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International Workshop on Maritime Autonomous Surface Ships and IMO
regulations
Analysis of Regulatory Barriers toAutonomus Ships
Director Per Soenderstrup, Danish Maritime Authority
14 May 2018IMO
The autonomous ship
BACKGROUNDIndustrial rev. 4.0
The Svitzer project Remotelyoperated for navigation
Increasing number of technology projects
Electronic lookout
Test of automation technologyfor navigation
A steep learning curve for authorities and regulators
• In March 2017, DMA published an initial study, focusing on the possibilities and possible technical challenges
• In May 2017, IMO decided to initiate a scoping exercise regarding autonomous ships (MASS)
• December 2017 report on regulatory barriers for autonomous ships in Danish legislation
• Projects on autonomous ships still on a experimental basis – but for how long
https://www.soefartsstyrelsen.dk/Documents/Publikationer/Autonome%20skibe%20DTU%20SFS%20rapport.pdf
Analysis of regulatory barriers
Need for a systematic and well defined approach
Where is the decision made?
Who decides?
On board Elsewhere
System
Human
AL0
AL1
AL2
AL3AL4
AL5AL6
Conceptual
AL0Manually controlled. The operator is on board or controls the vessel remotely through radio link.
AL1 Decision-support on board. The operator monitors and changes course and speed if necessary.
AL2Decision-support on board or from shore. Suggestions for interventions may be provided by algorithms.
AL3 Execution by operator who monitors and authorises actions.
AL4Execution by operator who monitors and is able to intervene. Monitoring may take place from shore.
AL5 General goals are determined by the operator. Monitoring may take place from shore.
AL6 Fully autonomous. General goals may be determined by the system. Monitoring from shore.
09/11/2017
Artificial intelligence - modeling the brain of a navigator …
• It is a fundamental principle of COLREG that ships are controlledby human beings and that navigational decisions are based on a seamanlike assessment
• COLREG is only decisive to who is controlling the ship and not from where it is controlled.
• It is technically possible to replace human vision and hearing with cameras, sensors, radars or other technical means (electroniclookout),
The COLREG challenge
Manned versus Unmanned
The remote operator should be legallysubjected to the same navigationalobligation and liability
Regulatory scoping exercise
Regulatory theme: Navigation and Seaway Regulations Autonomy levels: R and RU
Legal basis:
COLREGS (namely reg. 2, 5, 6, 7 and 8).
Assessment:
COLREGS is based on a fundamental principle of contemporaneous human decision-making and real time assessment taking into regard the ordinary practice of seamen.
Remotely-controlled ships with or without crew (R + RU) will satisfy the requirement of contemporaneous human decision-making to the extent a human will in fact in real time remotely control the ship and make navigational decision
Recommended actions:A common understanding and interpretation of COLREGS in respect of ships on autonomy levels R and RU should be pursued within IMO.
New regulation is required in relation to:
(i) Technical requirements for electronic outlook, remote control, and communication and network systems, including requirements on latency, redundancy and communication breakdown (likely to be included in SOLAS);
What about fundamental convention obligations
Fire fighting
Assistance for personsin distress
Safe manning
Regulatory frameworkGlobal regulations are neededStates’ right to ban ships from its ports and inner waters and to lay down special regulations on foreign ships’ port calls under UNCLOS, articles 25(2), 211(3) and 22, will present a general barrier to autonomous ships to the extent that port and coastal States do not want autonomous ships in their waters, cf. section 4.3.2 (jurisdiction as a coastal State and a port State).
Goal based and functional standards
Data formatExchangeProtocols
The way forward
• Stepwise approach• Hollistic regulatory framework• Function and demand driven
Some conclusions• Issues to address for fully autonomous and unmanned ships is
numerous– Safety of Navigation– Liability and insurance– Manning– Merchant shipping act
• Short term goal– The Conventions has some room for technology driven
innovations but we need to have a common understanding of howfar can we go under the existing regulatory framework
• It should be carefully considered how to get things right
– technology is already far ahead of the existing regulations
– Is the right approach a new regulatory framework rather a verylabour intensive and time consuming walkthrough of the existing instruments
Questions?