MSC 70/11/8
5 Less safety due to subjective interpretation
- The current paragraph 1.2 of the RCDS mode section in the
proposed draft performance standards permits a wide range of
interpretations, from the use of reduced folio of the paper
charts for references to the use of the complete folio of
paper charts, required by SOLAS, with mandatory plotting of
the vessel's track on the paper chart. The discussion of this
draft standard by the Sub-Committee over the past 3 years has
demonstrated that the majority of delegations support the
non-equivalence status of RCDS and so the mandatory use of
"... the complete folio of paper charts ....". It
is quite possible that the lack of precision in this
paragraph may cause conflicts between shipowners and port
State control due to different interpretations of this
paragraph by different national maritime Administrations.
Taking into account the numerous limitations of RCDS,
listed in the above-mentioned documents and the potential
reduction of safety of navigation, the Russian Federation is
of the opinion that paragraph 1.2, must be re-formulated in
order to prevent inappropriate interpretations.
6 Increased costs and further delay to industry
and users - Considering the fundamental changes required to
ECDIS that incorporate an RCDS, in terms of both SW systems
and HW platforms, the additional cost to industry and so
users will easily amount to an increase of US$1 0,000 -
US$15.000 per system. This may raise total system costs up to
US$40,000 - US$60,000. Adjusting systems - which are already
predisposed to the current ECDIS performance standard - will
costs industry millions of dollars in adaptation. In
addition, adherence to the requirements of the draft standard
will necessitate extremely expensive monitors of
significantly increased dimensions than those required for
original ECDIS.
Beyond added costs, it is also estimated that adaptation
to RCDS will require at least two years of development by
most ECDIS manufacturers (from the moment functional
technical standards exist). It should be noted that while a
good portion of true ENC coverage is already being prepared
by HOs, virtually all would be available well within this
two-year period, therefore rendering the adaptation to RCDS a
wasteful and futile effort.
These two factors - increased costs and delayed
availability - can only reduce the market potential for ECDIS
and certainly represent a setback to the focus on the
employment of vector electronic charts.
7 In conclusion - The above arguments
summarizing our technical analysis and the obvious
limitations of RCDS as currently proposed, should call the
attention of all Member States to the insufficiencies of the
proposed draft performance standard as currently formulated.
Such insufficiencies will inevitably exert a negative
influence on the overall progress of ECDIS in terms of:
formulation of clear standards, achieving type approval of
ECDIS with RCDS mode, wasteful investments by industry and
shipowners, delays in the realization of true ECDIS and
potentially negative effect on the safety of navigation.
Action requested of the Committee
8 On the basis of these arguments, the Russian
Federation therefore respectfully advises that this draft
performance standard be returned to the Sub-Committee on
Safety of Navigation for more careful consideration and
subsequent development.
I:/MSC/70/11-8.WPD
