Wednesday, July 17, 2024

Nautical Chart Carriage Requirements When Traditional Paper Charts No Longer Exist

Traditional paper charts will all be gone in six months; most are gone now. Here is a summary of  the USCG's official chart carriage policy, followed by a short background, some details, and direct links to the references.

(1) A non-ECDIS vessel that is required to carry nautical charts may meet that requirement with NOAA Custom Charts (NCC), providing they are up to date (within 6 months) and made at adequate size and scale needed for safe navigation in the waters covered, and preferably on adequate paper quality for routine navigation plotting underway. 

 (2) A non-ECDIS vessel on inland waters that is required to carry nautical charts may meet that requirement in lieu of any paper charts on board with an ECS of their choice, providing they are viewing official NOAA ENC, using an adequate size screen for safe navigation (large tablet or computer), and the ENC are up to date.   

(3) Vessels in coastal waters, when relying on electronic charting alone, must display official ENC on an ECS that meets more stringent environmental standards that are outlined in NVIC_01-16 (ch 2)—and under further development at the moment. The ECS manufacturer must provide a declaration of conformity. In the meantime, appropriate NCC can be used in coastal waters. 


Sample section of a NOAA custom chart (NCC)

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Five years ago, NOAA announced to the world that they had begun the process of discontinuing all traditional paper charts and related chart products such as raster navigational charts (RNC), PDF charts, etc. They said it will be a gradual process, but all traditional paper charts will be gone by the end of 2024. 

And they have kept their word on this; at the moment, five months from the promised completion date at the end of this year, we have only 195 charts left of the 1100 or so that existed five years ago, and all of those left are marked last edition (LE). They have not been updated for months, and will not ever be. Even these last charts are already historic items. (The last edition of each NOAA chart once discontinued is available at historicalcharts.noaa.gov.)

Traditional paper charts, with their fixed sizes, scales, and coverage areas, are being replaced with new versions of electronic navigational charts (ENC), downloaded at no charge from NOAA. They are updated daily at 0500 UTC. If we want to know what is changed on the LE charts left, we need to check the corresponding ENC.

NOAA is also offering now a new form of printed chart called a NOAA custom chart (NCC) that is based upon the latest ENC data. These NCC play a key role in our chart navigation going forward,  as discussed below.

In short, this historic and impactful revolution in charting is indeed taking place. Several major maritime nations have similar plans for ENC to play a larger role in their chart production, but the US will lead the way, as it has historically with other aspects of electronic charting. The UKHO, for example, had announced a similar deadline for their transition to all ENC, but has since postponed the date, perhaps in part because they had not worked out the carriage requirements that is the topic at hand for US vessels. 

ENC are not a new concept, even though the new reschemed versions are significant improvements over the legacy versions.  ENC have been in use since the mid 1990s.  Since 2018, ENC have been required on nearly all commercial vessels on international voyages. These international ships, and other classes of ships in US waters are required to display the ENC using a type-approved hardware and software system called ECDIS (electronic chart display and information system). But these classes of large "ECDIS vessels" are not a subject at hand, because their rules on charts are not affected by the demise of traditional paper charts.

The International Hydrographic Organization (IHO) specifies the standards for the content and format of ENC in a document called IHO S-57. The IHO also specifies how ENC should appear on the navigator’s chart screen in IHO S-52. An ENC of any nation by definition meets the requirements of  S-57, and ECDIS chart display from any manufacturer by definition meets the requirements of S-52.

In Jan, 2016, the USCG announced (NVIC_01-16) that all commercial vessels not required to use ECDIS, may use ENC in lieu of paper charts, and spelled out the details required. Chart display systems (nav apps and chart plotters) that do not meet ECDIS standards are called electronic charting systems (ECS)—which is not a generic name, it is an official IHO definition. 

This  document was then notably updated in May, 2020 (NVIC_01-16_ch2) and added clarification of the use of electronic versions of other required publications such as the Navigation Rules Handbook, Coast Pilots, Light Lists, and tide and current data—recall that in 2020 NOAA discontinued the authorized publication of annual tide and current tables that use secondary station corrections (Tables 2), and since then it is up to mariners to create their own appropriate tables for required stations using the convenient options at tidesandcurrents.noaa.gov. Tables 2 corrections still in print today are not authorized nor dependable.

Then in June, 2023 an historic internal USCG Policy Letter (NAVPOLTR_01-23) explained the crucial role of NCC. 

Those two documents spell out the rules on chart carriage and display that govern chart carriage after the end of this year when all traditional paper charts will be gone—and they govern the policy right now for areas where there are no paper charts left of an appropriate scale for safe navigation. 

Please read the full documents linked below. My notes here are only brief paraphrases. 


Chart Carriage Requirements During NOAA Chart Sunsetting Plan,

CG-NAV Policy Letter 01-23

(NAVPOLTR_01-23

Key takeaways include...

• Though not stated elsewhere to my knowledge, this document confirms that NOAA custom charts NCC will be accepted as meeting chart carriage requirements, provided:

(1) They are up to date (within 6 months)

(2) Made at an adequate scale and paper size for safe navigation in the waters at hand

(3) Preferably printed on adequate paper quality for routine navigation plotting underway

 • The preference (3) suggests using one of the existing print on demand (POD) chart printers. Several are set up to accept a mariners homemade NCC, and some are offering predesigned NCC options that replicate as near as possible the traditional chart coverages. They are accustomed to chart printing on quality paper.

• The Policy Letter does not rule out individual printing of chart booklets on smaller size paper similar to those used in commercial chart booklets. The economic 34" x 22" option (ANSI D) might meet single chart or booklet applications for smaller commercial vessels.

• The Policy Letter anticipated an important advance in the NCC program that has since been implemented. Namely, in NCC ver 2.0, mariners can save their NCC designs and then return to them and with two button clicks create an updated version of their saved NCC design. We anticipate NCC app ver 3 in mid July.

• Also noted in the Policy Letter is the fact that NCC do not have chart numbers so there are no Local Notices to Mariners presenting proposed or actual changes for specific NCC, but mariners can check on line for latest ENC updates to the regions they have charted and that way decide if a new NCC is needed or not from their saved NCC design—this is a new update to this updates page, making it even easier stay aware of ENC updates that could affect the NCC.

• We have a portal of NCC related links at starpath.com/NCC.

• It should be noted that the Policy Letter has an expiration date of April, 2025. So until something shows up in the CFRs we should be be aware that things could change at that time.

• References: CG-NAV Policy Letter 01-23,  8b (1) and (2)


Use of Electronic Charts and Publications in Lieu of Paper Charts, 

Maps and Publications, 

Navigation and Vessel Inspection Circular number 01-16, 16700.4  

(NVIC_01-16_ch2

Again, please read the full document; it includes an interesting history of paper and electronic charting. My notes are just brief paraphrases, with these short takeaways...

• The rules for electronic charts only (no paper charts on board) are different for inland vs coastal waters, where "coastal waters" in this context means anywhere on the outer coast, seaward of the MLW line.

• On inland and coastal waters, however, the key factor is we must use official NOAA ENC that are up to date and of adequate scale for the navigation at hand. (This is not a major concern, because most suitable ECS (nav apps), and there are many as noted in the NVIC, offer the option to check for latest updates and load all scales available with a couple button clicks.)

• We stress that third-party charts or charts described as "based on ENC", "modified ENC," "Enhanced ENC," etc, do not qualify. For non-ECDIS vessels to rely on electronic charts only, they must use official NOAA ENC, presumably obtained directly from NOAA, who provides them at no charge, updated daily at 0500 UTC when changes are confirmed. Light List changes take about a week or so to enter into the affected ENC updates.

• A non-ECDIS vessel on inland waters that is required to carry nautical charts may meet that requirement in lieu of any paper charts on board with an ECS of their choice, providing they are viewing up to date NOAA ENC, using an adequate size screen for safe navigation. This is not spelled out more specifically here, but we can note that the  IMO Performance Standards for ECDIS, Sec 10.2, calls for a minimum screen size of 270 mm x 270 mm (10.6" x 10.6"), which is about the size of a nominal 13" laptop or an iPad Pro—keeping in mind that ECDIS standards are not required for inland ECS usage. 

• Non-ECDIS vessels traveling in coastal waters when relying on electronic charting alone, must display official ENC on an ECS that meets more stringent environmental standards that are outlined in NVIC_01-16 (ch 2)—and under further development at the moment. The ECS manufacturer must provide a declaration of conformity. In the meantime, appropriate NCC can be used in coastal waters.

• References:  NVIC_01-16 (ch 2), Enclosure 1, Sec B1, A2, B2. Enclosure 2, Sec B7c.

• This NVIC also clarifies that digital copies (PDFs, for example) of tide and current data, Coast Pilots, Light Lists, and Navigation Rules Handbook can also meet similar carriage requirements—which is a reminder to all vessels, even those not formally required to carry such documents, that they can meet prudent safe-navigation document needs with digital products. 

The active government agencies, USCG, NGA, and several divisions of NOAA, make it very easy to download the documents and keep them up to date. Storing them in the library of your favorite ebook reader is one way to organize them, with convenient search, bookmark, and highlight tools. Ship and instrument manuals can be in another library folder.



Sample ENC section of the same region shown above as NCC, viewed in qtVlm. This ENC has  a compilation scale of 1:12,000. It can be zoomed to show detail.


Zoomed section of the above. Many ECS offer the option to highlight sector light coverage; in this case we see the green light marking the top of the main San Diego Bay entrance range


Summary

These basic rules for the smaller commercial vessels that do not require ECDIS seem very reasonable and practicable. The ECS "of our choice" to view the ENC could be any of the many commercial and even free versions available now, such as Coastal Explorer, TimeZero, Expedition, OpenCPN and qtVlm.  All show official ENC with convenient means of chart downloading and semi-automatic chart updating. They run on computers and some on large tablets, and all include the range of functionality wanted in a versatile ECS.  There are certainly numerous others we have not tested. 

The NCC program for the paper chart alternative is very attractive and slowly becoming better known. There is certainly room to improve, especially with regard to terrain coverage,  but this is understood and on the table to be improved. Indeed, with all the GIS information available these days on elevation contours, roads, building, ground cover, and so on, we can expect NCC of the future to be superior in this regard to the limited but valuable examples on the paper charts being discontinued.

Recreational mariners are not directly affected by chart carriage requirements of commercial vessels, but it is fair that they look up to their rules as guidelines to prudent navigation. And all mariners are, of course, bound by Rule 2a ("good seamanship rule") of the Navigation Rules.


Sailing and Navigation Schools

On the water training of students who paid for the training are required to have a USCG licensed instructor and the vessels are required to have authorized nautical charts on board. Between now and the end of the year, if there is still a traditional NOAA chart available of adequate scale for safe navigation then a copy of that chart will meet this need until Jan 1, 2025. After that, the training vessel must have either an NCC made as noted above, or have a tablet or computer showing official NOAA ENC of the area as explained above. Third party charts do not meet the requirement, and viewing on a small screen (ie phone) alone will not meet the need according to the documents presented.  

On the water training in certain restricted waters that do not require a licensed operator do not have these chart requirements, but simple prudence would  call for them in any event.  As noted, Rule 2a still applies to all navigable waters, as do perhaps local and state rules.

It seems logical that all navigation training should begin the transition to NCC in place of the historic training charts, which have frankly been distractingly outdated for many years. We are now working on NCC replacements for 1210tr and 18465tr. The challenge is creating NCC that have adequate labels so the many standard exercise books and tests in use nationwide for decades can be adapted to the new NCC. We also have a unique challenge of how to cover a significant section of 18465tr that is now only covered by a Canadian ENC.

Even though the historic training charts will remain available, it seems a disservice to students to continue to use them. NOAA has helped with this transition in that they use on the NCC the traditional chart symbols for all ATONS, rather than the official ENC symbols. Presumably that will change in a year or two... or at least we will have the option to show old symbols or official ENC symbols.

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Our text and reference books on ENC usage can be seen at   starpath.com/ENC


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I will be adding a series of videos on the background for this post, starting with this one:


The US Nautical Chart Revolution,
Part 1: State of NOAA Charts, Last Half of 2024






3 comments:

Robert said...

At the very top of this excellent article, you say in (1) & (2) that those paragraphs apply to vessels "required" to carry charts.

Everyone definitely ought to carry charts. But, my recollection is that recreational vessels are not required to carry charts.

If that is correct, that would leave most recreational boaters the option to rely solely on electronic charts other than the pure NOAA chart files. So, for example - the often used charting apps for tablets.

Am I missing anything on this point?

David Burch said...

Thanks for your kind words. You are right. Recreational mariners are not required to carry charts beyond what is discussed in the summary to the article... and yes, they are likely fine with popular tools using unofficial charts in most cases. However, if a rare accident might happen based on charting error, ie you hit rock that was not charted and someone was hurt or worse, then after you get sued you would want to sue the third party chart maker, and they would simply say read the EULA you agreed to when you opened the app... where we tell you that these charts should not be relied on for safe navigation and that you must use official charts. All the nav apps using third party charts have such an EULA.

David Burch said...

Since the ENC are free and easily accessible, it seems to me that — regardless of primary navigation system in use — a good solution going forward is just to have an app in your phone such as qtVlm that has a super slick way to load and keep the ENC up to date and then you could just double check a route or chart whenever things might be crucial just to see that all is ok... even if you prefer to use a different app or chart plotter that uses unofficial charts for daily navigation. Also it is almost certain that once this charting revolution settles in, that essentially all apps will implement using official US ENC so that will resolve the issue.