AIS mandates in the USA, the Coast Guard speaketh
Just online this morning is the USCG’s latest proposed rulemaking regarding the use of AIS by commercial vessels (and also expansion of the Notice of Arrival and Departure requirements). While the PDF weighs in at 94 pages—and contains some required bureaucratic folderol (that must drive writers nuts)—the suggested regulations make a lot of sense and will significantly improve marine safety, I think. Once refined and enacted—the USCG is hoping for 2010 mandates—the new rules will also be a boon for the manufacturers and installers of Class A or Class B AIS transponders, or both. You see, while the CG has a very specific idea about which formerly-exempt vessels should be made to carry AIS—17,442 more tugs, fishing boats, dredges, passenger vessels and others, to be exact—and endorses Class B technology with vigor, it also recognizes the superior performance of Class A, and is asking all parties involved to help decide which gear should be required on which new classes of mandated vessels…
Some commenters recommended that the Coast Guard permit the use of AIS Class B devices. We agree. Since publication of the 2003 final rule (68 FR 60559) and through the diligent work of various standards bodies, we now have AIS Class B devices that are interoperable with AIS Class A devices. Class B devices differ slightly in features and nature of design, which reduce their cost (on average half the cost of Class A devices); however, their performance is somewhat limited. They report at a fixed rate (30 seconds) vice the Class A’s variable rate (2-10 seconds dependent on speed and course change). They consume less power, but also report at lower power (2 watts versus 12 watts of AIS Class A), thus impacting their broadcast range. Despite these design limitations, and after extensive testing by the Coast Guard Research and Development Center, we deem AIS Class B devices can operate properly and safely amongst Class A devices and offer similar AIS benefits. They broadcast and receive virtually the same vessel identification and other information. They have the same ability to see targets that radar may not always show (around the bend, in sea clutter, or during foul weather). For these reasons, we have concluded that AIS Class B devices do enhance navigation safety and assist in collision avoidance comparable to AIS Class A devices; however, given their design limitations, we caution users that they may not be the best alternative for vessels that are highly maneuverable, travel at high speed, or routinely transit congested waters.
The Coast Guard seeks comment in this NPRM on whether AIS Class B devices should be permitted only on certain vessels or waterways, or whether this decision should be best left to the master or owner’s discretion.
Mandated AIS usage is subject to “effective operating conditions” and the new rules smartly intend to spell those out:
(i) ability to reinitialize the AIS (knowledge of system password)
(ii) ability to access AIS information from conning position
(iii) accurate broadcast of an official MMSI
(iv) accurate input and upkeep of all AIS data fields 'and system updates'
(v) continual operation of AIS and its associated devices when underway, at anchor, or moored in or near a channel, except when its use would compromise safety or security (securing an AIS for the later must be logged and reported to USCG)* AIS text messaging must be conducted in English and solely to exchange or communicate navigation safety information
* AIS is primarily intended for use of the master or person directing the movement of the vessel, who must maintain a periodic watch for AIS information
* Spells out that use of AIS does not relieve the vessel of Navigation Rules duties regarding sound, lights or shapes nor Bridge-to-Bridge radiotelephone requirements
Which means, I think, that all commercial vessels using AIS in U.S. waters are going to have to clean up data irregularities, and at least have target info near the conning position. (Interestingly, the CG states in the proposed ruling that it would like to mandate target display on an electronic charting system, but can’t until such systems are better defined, a process which is underway.) I’ve asked if “effective operating conditions” might also mean that a mandated vessel can not filter out Class B targets, but I think that liability issues will take care of that overblown issue anyway.
At any rate, this is just the beginning of a rulemaking process I intend to keep an eye on (e-mail notifications are available at the same Regulations.gov site). At the moment I don’t have a strong opinion as to whether any of the newly mandated commercial vessels should be required to use Class A instead of B, though those 25–knot Water Taxis I mentioned yesterday would surely plot better if A equipped. What do you think?
I strongly support the requirement that all commercial vessels be equipped with AIS.
Regarding A vs B I don't see anything in the electronics of the A that necessitate it costing twice as much to build and I doubt the regulatory hoops are any more difficult (FCC, etc.). I suspect the price either reflects 1st generation hardware that has not been cost reduced, or high profit margins because the A systems were going to customers who were required to make the purchase.
I think there is a clear opportunity for someone to bring to market a class A system at class B prices. It won't be any of the established vendors, they won't gore their own ox, especially during these economic times. But we may see a new vendor who sees the opportunity to grab a lot of share, especially if the CG is about to increase market demand.
So, what if the cost were the same, why allow or require A vs B? Wouldn't we all prefer to be receiving better information (i.e., more frequent and at greater range)? These update rates are all theoretical; your receiver does not necessarily receive every update from every AIS. Who wants to watch a target jump across their screen because you miss one class B update and the target with a speed of 15kt has travelled 1,500m and made a turn since the last update?
If the argument for B is that an "all A" world would cause too much congestion on the AIS channels, then the CG/FCC had better get some regs on the books to limit the use of A very soon because telling pleasure boats they can't use A will cause a lot of grief as the installed base of A continues to grow.
In summary, require AIS on every commercial vessel, hope that a new vendor emerges to lower the cost of A and forget about B altogether.