MARITIME SAFETY COMMITTEE
70th session
Agenda item 11

SAFETY OF NAVIGATION

Navigation aids and related matters

Performance Standards for ECDIS (with RCDS mode)

Note by the Russian Federation

1　　　　With reference to the proposal of NAV 44 to revise resolution A.817(19) including an RCDS mode draft performance standard, the Russian Federation, considering first of all the safety of navigation and the results of technical analysis of the draft standard, notes the following:

2　　　　Conflicts within documents - The inherent limitations of raster technology, as currently utilized in RCDS (listed in documents NAV 44/7/10, NAV 44/7/1 1 and NAV 44/WP.2, annex 3), generate unresolvable conflicts among paragraphs of the revision of resolution A.817(19).

3　　　　Technical standards and type approval may be impossible - Due to noted conflicts among paragraphs of the revised standard, it is doubtful that the necessary technical standard and type approval may be achieved in any functional manner. Our expertise indicates that it will be nearly impossible to develop an RCDS, which can obtain type approval in strict adherence to the proposed draft performance standard.

4　　　　Lack of a true raster product specification - NAV 43 requested that a raster navigational chart product specification be developed BEFORE the adoption of the RCDS performance standard. IHB submitted to NAV 44 a draft recommendation for such a product specification (NAV 44/7/8, appendix E). This paper was never discussed during NAV 44 due to lack of time, and cannot be accepted as an international document intended for the standardization of chart data as it fails to define the primary element of standardization - raster data structures. According to this document "the national hydrographic office producing the raster nautical chart should select the data structure". This is clearly insufficient for the needs of both industry and users.

I:/MSC/70/11-8.WPD

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