheapness' directly conflicts with the independence of the pilot captain. The regulation itself emphasizes that the service must be conducted according to the principles of independence and impartiality. The phrase 'we can manage with an intern' at sea is risky even on land; in narrow waterway maneuvers, under currents/wind, it almost turns into a joke—but it is not funny.

What does TKKD want?

The association announced three main demands to the public: immediate cessation of internship and personnel impositions that violate the regulation; regional takeovers to be carried out only with pilot captains who possess regional licenses; and an end to practices that effectively eliminate job security for professionals.

The crux of the process: The Administration's oversight of 'pre-contract employment'

The legal core of this debate lies in the explicit provision of the regulation: It is a condition to employ the minimum number of qualified pilot captains for the relevant region specified in Annex-1 before signing the contract. Therefore, the key question is: How will the Administration determine whether this condition has been met, by what method, with what standard of evidence, and on what date will it be considered 'complete'?

Moreover, it has been previously reported that TKKD has filed a lawsuit at the Council of State seeking annulment/suspension of the new regulation; and while this judicial review is ongoing, information has emerged that the tenders continue.

TKKD's current stance is, for this reason, not just a professional complaint; it is a direct challenge reminding the Administration of its oversight responsibility with the claim that 'the mandatory provision is being eroded in the field.' The responses from the Ministry and the winning/candidate companies regarding the issue will determine where the process will legally and practically settle.

Source: SeaNews Türkiye