Maritime Information Services of North America

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