INTERNATIONAL
MARITIME ORGANIZATION
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IMO
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MSC 70/11/10
9 October 1998
Original: ENGLISH
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MARITIME SAFETY COMMITTEE
70th session
Agenda item 11
SAFETY OF NAVIGATION
Performance Standards for ECDIS
(with RCDS mode)
Submitted by Italy
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SUMMARY
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| Executive
Summary: |
This document, on the
basis of inconsistencies
and flaws
present in the
proposed revision of
IMO resolution
A.817(19), proposes to
return the draft
revision to the NAV
Sub-Committee
for further discussion. |
| Action to be Taken: |
Paragraphs 5 and 6 |
| Related documents: |
NAV 44/1 4. |
|
1 With reference to the
proposal of NAV 44 to revise
resolution A.81 7(1 9)
adding an RCDS mode of operation
to the ECDIS
performance standard, Italy would
like to point out
the following problems:
Proposed revision of IMO resolution A.817(19):
Ambiguities and interpretations
2 Equivalence and liability The
interpretation of paragraph 1.2
of draft appendix 7
presents some ambiguity which
clearly emerged during
the sessions of the working group.
In fact, the
statement " ...... appropriate
portfolio of
up-to-date paper charts "
was interpreted by
some Administrations as meaning
that the primary
navigational reference must always
be the paper chart
and by some other Administration
as an indication
that it is up to the Administration
to decide which
paper chart portfolio is appropriate
(of course, for
some supporters of RCDS an "appropriate
portfolio" is a portfolio
of no charts, meaning,
in fact, that an RCDS is equivalent).
Within this
ambiguity there is a further
element of confusion:
which Administration should specify
the appropriate
portfolio? The flag Administration
or the coastal
Administration? As the large
majority of Member
States does not support the equivalence
of RCDS, and
this aspect has important implications
for the
liability issues involved, Italy
believes that this
aspect should not be left to
the incertitude of
paragraph 1.2.
3 Authorization to produce an RNC
- The
ability of Member Governments
not to authorize the
production of RNC of their waters
has been used as a
key argument to support the introduction
of RCDS.
This view is rather weak on two
accounts. First,
there is no accepted international
law, or IMO
regulation, that gives this right.
Second, in all
cases of neighbouring countries
this ability would
not spare the Government contrary
to the equivalence,
or anyway afraid of RCDS, from
the damage of an
accident and consequent pollution
in waters only a
few miles away (for instance
in the waters between
Sardinia and Corsica). Therefore,
the use of an RCDS
mode of operation for ECDIS according
to the proposed
draft appendix 7 is likely to
create conflicts among
Administrations.
For reasons of economy, this document is
printed in a limited
number. Delegates are
kindly asked to bring
their copies to
meetings and not to request
additional
copies.
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I:/MSC/70/11-10.WPD
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