On commercial craft we all use Raymarine, Garmin, Simrad type chartplotters – but did you know legally these craft can only use paper charts? New guidelines in the form of MGN319 has been issued to show the route forward.
In this article Paul Glatzel considers whether the MCA have struck the right balance with these new guidelines.
So have the MCA missed the mark with MGN319 Amendment 2?
So the MCA have released the long awaited update to MGN 319 detailing the standards relating to the use of ‘chartplotters’ by commercial operators in the sub 24m market. In doing so the MCA are seeking to address the very obvious elephant in the room when it comes to running a sub 24m vessel – namely that the only legal option presently is to navigate with paper charts as the Raymarine, Garmin, Simrad etc systems we are all using are utilising unapproved charts – and so are ‘not legal’…..but….everyone is navigating with those unapproved charts and systems.
So what are the MCA saying?
Big ships have been able to dispense with paper charts if they install a dual ECDIS system running approved ENCs (Electronic Navigation Charts) with kit meeting numerous installation and performance standards. Whilst there has been the idea of ‘mini-ECDIS’ the reality has been that there are few if any hardware/software options to support this option. MGN319 Amendment 2 basically kicks mini-ECDIS into the long grass, creates a new term SV-ECS (‘Small vessel ECS’) and aims to define the set of standards that they hope the likes of Furuno, Raymarine, Garmin and the like will produce kit for so we can run with legal kit that meets the standard.
The question is have the MCA taken a sensible approach and set achievable objectives?
From a couple of reads of MGN319 the basic rules seem to be:
You can use a multifunction display that meets certain criteria but it MUST be running ENCs issued by a Government Hydrographic Office (eg UKHO). Charts produced by the likes of Raymarine (Lighthouse), Garmin (Navionics) etc are not permitted. That these MFDs must be at least 150mmx150mm for a sub 15m vessel and 192mmx192mm for those over 15m vessels. A Raymarine 12” Axiom Pro2’s viewable screen area is 149.43 mm x 265.66 mm according to my friend (ChatGPT) rather suggesting that the MCA is saying your minimum screen size is a 12” for up to 15m vessels and 16” for over 15m. That these MFDs must offer functionality pretty much inline with what’s expected of ECDIS – eg Display Base, Standard Display, Route Planning & Monitoring, System failure warnings and indications etc etc. You will need a backup which can be, a second SV-ECS installation, fully up to date paper charts or could be a tablet running ENCs with functionality similar to an installed system and with its own battery backup. Raster charts cannot be used for the main set or backup. There needs to be an alternative power source in case of failure of the main system.
So what’s our view?
In short this is totally do-able for the big manufacturers. They will need to add some functionality to their plotters but nothing that actually seems that complicated, they will need to drop the use of their charts and use approved ENCs (more of which in a moment).
For operators they’ll need to fit MFDs of 12” plus which is pretty do-able in all but the smaller vessels. Logically fitting two systems would allow one to run radar and one the ENCs – as many do already. There would need to be a battery backup but that’s pretty easy too. There are numerous other stipulations but again these are pretty easy targets to hit.
Will it cost loads?
It depends really on the direction Raymarine and the like choose to go. It doesn’t feel like the cost of the kit would be a whole lot more than commercial vessels are already installing. The MFD manufacturers will lose revenue through not packaging their own charts but perhaps they can find a way to offer all the same functionality and extra information they give us now but with approved ENCs being the centre-piece. I don’t think commercial operators expect anything for free and it may be plotters cost a bit more and operators take a short term hit but it’s do-able. Another factor is whether the MCA’s solution gets worldwide traction as in reality the revenue from the UK for these manufacturers is negligible versus the US or other markets. The weight of the MCA and the reality that there doesn’t seem to be any competitor standards suggests to us it could be a winner. See update below!
And finally…. Well done MCA. We are all happy to criticise but this seems well thought through, logical and most importantly achievable.
So Raymarine, Garmin, Simrad, Furuno and the likes – are you up for it?
NEWS FLASH – UPDATE 15th Jan A really good point was made direct to me relating to this post which was that one of the key costs will be the cost of the ENCs. This is actually a really good point as there can be a significant cost to these for the areas that you may need. Perhaps a shout out to the UKHO then which is they need to join the party alongside the MFD manufacturers and think about realistic costing for their products – in the sub 24m world we do not have the revenue of the big boat world. It may be that the manufacturers can find a way to licence the charts through themselves and sell direct as that’s in essence what they do already as they licence the data from the UKHO (and others) and repackage that to be their propriety product.
Paul Glatzel, Powerboat Training UK
MGN319 – Here
Note: These are opinions are those of the author and may misinterpret any aspect of this MGN. If we have got anything wrong then i) Please tell us ii) Sorry but all of us are fallible! To be on the safe side always seek advice from your Certifying Authority Surveyor before making any decisions.
