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............. EUROPILOTS .................

The Association of Licensed Deep Sea Pilots

www.europilots.org.uk

'AREA OF CONCERN '

A DISCUSSION DOCUMENT

PRESENTED BY

THE NORTH SEA PILOTS ASSOCIATION

 

 

 

 

 

 

 

comprising :-

EUROPILOTS

PILOTAGE HAUTURIER

VERENIGING VAN OVERZEELOODSEN


 The horrific transport accidents that occurred during and since the autumn of 1999 on land, sea and air have brought to the public's attention various aspects of transport safety. For our Associations the Southern North Sea, and the Dover Strait in particular, is again becoming an area of concern.

Several topics have to be considered:-

The observance of the provisions of
Rule 10.
Behaviour of Fishing Vessels.
Communications
The use of the Deep Water Route
The Channel Reporting Scheme
Overuse of the Global Positioning System (G.P.S.)

Some years ago, before the introduction of the Traffic Separation Schemes, a state of virtual anarchy reigned, particularly in the Dover Strait, with ships choosing their proposed tracks through the Straits almost at random. The introduction of the Traffic Separation Schemes alleviated this problem to a great degree. Now, however, "anarchy" seems to be creeping back into the scheme of things in a number of subtle ways.

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The observance of Rule 10
Most vessels still adhere to the International Regulations for the Prevention of Collision at Sea. These used to be known as "the Rules of the Road", now they are more commonly known, often appropriately, as the Collision Regulations or ColRegs. There is, however, an increasing number of seafarers who regularly ignore the provisions of these rules or who interpret them in such a way as to leave other mariners in their vicinity at best confused, and at worst, in severe danger of collision, loss of life, property and severe pollution.

There are growing numbers of seafarers in charge of vessels transiting the English Channel and Southern North Sea who earnestly believe that once they have their ship safely protected by the purple lines of the Traffic Separation Scheme (T.S.S.) on either side of them they have total right of way over any vessel presumptuous enough to want to cross the T.S.S. in their vicinity. The area around the F3 Lightship and in particular in the Noord Hinder South T.S.S. frequently generates VHF (Very High Frequency ) communications from which it is evident that some ships are frequently demanding "give way" action from a vessel which is required by the ColRegs to stand on.

The Vlieland Junction is also another area where this misinterpretation of the Rules is very prevalent, although the problem of "give way" vessels refusing to give way is common throughout the whole of the North Sea, and presumably the rest of the World.

Behaviour of Fishing Vessels in T.S.S.s
Some fishing vessels also seem to treat the T.S.S.s with contempt and can frequently be observed ignoring the provisions of Rule 10, crossing the lanes at oblique angles as they make their way directly from their home port to their chosen fishing grounds in convoy, or engaging in fishing within the traffic lanes against the traffic flow. Many of these transgressions occur within the radar surveillance area of the C.N.I.S. ( Channel Navigation Information Service ) and no action is ever seen to be taken against such vessels. Indeed in circumstances where a collision has been narrowly avoided, or a rogue vessel has been positively identified by a transiting ship, neither Dover Coastguard nor Cross Gris Nez can take any action, it is left to the Master of the vessel involved to make a report to the Port State Authorities at his next port of call when it would be far too late for any effective action to be taken against the transgressing vessel.

Misuse of Signals
There are frequently observed examples of the misuse of light signals in this area, by a range of vessels, but again in particular by fishing vessels. Very large vessels, obviously in ballast and "flying light", can be seen displaying three vertical red lights, or vessels, usually small coastal tankers, exhibiting a single red light. Fishing vessels in parts of the North Sea often display a flashing orange light and in the Dover Strait it is common to see fishing vessels displaying two vertical red lights, indicating that their nets are fast on an underwater obstruction, happily trawling along at five or six knots. This can be quite dangerous as a vessel seeing these lights may quite rightly expect a fishing vessel displaying such lights to be stationary, making no way over the ground, and then suddenly realise that the fishing vessel is in fact making considerable headway. It would seem that the reasoning behind the misuse of these light signals is to create some element of doubt in the mind of an observer and thereby induce a wider berth from vessels in the vicinity.

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 Misuse of the Deep Water Route
The Deep Water Route to the North of the Sandettie Bank is hazardous enough, being narrow, close to the Southwest bound traffic to port and close to the Sandettie Bank to starboard. It is now very common to observe the Deep Water Route being occupied by ships of all sizes, some with drafts which could not possibly exceed five metres even fully loaded. Transiting the Deep Water Route in Ultra Large vessels drawing in excess of 20 metres can be extremely hazardous. A small vessel hindering the passage of such large vessels may cause a collision, or the large vessel to take the ground at speed. The resulting potential for pollution would be catastrophic, with the fast flowing tidal streams ensuring that the pollution would be widespread. The Deep Water Route is covered by the radar surveillance at Dover and Gris Nez, yet the Coastguard has no authority to police the traffic using the route.

Communications
Despite the introduction of G.M.D.S.S. ( Global Maritime Distress and Safety Systems ), V.H.F. Channel 16 (the distress and calling frequency ) is becoming increasingly overburdened. There are several causes of the overuse of this channel. Ships often use Channel 16 to call services which are given their own dedicated working channels. Is it sheer laziness that these people cannot be bothered to look up the working channels in the A.L.R.S. ( Admiralty Lists of Radio Signals ). Surely this should be included in the passage planning, or have the standards of training fallen so low that some vessels watch keepers may even be unaware that there is such a thing as a list of radio stations? Since the introduction of the mandatory reporting system in the Dover Strait in 1999, we now have both Dover Coastguard and Gris Nez Traffic frequently and repeatedly calling vessels which have failed to report on entering the surveillance area. In addition there is also one continental commercial Coast Radio Station which uses Channel 16 virtually as a telephone exchange. This station is so powerful that in times of high atmospheric pressure, and the attendant enhanced radio propagation, it can be heard as far as the North of Scotland, Denmark and Norway. There is a further aspect of communications that is beginning to be disturbing, that is the refusal of some ships to respond to V.H.F. calls made to them. This is particularly prevalent, though not confined to, the short sea traders and cross channel ferries. Many V.H.F. calls are directed to "unnamed ferry" and no identification is made of the caller, however, some calls are much more precise, and the identification of the called vessel should not be in doubt, whether named or not, and still many of these calls go unanswered. It is difficult to believe that some ferries and other vessels cross the Dover Strait and the Southern North Sea with their V.H.F. sets switched off or the volume turned down, so why are calls being ignored? In some incidences it may be that the vessel being called expects to be asked to give way to a "give way" vessel and therefore ignores the call. In cases where relevant information on a crossing vessel's intended movements is to be passed, ignoring such a call can only be described as arrogance on the part of the vessel being called. Of course, the frequently observed poor command of the English Language may also be a reason for officers on watch not to answer the V.H.F. This also occurs in conjunction with poor training and a lack of knowledge of and/or poor appreciation of the ColRegs.

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Use of G.P.S.
Whilst G.P.S. ( Global Positioning System ) is a very useful tool for the mariner, it appears that it is superseding the need for navigators to monitor their position relative to channels, banks, buoys and other marks. Even the C.N.I.S. is now requesting vessels to give their positions in Latitude and Longitude rather than with reference to a sea-mark. Mariners having the con of their vessels and who know the area well may also experience a delay in identifying a position given in Latitude and Longitude terms instead of reference to land/sea marks and in hazardous circumstances such a position should be instantly identifiable. The knowledge of the area for experienced Masters, Pilots and Skippers of fishing vessels is focussed on buoys, beacons and landmarks etc. to identify their positions. Some vessels, when asked by the C.N.I.S. stations to clarify their position by reference to a buoy, seem to experience difficulty in identifying the mark referred to. This lack of spatial awareness is bound to create difficulties for them if they have to initiate a substantial manoeuvre resulting in disorientation. This will mean that they will have to leave the con and refer to their charts, instead of being able to maintain the con and constantly monitor the situation in progress.

Some Solutions

Rule 10.
In addition to the information on passage planning charts such as B.A.5500, warnings should be printed on all charts showing T.S.S.s, referring to the obligation to obey the Rules of the Road or ColRegs, and in particular the requirements for vessels in, adjacent to or crossing the T.S.S., especially in the areas referred to above. A clear warning should appear wherever relevant.

Communications.
Extend the mandatory reporting schemes by requiring vessels to fax or telex their details before entering the controlled area. The mandatory reporting limits should be extended, particularly to the North East of the F3 Lightship; this may introduce more vigilance when approaching the precautionary area. The extent of radar surveillance coverage should be extended to safely include the F3 and West Hinder Junctions. On entering the reporting area, the ship's details having previously been telexed or faxed, Gris Nez Traffic or Dover Coastguard can quickly identify the reporting vessel without lengthy V.H.F. communication. This short report seems to work very well with cross channel ferries, communication times for their reports often being less than five seconds. The details in the reports should be extended to include bunker figures, as it is quite normal for some large cargo vessels to carry in excess of 5,000 tonnes of heavy bunker fuel, yet at the moment this is not required in the report, but small coastal tankers are obliged to report much smaller quantities of oil carried as cargo. It should also be mandatory to report whether or not a Deep Sea Pilot is being employed, as it is in the written checklist for ships carrying dangerous or polluting goods ( MSN1741 M )

Deep Water Route.
Consideration could be given to establishing some sort of patrol, operated by either the navies or coastguards of the E.U. Nations to police the Dover Strait and in particular the Deep Water Route and keep it clear for those vessels which are constrained to use it. The patrol could also monitor, for further action, the misuse of light signals and VHF.

General Safety.
Can be enhanced by the gradual introduction of compulsory Deep Sea Pilotage, ensuring that an experienced and qualified person is keeping a proper watch, beginning with the largest vessels and those carrying particularly dangerous, polluting, and noxious substances. Whilst U.N.C.L.O.S. (United Nations Convention on the Law of the Sea) indicates that in International waters, vessels have the right of innocent passage, the introduction of Pilotage should not be seen as interfering with that right, on the grounds of Maritime Safety and the prevention of pollution.

 

 Author

Edited by

Edited by

 Captain J.D.Robinson M.N.I.

 Captain Ph.Martin

Captain M.A.Hartog 

 ( for Europilots )

 ( for Pilotage Hauturier )

 (for Vereniging van Overzeeloodsen)

53, West Ella Road, Kirk Ella,

 5, Allee Forain,

 Oesterstraat 57

HULL ..... HU10 7QL 

 76600 ... Le Havre

 4301 ZL Zierikzee

United Kingdom

 France

 Netherlands

     

chairman@europilots.org.uk

philmartin@wanadoo.fr

mahartog@wxs.nl

( readers of "An Area of Concern" should also refer to Europilots F.A.Q.s. page - Q.s. 16 & 17 )

 

 

 


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