On November 4, the American Waterways Operators submitted comments on proposed revisions to U.S. Coast Guard requirements relating to the use of electronic charts and publications in lieu of paper charts, maps and publications.
In its comments, AWO says that it “strongly supports the revision of this NVIC to allow certain navigation publications to be accessed electronically via the internet to meet domestic and international carriage requirements” and agrees that “the efforts of federal agencies to provide marine safety information in an updated electronic format, combined with vessel operators’ investments in electronic devices and underway internet connectivity, have progressed to the point that accessing required navigation information via the internet on an as-needed basis provides an equivalent level of safety to keeping a publication on board the vessel.”
However, AWO says it is concerned by a proposed requirement that publications that must be available as a “ready reference” including the Inland Navigation Rules, must be displayable within two minutes.
“We believe that this interpretation of ready reference is arbitrary and could lead to unwarranted penalties for mariners during Coast Guard marine safety inspections and boardings,” says AWO.
The Coast Guard now considers most electronic devices to be capable of meeting a two-minute time frame and, although AWO agrees that this is an accurate assessment of the capability of most electronic devices, “it does not take into account circumstances that could arise when a Coast Guard marine inspector or boarding officer requests a mariner to demonstrate that the required publications can be displayed within two minutes.”
AWO says that “if the mariner must boot up the computer, if the network transmission speeds are slow, or if there are other factors that impact the speed at which the publications can be displayed, the revised NVIC does not allow Coast Guard personnel to consider these factors when determining whether, for all practical purposes, the mariner can access publications needed in a timely manner to conduct voyage planning.”
The revised NVIC acknowledges that when a vessel is underway, “connectivity may be intermittent or unavailable for short durations of a voyage,” and that “[t]his temporary unavailability does not necessarily constitute a lack of access particularly if no voyage planning activities are occurring.”
AWO believes that similar consideration should be extended to situations in which the vessel is not underway so that the mariner and the vessel are not penalized or prevented from utilizing the equivalency available under the revised NVIC, if they are unable to produce these documents within two minutes.
Read AWO’s comments in full HERE