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Annex 3 - Draft Text Developed by Discussion Groups
Input for IMO from the IALA Seminar on Long Range Tracking - Global Tracking
 IALA, in conjunction with the Light Dues Board Peninsular, Malaysia held a Seminar on 'Global Tracking of Vessels' from Nov. 9 -11, 2005 in Kuala Lumpur, Malaysia. The Seminar focused on clarification of long range tracking and what is meant by long range tracking, involving all aspects (SAR, Pollution Prevention, Security, IT, etc.).
 
 Four key objectives were identified:
・Clarify the purpose of long range tracking;
・Define long range tracking in the overall concept of e-navigation;
・Define roles and responsibilities within long range tracking; and
・Provide input to COMSAR on requirements of long range tracking.
 
 To ensure the objectives were met, the seminar format included presentations and discussion groups / drafting groups within the context of the seminar.
 
 The goal was to build on work already underway in IMO. To ensure this, reference documents from both COMSAR and MSC were available for delegates. Discussion groups dealt with issues at the Technical, Functional and Policy/Legal levels. The results of these discussions, as agreed during plenary sessions, are presented for consideration.
 
 It is proposed that the agreed LRIT system be kept as simple as possible and that any requirements proposed have minimal impact on legacy shipboard systems. The comments provided in this document do not alter any aspects that have already been agreed at IMO, rather they provide proposals for those aspects that remain under debate.
 
Functional Requirements
 Elements included in this submission:
・Data Elements
・Reporting Interval
・Security of Prescribed Equipment
・Area of Coverage
・Latency
 
Data Elements
Parameter Comments
Data to be transmitted from the onboard equipment Unique equipment Identifier The Identifier used by the onboard transmitting equipment.
Position The GNSS position (latitude and longitude) of the vessel (WGS84).
Time Stamp 1 The time (UTC) associated with the GNSS position.
Data to be added by the LRIT Tracking Service LRIT Tracking Service Identifier The identity of the LRIT Tracking Service to be clearly identified by an approved Unique Identifier.
Vessel Identity 1 The IMO number and MMSI number for the vessel.
Time Stamp 2 The time the position report is received by the LRIT Tracking Service.
Time Stamp 3 The time the position report is forwarded from the LRIT Tracking Service to the LRIT Data Centre.
Data to be added by the LRIT Data Centre LRIT Data Centre Identity The identity of the vessel to be clearly identified by an approved Unique Identifier.
Vessel Identity 1 The data forwarded from the LRIT Data Centre to Contracting Governments is to include the IMO number and MMSI number for the vessel.
Time Stamp 4 The time the position report is received by the LRIT Data Centre.
Time Stamp 5 The time the position report is forwarded from the LRIT Data Centre to a contracting government.
 
Reporting Interval
 For reporting interval (also known as reporting rate) the proposal identifies achievable and realistic goals.
1. There should be no onboard interaction required to transmit position reports
2. Contracting Government to have the capability to request a position report on demand
3. Contracting Government to have the capability to determine a reporting interval on demand
4. Capability to deliver a minimum reporting interval of 15 minutes or less
5. A default maximum reporting interval of [every 6 hours] to monitor the 'health' of onboard equipment
 

1 Either the LRIT Tracking Service or the LRIT Data Centre may add these, but the responsibility to ensure the data item is added rests with the LRIT Data Centre.

 
Security of Prescribed Equipment
 While it is proposed that an internal GNSS be required, it is recommended that a grandfather clause be included in the Functional Requirements to allow for a phased in approach over a 3 - 5 yr time scale.
 
 Key elements required of the equipment to minimize security breaches include:
1. The equipment must have an internal GNSS
2. The internal GNSS to be configured for WGS84
3. The internal GNSS must override any external position source or provision to enter manual position reports
4. The GNSS and data communications applications of equipment should be highly integrated so that the link between them may not be readily accessed in manner that may compromise the integrity of [data to be transmitted from the onboard equipment]
 
Area of Coverage
 It was agreed that the existing text in MSC 81/5/1 is sufficient. (Sea Areas Al, A2, A3 and A4 as defined in regulations IV/2.1.12, IV/2.1.13, IV/2.1.14, IV/2.1.15)
 
Latency
 Operational requirements and situation management require a limitation on maximum latency for LRIT information.
 
 Within the reporting requirements prescribed by the SOLAS amendment LRIT Equipment must be capable of delivering LRIT data to LRIT Tracking Services in near real time irrespective of where the vessel is located. In particular, this includes:
5. For pre-scheduled position reports the latency for forwarding LRIT data to LRIT Tracking Services must be 5 minutes or less.
6. For "On demand" position reports and messaging the latency for forwarding LRIT data to LRIT Tracking Services must be 10 minutes or less.
7. The availability of service should be 95% of the time over a 24-hour period and 99% over 1 -month.
 
Technical Requirements
 Elements included in this submission:
・Confidentiality (technical solution aspects - for policy / legal aspects, section 3, bullet 3, refers)
・Information provided to the LRIT Data Centre.
 
Confidentiality
・Data should be protected during collection and distribution to the extent necessary to ensure that data can not be readily interpreted if intercepted by an unauthorized party.
・The LRIT data collection system should provide for a level of authentication and verification so that data provided by an unauthorized user will not be accepted.
・The LRIT data distribution system should provide for a level of authentication and verification so that data will not be provided to an unauthorized user.
 
Information provided to the LRIT data centre
 Service providers should have the freedom to determine how to get data from the ship to the LRIT Data Centre. The LRIT Data Centre should determine the process and format for data transfer to parties entitled to the data (i.e. Contracting Governments) as identified in the audited relationship between the Centre and the Flag State (Section 3 refers).
 The following information should be provided to LRIT Data Centre, preferably in the order presented:
8. Ship ID - The [LRIT] service providers may utilize various identification numbers. The data received at the LRIT Data Centre should include the IMO number as the unique ID. It is recognized that the IMO number is not necessarily sent from the ship, but it must be available at the LRIT Data Centre to validate the vessel identity. This could be provided by the ship owner, through a linked data base process or some other suitable means when the data enter the LRIT Data Centre.
 
 The LRIT Data Centre should have the capability to translate the unique ID number provided by the LRIT service provider to MMSI, IMO number (see footnote, section 1).
・MMSI: First 3 digits identify flag. This is as used for VTS and GMDSS purposes as well as to associate EPIRB messages with ship identification. The Flag State must determine who has the right to receive data. If MMSI alone is used, the LRIT Data Centre will need a database, or access to a database that relates MMSI to IMO Number.
・IMO Number: This never changes for the ship, but the MMSI changes with Flag change. Processes to disseminate changes of MMSI exist, and these processes should be expanded to include forwarding of information to the LRIT Data Centre as well as related communications centres. The process for updating of communications systems information must be easily implemented and should ensure complete dissemination of the information in a timely manner.
 
 Consideration needs to be given to the length of time required for flag states to change database.
9. Time - UTC should be used for position fix (not time of transmission). Minimum accuracy required is to nearest second (HH/MM/SS).
10. Lat/Long - WGS84 should be used. Minimum resolution for the position report is to nearest second of arc. It is noted that data stream in existing equipment contains enough space to provide position accuracy of metres.
 
Policy / Legal Requirements
 It is stressed that the resolution of the Coastal State tracking issue is as important as the Flag and Port State issues to the successful implementation of LRIT. The legal basis for LRIT can be derived from UNCLOS, however concern arises when the receipt of information is confused with enforcement activities. The distance for tracking from coast baselines of a Contracting Government should not be a major concern because the collection of information does not infringe on the freedom of navigation as defined in UNCLOS.
 
 It was recognized that the draft SOLAS V regulation 19-1/9 notes the importance of the confidentiality of LRIT information and it is recommended that this be embodied in any terms of reference for the LRIT oversight body.
 
 In addition, the draft SOLAS V regulation creates a relationship between Flag States and the overseeing organization for LRIT. The existence of this relationship should be audited as part of the IMO Voluntary Flag State Audit Scheme.
 
 It is recommended that documentation for LRIT responds to the following policy / legal elements:
 
・Replace the term 'Coastal State' with 'SOLAS Contracting Government'.
 
 The term Coastal state is not actually used in SOLAS, however the other two terms - Flag State and Port State - are included in the text of SOLAS.
 
・Define the range from the coast at which a Contracting Government may wish to obtain LRIT information from passing vessels. It is suggested that a distance as agreed by the Contracting Governments be used.
 
 In the case where a Contracting Government has a SAR region that extends beyond the limit identified, such a Government should be entitled to receive LRIT information for ships in the SAR region free of charge in response to a SAR incident.
 
・Include reference to the requirement for confidentiality of information.
 
 Confidentiality can be dealt with at a technical level (Section 2. 1 refers), however it must be included in the policy level to ensure it is consistently achieved.
 
・Include terminology to provide flexibility for Contracting Governments to enter into bilateral or multi-lateral arrangements to obtain LRIT information.
 
 Flag States may recognise the benefits of their ships reporting to another Contracting SOLAS regulations for bilateral or multilateral arrangements.
 
・Separate aspects of 'information collection I dissemination' and 'enforcement'.
 
 LRIT, as an information collection system, does not contravene UNCLOS, however any enforcement response stemming from LRIT information is limited by compliance with UNCLOS, as recognised by draft SOLAS V regulation 19-1/3.


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