Comments to the LRIT Regulatory Docket
2 January 2008
The following comments are submitted by David W. Stambaugh, President of the
Maritime Information Services of North America (MISNA) and General Manager of
the Baltimore Maritime Exchange regarding docket number USCG-2005-22612,
Long Range Identification and Tracking of Ships.
MISNA has operated a long range satellite-based vessel tracking since 2001 and
has developed an appreciation for the complexities of tracking vessels. Given
MISNA?s experience with long range vessel tracking, the following comments are
offered on the proposed 33 CFR 169 regulations.
Regulatory Analysis: Section V. A.
Cost of Long Range Vessel Tracking
MISNA membership is comprised of hundreds of maritime operators and
stakeholders, many of whom are already participating in a satellite-based, long
range vessel tracking system to aid safe, secure, efficient and environmentally
sound maritime operations. Based on our experience operating our Automated
Secure Vessel Tracking System (ASVTS), we are concerned that the NPRM does
not reflect costs that will be borne by vessel operators required to participate in the
LRIT system. In other words, the 25 cent per position report estimated in the
NPRM incurred by the Coast Guard does not reflect all costs in implementing
LRIT, or the actual costs vessel owners and operators will incur.
We have specifically noticed that there are frequent failures of data transmissions
due to equipment problems, blocking of satellite signals and changing of satellite
ocean regions. Additionally, position report failures oftentimes develop as a result
of Communication Service Providers? (CSP) connectivity, internet or other
communications failures. These disruptions to vessel tracking are not noticeable
to vessels? masters or crews as the systems are automated and send the data
directly to terrestrial earth stations for further dissemination to land-based users of
the data. When breakdowns do occur, the Applications Service Provider (ASP)
and the owner/operator are typically the parties that notice the equipment failure
and in turn notify the master, or the CSP to correct the situation. In light of the
fact that a vessel?s master is responsible for notifying the Coast Guard of data
transmission failures or lapses and the penalty for non-compliance is $25,000,
owners and operators of vessels will likely incur additional costs in providing a
Quality Assurance program, in replacing communications hardware, and/or
obtaining technical support to ensure compliance with the LRIT regulations.
Additionally, the preamble states that the satellite position reports will be paid by
the Coast Guard, but the regulations are silent on this issue. We recommend this
provision also be specifically addressed in the regulations as the preamble is not
normally available or researched once regulations are implemented.
Information Sharing
We recommend the Regulations should clearly state that vessel owners and
operators may share the LRIT position reports with other parties, including but not
limited to their owners, operators, charterers, agents, pilots, ports, etc. through
their ASP or other mechanism, even when the Coast Guard is funding 4 position
reports a day. Based on our experience operating ASVTS, MISNA has found that
sharing of this data with other maritime stakeholders enhances safe, secure,
efficient and environmentally sound maritime operations.
Recognizing Ongoing Efforts to Maximize Maritime Domain Awareness
MISNA has been helping many vessel operators (tankers, containerships, ferries,
tugs, and cruise ships) to track their vessels with satellite systems for several
years now and have voluntarily shared this data with the Coast Guard. All have
elected more frequent polling rates ranging from every 1 to 4 hours depending on
the speed of the vessel to provide more meaningful data. This increased polling
aids maritime safety as well as the efficiency of commercial operations and
maritime security operations, including vessel escorts, dispatch of boarding
teams, etc. and should be encouraged.
The advantages of more frequent polling rates are clear. A 25 knot vessel polled
every 6 hours as per the proposed LRIT regulations could be, depending on its
course, anywhere in a 70,000 square mile area. Polling every 3 hours reduces the
area the vessel could be in by 75% to 17,600 square miles, providing for more
meaningful Maritime Domain Awareness (MDA), which is the stated objective of
LRIT. We recommend the Coast Guard recognize the added MDA value already
provided by ASVTS to vessels that voluntarily provide more frequent polling by
allowing partial relief from the Advance Notice of Arrival updating requirements.
Respectfully submitted,
David W. Stambaugh
General Manager
Baltimore Maritime Exchange, Inc.
(410) 342-6610
(410) 327-4847 fax
Manager@balmx.org
Maritime Information Services of North America
This is comment on Notice
Long Range Identification and Tracking of Ships
View Comment
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