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?