PREPARATION FOR THE 95th SESSION OF THE IMO MARITIME SAFETY COMMITTEE (MSC)

IHB File No. S3/3055 CIRCULAR LETTER 34/2015 27 April 2015 PREPARATION FOR THE 95th SESSION OF THE IMO MARITIME SAFETY COMMITTEE (MSC) 3 to 12 June 2015, London, United Kingdom References: A. IHO CL 20/2015 dated 6 March - IHO contribution to the implementation of e-navigation - Proposed submission to the 95th session of the IMO Maritime Safety Committee; B. IHO CL 78/2014 dated 01 December - Report on the 94th session of the IMO Maritime Safety Committee; C. IHO CL 50/2014 dated 9 July - Report on the 1st session of the Sub-Committee on Navigation, Communications and Search and Rescue (NCSR 1); D. IHO CL 24/2015 dated 16 March - Report on the 2nd session of the Sub-Committee on Navigation, Communications and Search and Rescue (NCSR 2). Dear Hydrographer, 1. The Circular Letter in Reference A invited Member States and the Chairs of the relevant IHO subordinate organs to review a proposed IHO submission on the implementation of e-navigation, for consideration by the 95th session of the IMO Maritime Safety Committee (MSC 95), and to provide comments, if any. 2. Seven Member States (Belgium, Canada, Chile, Finland, Portugal, Spain, and United Kingdom) and two Chairs of subordinate organs (SNPWG and S-124 CG) have responded. All responses supported the proposed submission. The responses and the outcome of their review by the IHB are provided in Annex A. The IHO submission was revised accordingly and submitted to the IMO Secretariat. It is now available on the IMODOCS website as document MSC 95/19/14. A copy is attached in Annex B for ease of reference. 3. As announced in Reference B, the 95th session of the IMO Maritime Safety Committee (MSC 95) will take place from 3 to 12 June 2015 at the IMO Headquarters in London, United Kingdom. 4. The provisional agenda for MSC 95 (MSC 95/1) includes three items of specific interest to IHO Member States, namely: 9. Human element, training and watchkeeping 11. Navigation, communications and search and rescue 19. Work programme 5. The work programme for implementing e-navigation will be discussed under item 19. An informative presentation on e-navigation developments coordinated by the Comité International Radio-Maritime (CIRM) is planned at the end of the first day of MSC 95. The presentation will include input from the IHB regarding the IHO perspective. The presentation will be followed by a -1- reception co-sponsored by BIMCO, CIRM, the International Chamber of Shipping (ICS), the International Maritime Pilots’ Association (IMPA) and the IHO. 6. Under item 9, the Committee will be invited to approve a draft MSC circular on ECDIS - Guidance for good practice. As reported in Reference C, the draft circular was endorsed by the 1st session of the Sub-Committee on Navigation, Communications and Search and Rescue (NCSR) and forwarded to the Sub-Committee on Human Element, Training and Watchkeeping (HTW) for review. The HTW agreed additional amendments to part E - ECDIS Training, part G - Guidance on training and assessment in the operational use of ECDIS Simulators and appendix 3 - Guidance on training and assessment in the operational use of ECDIS Simulators and has invited the Committee to approve the amended draft. 7. Agenda item 11 will consider the outcome of the 2nd session of the NCSR reported in Reference D. 8. The IHB delegation at MSC 95 will take the opportunity of its first address to the meeting to acknowledge the States which have recently joined the IHO and those which have applied for membership. 9. Member States are encouraged to liaise with and brief their national delegations at MSC 95 on issues of relevance to the IHO. On behalf of the Directing Committee Yours sincerely, Gilles BESSERO Director Distribution: - IHO Member States - Chair of HSSC - Chair of WWNWS-SC - Chair of ENCWG - Chair of S-100WG - Chair of SNPWG - Chair of S-124CG Annexes A: Responses to IHO CL 20/2015 and IHB comments B: IHO Submission MSC 95/19/14 (in English only; the French and Spanish versions will be made available later on the IMODOCS website) -2-  Annex A to IHO CL 34/2015 Responses to IHO CL 20/2015 and IHB comments Belgium The proposed submission has been reviewed by our colleagues of the Division Vessel Traffic Assistance of our agency MDK. They have no remarks. Canada Canada supports the comments by the IHO on the proposal to approve six outputs on e-navigation in relation to the proposed amended High-level Action 5.2.6, “Development and implementation of e- navigation”. Canada wishes to acknowledge and thank Norway and others for their work on the proposal for six outputs on e-navigation as well as an amended High-level Action 5.2.6. Chile We have taken note of the proposed text to be submitted to the MSC 95 session and we would like to offer the following comments: 1. We appreciate the involvement of IHB, on behalf of IHO, in the preparation of the proposal coordinated by Norway to be submitted to the 95th session of the MSC, dealing with e- navigation. We are confident that IMO MSs appreciate IHO´s contribution. 2. We feel that there is an inconsistency. On one side the IHB DC decided not to support the final text of Norway, endorsed by several IMO MSs, because it did not consider in full the IHB comments and on the other side, under paragraph 4 of the draft IHO proposal it is indicated that “the IHO supports the proposed amended High-level Action 5.2.6”. 3. Examining the text of the draft IHO proposal, we think that the wording referring to proposed outputs N° 1, N° 2, N° 4 and N° 6 really do not strongly contribute to the discussion and do not offer a concrete action to be followed. 4. We agree that we must highlight the concept covered by the comment on the proposed output N° 5. IHB comment: The IHB confirms that the objective of the IHO paper is to support the proposed amended High-level Action 5.2.6 while inviting further consideration of the scope of the proposed associated outcomes. Finland The original document submitted by Norway and others do contain relevant and advocated proposals for the work plan and outputs on implementation of the e-Navigation Strategy. In addition, the Finnish HO supports a separate submission from IHO as proposed by IHB where our role in implementing e-Navigation is described. Portugal The Portuguese Hydrographic Institute has no relevant comments to the proposed text. Nevertheless, this Institute considers that the proposed outputs will contribute significantly to enhance the safety of navigation and the environment protection, contributing assuredly towards the development of the e-navigation Strategy Implementation Plan, and for a better and sustainable global maritime transportation system. Spain Following the review of the documents submitted, this HO has no further comment. -A1- United Kingdom In response to the above CL, UK have the following comments to make on the outputs from the amended High-level Action 5.2.6. S-Mode UK agrees that the impact of S-mode on ECDIS standards is not clearly addressed. Moreover, just implementing this as a set of guidelines would seem unlikely to have the desired effect. Since S- mode is fundamentally about the display of base navigational chart data, the IHO should take a strong lead, aiming for a mandated solution. It is acknowledged that this will have a significant impact on regulators, equipment manufacturers, ship owners and ship operators, but that the safety benefits of global harmonisation will only be delivered through such an approach. Furthermore, and to support any implementation of S-mode, changes to ECDIS software needs to be regulated, otherwise within the current regime there would be no requirement to implement S-mode. Output 1 as currently defined is immature. It is suggested that a pragmatic starting point is to deliver consolidated user requirements. INS UK agrees that new modules for INS can only be considered alongside outputs 5 and 6 and therefore suggest stronger wording to propose that this output should be delayed because of these dependencies. In addition, UK believes that attempts to harmonise too soon are likely to restrict industry led development of user friendly solutions. UK does not consider this is an area of IHO expertise and is therefore content with a brief statement. Ship Reporting Systems UK agrees with the position that the IHO doesn’t consider ship reporting to be something it should comment on. BIIT for Navigational Equipment UK agrees with the statement that the impact of BIIT for navigation equipment will need to be considered in terms of standards for ECDIS, but wishes to emphasize the point made on S-mode above. Without a mandatory updating regime for ECDIS, any work done on BIIT will only be advisory, and will therefore not be a satisfactory response to what is described in Annex B to CL20 as a ‘compelling need’. Considering that this impacts on the integrity of navigational data as displayed on ECDIS, the IHO should strongly propose IMO consideration of mandatory updating of ECDIS as a significant contribution to navigational safety. Harmonized Display of navigational information UK agrees with the IHO observation that the HGDM is still dormant, but suggests strengthening this by questioning whether anything is really “ongoing” in terms of development of CMDS. MSPs UK agrees with the IHO statement on the development of MSPs, but suggests that further comment is required pointing out that it is unclear how the harmonisation and scrutiny of MSPs will take place, and what this will mean in practice. UK believes that attempts to harmonise MSPs too soon are likely to restrict and the development of innovative solutions. The IHO contribution is to provide the data standards which can be used by service providers. UK agrees with the stated arrangements for IHO contribution to e-navigation IHB comment: The inputs from the United Kingdom have been partially reflected in the amended text of the final IHO submission (paragraphs 5, 9 and 13). The IHB considers that the IHO has no justification to comment on the risk that harmonizing too soon would restrict innovation in relation to Integrated Navigation Systems (INS) and Maritime Service Portfolios (MSPs). The UK proposal that the IHO “take a strong lead aiming for mandated solutions” in relation to the S-Mode and BIIT seems to contradict somewhat the UK position on INS and MSPs and in all cases, the IHB feels that it would be premature. -A2- Chair of the SNPWG My comment is related to numbers 11 and 16. 11. As reported in NCSR 2/11, three product specifications based on S-100 which are relevant to navigational warning services are being developed. The IHO is developing S-124 - Navigational warnings. The Joint Technical Commission for Oceanography and Marine Meteorology (JCOMM) of the World Meteorological Organization (WMO) and of the Intergovernmental Oceanographic Commission (IOC) is developing S-411 - Sea ice and S-412 - Met-ocean forecasts. I understand that these Product Specifications have been reported as being relevant to nav warning services to NCSR. 16. The Nautical Information Provision Working Group (NIPWG) is tasked to develop high level specifications for a combined MSP covering the provision of hydrographic services to mariners, in accordance with the e-navigation SIP. Would it be feasible to mention that the S-122 (Marine Protected Area) ProdSpec is under development and that it will be the first ProdSpec which will work together with S-124 (Navigational Warnings)? Background: Some MPAs are of temporal nature and will be established if indications of the presence of certain types of animals are given. This might be broadcasted based on S-124. The portrayal of such temporal areas (based on S-122) could be initiated (automatically or manually) by the broadcast signal and the ECDIS system internal interaction between S-122 and S-124. IHB comment: The IHB considers that MSC is not the appropriate forum to consider the details of the various S-1xx Product Specifications developed by the SNPWG, at this early stage of their development and of the development of S-124. Leader of S-124 CG My feeling is that the 6 proposed outputs don’t reflect enough the tasks related to the shore side to be undertaken to implement e-navigation: maritime services (MSPs) via data and communications (taking into account the revised GMDSS). Thus, I agree with the IHO’s draft comments in general and especially those related to the Common Maritime Data Structure (CMDS) and T14, to the MSPs (T17), to the coordination with the on-going review of the GMDSS. However, I have a small comment about §8: the development of the CMDS and the development of MSPs seem to be pre-requisites to the implementation of the harmonized display of navigation information. They are possibly not pre-requisites to the development of the guideline for the harmonized display (shipboard requirements) which could be seen as the driver of the developments of the CMDS and MSPs. In all cases, these developments are closely linked and should be coordinated. The §10 seems in line with this point of view. IHB comment: The comment on paragraph 8 is reflected in the text of the final IHO submission. -A3-  Annex B to IHO CL 34/2015 IHO Submission MSC 95/19/14 -B1- -B2- -B3- -B4-