ECDIS and Paper Charts


#1

I’ve been hearing a lot about the abolishment of paper charts and the requirement of a twice redundant ECDIS system like on cruise ships. Can anyone give insight on this? People talk a lot of bull and spread ridiculous rumurs. Does anyone know where I can find this in writing, if it exists of course. Thanks!


#2

Yes it exists and many ships are now on the paperless system.


#3

It’s an IMO requirment, I’m not familiar with the details but a google search will turn up lots of info. In general, ships that are required to carry ECDIS are required to have a back-up. It can be another ECDIS or it can be paper charts. In both cases charts are not being abolished but with two ECIDS paper charts are not required.

My experience is it’s better to jump in with both feet as the single ECDIS solution requires the trouble and expense of maintaining both systems.

I prefer paper charts in some cases although I could eventually learn to live without them. For example, planning prior to entering an unfamiliar port it’s nice to see the whole picture without having to scroll. zoom etc.

Even using an ECDIS backup you can still use paper charts although I assume purchasing would not be happy to see a large bill for a paper chart order. I’d just keep some of the old ones aboard for convenience sake but not update them.


#4

In order to go paperless you must have the redundant system, pay for the charts (pay as you sail or whatever else they offer), equipment specific training for the crew, and operate outside of Jones act trade. So a U.S. Flag vessel working jones act trade can NOT go paperless at least for now. This may change in the future but I doubt it.


#5

[QUOTE=PR-9;169381]In order to go paperless you must have the redundant system, pay for the charts (pay as you sail or whatever else they offer), equipment specific training for the crew, and operate outside of Jones act trade. So a U.S. Flag vessel working jones act trade can NOT go paperless at least for now. This may change in the future but I doubt it.[/QUOTE]

Wasn’t aware of that. Just out of curiosity what the deal with this?


#6

[QUOTE=PR-9;169381]So a U.S. Flag vessel working jones act trade can NOT go paperless at least for now. This may change in the future but I doubt it.[/QUOTE]

Unless you can provide a specific citation to validate your claim I’m going to say that you are incorrect. See below:

http://www.uscg.mil/hq/cg5/cg553/NAVStandards/ECDIS.asp

Specifically:

"On July 14, 2004, the US Coast Guard published a notice in the Federal Register outlining the criteria by which ECDIS could be used to meet the charts carriage requirements outlined in 33 CFR 164.33.

42192 Federal Register / Vol. 69, No. 134 / Wednesday, July 14, 2004 / Notices

“Carriage of Navigation Equipment for Ships on International Voyages”
“If a ship has an approved ECDIS installed according to chapter V, the ECDIS will be considered by the Coast Guard as meeting its nautical chart regulation in 33 CFR 164.33(a)(1), because the ECDIS meets the same navigational safety concerns as do paper nautical charts. This policy benefits the ship owner and operator by relieving them of the need to unnecessarily duplicate equipment.”"


#7

I stand corrected and disappointed. I believe that ECDIS gives the operator to many options as far as removing layers. Also in my experience the pay as you sail doesn’t always work and you end up with the Warning message “ENC #%#%# is not up to date”. So if you have no paper charts you are stuck fixing it before you can sail.
I will hold on to my paper charts as long as I can!!


#8

That citation discusses ships on international voyages not domestic/coastwise trade. I believe US flag operators would need to get a navigational waiver if they wanted to go paperless with ships in the Jones Act trade.


#9

[QUOTE=dredgeboater;169441]That citation discusses ships on international voyages not domestic/coastwise trade. I believe US flag operators would need to get a navigational waiver if they wanted to go paperless with ships in the Jones Act trade.[/QUOTE]If it meets the requirements of 33 CFR 164.33 then it meets the requirements. I didn’t see anything in that USCG post that even sightly insinuated that that decision applies only to vessels in international trade.


#10

This is as of 2004, next step is to check CFR 33 and 46 have been amened to align with SOLAS since then.

What Ships Are Affected?
This policy applies to the following ships, which are subject to the amendments to chapter V:

  1. U.S.-flag ships of 150 or more gross tonnage that engage on international voyages.
  2. U.S.-flag ships certificated solely for service on the Great Lakes and the St. Lawrence River as far east as a straight line drawn from Cap de Rosiers to West Point, Anticosti Island, and, on the north side of Anticosti Island, the 63rd Meridian.
  3. Foreign-flag ships to which SOLAS, chapter V, applies that are operating on the navigable waters of the United States.
    Note that U.S.-flag ships without mechanical means of propulsion are exempt from certain requirements of SOLAS under SOLAS, chapter V, regulation 3.1.
    [B]This policy is not applicable to U.S.- flag ships engaged only on domestic voyages. These ships must continue to comply with the existing navigation equipment requirements in titles 33 and 46 CFR.[/B]
    How Long Will This Policy Remain in Effect?
    This policy will remain in effect until titles 33 and 46 CFR are aligned with SOLAS, chapter V.
    Dated: July 8, 2004

#11

i see how you could interpret it that way, but i don’t think they’re referring to “vessels on international voyages” other than to reference a publication titled "42192 Federal Register / Vol. 69, No. 134 / Wednesday, July 14, 2004 / Notices
“Carriage of Navigation Equipment for [B]Ships on International Voyages[/B]”

Don’t see why not either.


#12

Here is the first part, if I am reading it correctly it says that for ships to which this policy applies meeting SOLAS requirements for ECDIS is ok.

For ships to which this policy applies,
when an amendment to chapter V and
a provision in Coast Guard regulations
address the same navigational safety
concern and when applying both would
result in an unnecessary duplication,
the Coast Guard will accept the
provision under chapter V as meeting
the corresponding Coast Guard
regulation. In other words, if a ship has
an approved ECDIS installed according
to chapter V, the ECDIS will be
considered by the Coast Guard as
meeting its nautical chart regulation in
33 CFR 164.33(a)(1), since the ECDIS
meets the same navigational safety
concerns as do paper nautical charts.
This policy benefits the ship owner
operator by relieving them of the need

Here are the ships that the policy applies to:

What Ships Are Affected?
This policy applies to the following ships, which are subject to the amendments to chapter V:

  1. U.S.-flag ships of 150 or more gross tonnage that engage on international voyages.
  2. U.S.-flag ships certificated solely for service on the Great Lakes and the St. Lawrence River as far east as a straight line drawn from Cap de Rosiers to West Point, Anticosti Island, and, on the north side of Anticosti Island, the 63rd Meridian.
  3. Foreign-flag ships to which SOLAS, chapter V, applies that are operating on the navigable waters of the United States.
    Note that U.S.-flag ships without mechanical means of propulsion are exempt from certain requirements of SOLAS under SOLAS, chapter V, regulation 3.1.
    [U]This policy is not applicable to U.S.- flag ships engaged only on domestic voyages. These ships must continue to comply with the existing navigation equipment requirements in titles 33 and 46 CFR.
    How Long Will This Policy Remain in Effect?
    This policy will remain in effect until titles 33 and 46 CFR are aligned with SOLAS, chapter V.
    Dated: July 8, 2004[/U]

It specifically says: ]This policy is not applicable to U.S.- flag ships engaged only on domestic voyages. These ships must continue to comply with the existing navigation equipment requirements in titles 33 and 46 CFR

So it looks to me that as of 2004 that the US flag ships on domestic voyages can not meet the requirement to carry charts with an ECDIS. In other words they are required to carry paper charts - as of 2004.

Have the CFRs been updated since then?

This is from 2013. Looks like companies that want to sail paperless can get a waiver.

In 2004, Congress amended the Ports and Waterways Safety Act of 1972 broadly requiring the use of electronic charts in navigable waters of the U.S., allowing for individual vessel exemptions and waivers, and directed the USCG to implement this addition to the law before 2007 (33 U.S.C. 1223(a)). The USCG implemented portions of the PWSA beginning in 1983 as 33CFR160 with amendments as recent as 2011, but without addressing the use of electronic charts.
In the absence of such rulemaking, the USCG, ironically, is able to grant waivers to allow for paperless navigation by SOLAS classed ships sailing domestically under US flag. The rule that would allow this has been in place (33CFR164.55) since 1977 for navigation safety regulations in general, and since 1951 for waivers of navigational compliance (33CFR19.01). Soon there may be some prominent shipping companies who will make use of this. All of it will impact domestic operators – no matter where and on what platform they sail on.


#13

[QUOTE=z-drive;169450]"42192 Federal Register / Vol. 69, No. 134 / Wednesday, July 14, 2004 / Notices
“Carriage of Navigation Equipment for [B]Ships on International Voyages[/B]”[/QUOTE]

Wow, I’m blind! I read everything else word for word but didn’t actually bother read the title of the federal register!


#14

I am agreeing with you.


#15

[QUOTE=Kennebec Captain;169458]

This is from 2013. Looks like companies that want to sail paperless can get a waiver.[/QUOTE]

That’s not what 33 usc 1223a says. You would need a waiver to be allowed to NOT use electronic charts if you were one of the subject vessels. Paperless=mandatory.


#16

[QUOTE=Jamesbrown;169519]That’s not what 33 usc 1223a says. You would need a waiver to be allowed to NOT use electronic charts if you were one of the subject vessels. Paperless=mandatory.[/QUOTE]

Not sure. Here is 33 USC 1223a

§1223a. Electronic charts
(a) System requirements
(1) Requirements
Subject to paragraph (2), the following vessels, while operating on the navigable waters of the United States, shall be equipped with and operate electronic charts under regulations prescribed by the Secretary of the department in which the Coast Guard is operating:
(A) A self-propelled commercial vessel of at least 65 feet overall length.
(B) A vessel carrying more than a number of passengers for hire determined by the Secretary.
© A towing vessel of more than 26 feet in overall length and 600 horsepower.
(D) Any other vessel for which the Secretary decides that electronic charts are necessary for the safe navigation of the vessel.
(2) Exemptions and waivers
The Secretary may—
(A) exempt a vessel from paragraph (1), if the Secretary finds that electronic charts are not necessary for the safe navigation of the vessel on the waters on which the vessel operates; and
(B) waive the application of paragraph (1) with respect to operation of vessels on navigable waters of the United States specified by the Secretary, if the Secretary finds that electronic charts are not needed for safe navigation on those waters.
(b) Regulations
The Secretary of the department in which the Coast Guard is operating shall prescribe regulations implementing subsection (a) of this section before January 1, 2007, including requirements for the operation and maintenance of the electronic charts required under subsection (a) of this section.
(Pub. L. 92–340, §4A, as added Pub. L. 108–293, title IV, §410, Aug. 9, 2004, 118 Stat. 1045.)

So it says “shall be equipped with and operate electronic charts”

But, where does it say the vessel don’t have to comply with §164.33 ?

Charts, publications, and equipment: General.
No person may operate or cause the operation of a vessel unless the vessel has the marine charts, publications, and equipment as required by §§164.33 through 164.41 of this part.

[CGD 82-055, 48 FR 44535, Sept. 29, 1983]

§164.33 Charts and publications.
(a) Each vessel must have the following:

(1) Marine charts of the area to be transited, published by the National Ocean Service, U.S. Army Corps of Engineers, or a river authority that—

(i) Are of a large enough scale and have enough detail to make safe navigation of the area possible; and

(ii) Are currently corrected.


#17

[QUOTE=Kennebec Captain;169521]So it says “shall be equipped with and operate electronic charts”

But, where does it say the vessel don’t have to comply with §164.33 ?[/QUOTE]

I don’t see anything in 33 CFR 164.33 that would indicate that an electronic chart does NOT satisfy that requirement.


#18

[QUOTE=Kennebec Captain;169521]Not sure. Here is 33 USC 1223a

So it says “shall be equipped with and operate electronic charts”

But, where does it say the vessel don’t have to comply with §164.33 ?[/QUOTE]

Well, first I would say the two sections are not mutually exclusive and as Capt Phoenix notes where does it say an electronic chart may not be a ‘marine chart’? But, the statute is ‘newer’ than current 33 CFR 164.33–which is where CG would likely place the ‘required’ regulations to implement 33 USC 1223a. The section has only be amended in 2001 and 2015, though not to comply with the statute.

This wouldn’t be the first time that the CG backlog hasn’t matched Congressional timelines, but to be fair to the blue-suiters, this would be a difficult statute to implement beyond the Secretary declaring all US waters safe without using electronic charts in accordance with 33 USC 1223a(a)(2)(B) to preserve status quo and how hard would that be–it was safe yesterday, or as safe as it has been, how did it become unsafe just by a bit of language inserted to a law? How do you demand ECDIS (or some lower-grade variety) for the majority of vessels foreign and US operating in US waters (or transitting)? Violates IMO requirements for foreign vsls by contravening SOLAS to potentially make a foreign vsl not required to fit ECDIS to use ECDIS in the US in 2007? Type approvals, installation requirements for non-SOLAS ships, user training, certification of non-STCW mariners to STCW ECDIS standards or not requiring it… This would be a tough one to implement, costly, and potentially dangerous.


#19

I do agree that having a paper back up would be on the safe side, electronics do fail and software can have issues within themselves. One should always have a good CHART KNOWLEDGE foundation.


#20

This discussion always makes me laugh.

There are about 100,000 commercial flights a day around the world and the way people talk about GPS, ECDIS or electronics failure you’d think those airplanes would be falling from the sky with steady regularity.

Dirty little secret: Jumbo jets don’t use paper charts and don’t have navigators. Those have been replaced with gasp electronics!