RADAR Question

[captfish]

Greetings. I am currently crewed up on a tug that operates on the west coast, primarily in Puget Sound, but also occasionally to Canada and down to California. The vessel is <200 GRT, and we tow petroleum barges.

The wheelhouse has two old radars. One ancient Furuno without offset EBL or index lines, the other a tiny Raytheon with a screen barely bigger than my outstreched hand. Neither one is stabilized, as the vessel does not have a gyro of any type (auto pilot runs off mag compass). The company is not interested in upgrading the equipment, which would greatly improve the safety of navigation...so, I was hoping to find a regulation that would justify new radars- as I suspect that ours are not up to code:

[Code of Federal Regulations]
[Title 33, Volume 2]
[Revised as of July 1, 2009]
From the U.S. Government Printing Office via GPO Access
[CITE: 33CFR164.72]

[Page 627-630]

TITLE 33--NAVIGATION AND NAVIGABLE WATERS

CHAPTER I--COAST GUARD, DEPARTMENT OF HOMELAND SECURITY (CONTINUED)

PART 164_NAVIGATION SAFETY REGULATIONS--Table of Contents

Sec. 164.72 Navigational-safety equipment, charts or maps, and publications

required on towing vessels.

(a) Except as provided by Sec. 164.01(b), each towing vessel must
be equipped with the following navigational-safety equipment:
(1) Marine Radar. By August 2, 1997, a marine radar that meets the
following applicable requirements:

[[Page 628]]

(i) For a vessel of less than 300 tons gross tonnage that engages in
towing on navigable waters of the U.S., including Western Rivers, the
radar must meet--
(A) The requirements of the Federal Communications Commission (FCC)
specified by 47 CFR part 80; and
(B) RTCM Standard for Marine Radar Equipment Installed on Ships of
Less Than 300 Tons Gross Tonnage, RTCM Paper 71-95/SC112-STD, Version
1.1, display Category II and stabilization Category Bravo.
(ii) For a vessel of less than 300 tons gross tonnage that engages
in towing seaward of navigable waters of the U.S. or more than three
nautical miles from shore on the Great Lakes, the radar must meet--
(A) The requirements of the FCC specified by 47 CFR part 80; and
(B) RTCM Standard for Marine Radar Equipment Installed on Ships of
Less Than 300 Tons Gross Tonnage, RTCM Paper 71-95/SC112-STD, Version
1.1, display Category I and stabilization Category Alpha.

When I go to the Radio Technical Commission for Maritime Services (RTCM) website: https://ssl29.pair.com/dmarkle/puborder.php?show=8 they want $15 for the document referenced in the CFRs? bullshit.

Does anyone have a copy of this document that they would be willing to share, or know where I can find it online without having to pay the $15 fee? Yes, I'm sure there is a copy in our office somewhere...and no, they don't want me to read it [because it may justify new RADARs for the boat].

Thanks for your help.

[Capt. Fran]

Capt. Fish,
I don't have that document, but I want to thank you (!) for looking up stuff first and then asking a direct question! Holy crap I am sick of posters not searching for stuff before they splew on the forum!
Good on you, lad! And I'll ask my nerdy tech sparky type friends if they might have a copy of your paper.
Fran

[rjbpilot]

Looks like you have a sound argument. I am amazed your company would not want the upgrade. A couple thousand dollars is a drop in the bucket compared to an "incident"......

[mvittone]

Given that

1. this is the line of work I am in

and..

2. because it is my line of work the purchase is deductible

and..

3. A complete library makes me happy

I bought the publication....I should have it electronically in a day (I hope) and I'll get you an answer.

Best,

Mario

[captfish]

Wow...thanks to all of you! RJBPilot: you would think that this company would want the best equipment on their tugs (especially towing oil!). Sadly, this is not always the case...

Mario: How can I thank you? I can't wait to find out what that document says. At the end of the thread, we will all be a little smarter, and probably a bit geeker too!

-Eric (capt.fish)

[mvittone]

It took a few hours, but I finally received the aforementioned document -

Its about 20 pages and says a lot of things, but what follows are the requirements that answer your question.

(disclaimer: The views and opinions expressed in this posting are those of the author, and not necessarily those of the Department of Homeland Security or the U.S. Coast Guard)

The display for ALL ships shall (among other things):

~ have a means of plotting target track history
~ provide the following range scales of display: .25, .5, .75-.8, 1.5, 3, 6, 12, and 24 nautical miles (minimum)
~ the range scale and distance between range rings shall be shall be clearly indicated at all times

Category I requirement:

the equipment shall - without external magnification - provide a relative plan display in the head-up unstabilized mode with an effective diameter of not less than 180 millimeters (9")

(Mario's note - so it would seem that any display less than 9" is therefor disqualified?)

~Range rings are required - at least 2 for the .75-.8 mode and 6 range rings for all other modes

Here is one you may not have on older systems:

~ A variable electronic range marker with a NUMERIC readout of range SHALL be provided.

~ fixed and variable rang rings shall be capable of being turned on and off independently.

Now on to stabilization:

~ Azimuth stabilization is mandatory for all category ALFA ships.

.....I know - I could have said that first and gotten it over with, but I was trying to convey as much info as practicable.

Eric: how you broach the subject with your boss is entirely up to you, but it doesn't appear that the RADAR systems you described meet the requirements as described in 33 CFR 164.72 - If you would like additional (and official) guidance, you can contact the Marine Safety Center via email at MSC(at)uscg.mil - Additional Contact Info

I hope that helped.

Best,

Mario

[captfish]

I hope that helped.

Mario- my sincerest thanks for all of you help with this matter. Acquiring the document to share with this community, reading it, and then posting your findings: that was above and beyond. On behalf of all gCaptain boat geeks and those interested in improving safe navigation, thank you. This is what makes this forum an invaluable tool to the professional mariner.

I will take a close look at our RADARs tomorrow morning with a cup of coffee in hand. One thing is for sure: we do not meet the stabilization requirement, as we have no gyro or sat compass. And, I have a feeling that we are short on a few of the other items.

My original comment about my company's reluctance to upgrade the RADARs may have sounded a bit snarky...and it was. But, I do understand why.

Following my request for a new-er RADAR the response from our Port Engineer was: "That boat has two functional RADARs and everyone's managed just fine with them for forty years!" Without the documentation to back up my hunch about the equipment not meeting the standards, I didn't have a very solid argument (at least to him).

I now have the tools I needed to get this done. Even if the Port Engineer shrugs off my request, I can file a Non-Conformity Report under our company's SMS, which will then end up on the desk of the general manager. When confronted with the regulation, they will have no choice but to upgrade the equipment. Which, is something they should just do on principle anyway...but, that's another discussion.

You now have a copy of this enigmatic document for your library, and hopefully it will help you better preform your own job duties. To be sure: I have never met an inspector here on the west coast that had a copy of that paper in their bag. Inspections of the RADAR equipment by the USCG or ABS in my experience is not vary thorough- usually they just check to make sure the thing turns on!

Thanks again- I'll post to this thread again when my requisition is approved and/or when they respond to my NCR.

Regards,
Eric

[skinny stick]

are there any job openings at your company? I need to get out of the gulf

[herokitty]

Don't forget the beam width requirement for Cat 1 and Cat 2 is 2.5 degrees. Typically at a minimum the array would need to be over 3ft to meet this requirement. Also, just for clarification the 180mm display reference is to the actual radar "PPI" or inside the bearing scale where radar targets can be displayed. So… Just because the radar has a 9" LCD or CRT display doesn’t mean that it meets the minimum display size requirements. Typically the minimum display size to accommodate the 180mm PPI requirement is a 12" LCD or CRT.


B/R,

HK

Mario- my sincerest thanks for all of you help with this matter. Acquiring the document to share with this community, reading it, and then posting your findings: that was above and beyond. On behalf of all gCaptain boat geeks and those interested in improving safe navigation, thank you. This is what makes this forum an invaluable tool to the professional mariner.

I will take a close look at our RADARs tomorrow morning with a cup of coffee in hand. One thing is for sure: we do not meet the stabilization requirement, as we have no gyro or sat compass. And, I have a feeling that we are short on a few of the other items.

My original comment about my company's reluctance to upgrade the RADARs may have sounded a bit snarky...and it was. But, I do understand why.

Following my request for a new-er RADAR the response from our Port Engineer was: "That boat has two functional RADARs and everyone's managed just fine with them for forty years!" Without the documentation to back up my hunch about the equipment not meeting the standards, I didn't have a very solid argument (at least to him).

I now have the tools I needed to get this done. Even if the Port Engineer shrugs off my request, I can file a Non-Conformity Report under our company's SMS, which will then end up on the desk of the general manager. When confronted with the regulation, they will have no choice but to upgrade the equipment. Which, is something they should just do on principle anyway...but, that's another discussion.

You now have a copy of this enigmatic document for your library, and hopefully it will help you better preform your own job duties. To be sure: I have never met an inspector here on the west coast that had a copy of that paper in their bag. Inspections of the RADAR equipment by the USCG or ABS in my experience is not vary thorough- usually they just check to make sure the thing turns on!

Thanks again- I'll post to this thread again when my requisition is approved and/or when they respond to my NCR.

Regards,
Eric

[cappy208]

Dredging back.... WAY back. These early radars had the ability to be geographically referenced by the operator to get the relative speed, and by switching to plotting mode you could determine the relative motion and course of the target.

This has nothing to do with the new radar requirements you are getting info on.

A vessel over 200 tons does NOT HAVE to have the 180 mm tracking (ARPA) ability, but if it does, then everyone must have the ARPA license.

I think what your port engineer is referring to is the fact that these radars are all that is/was required, and there is no new requirement (yet) but I would'nt hold my breath waiting to be inspected to change it.

[Sea Clutter]

This thread caught my attention because the subject recently came up here on the Gulf Coast. It appears that Cat I (offshore) towboats over 12 meters and under 300 gross tons have to comply with the minimum 180mm (12") display, stabilized display (north up), and the 2.5 degree antenna beam (3' open array) requirements. However, a Cat II (inland) only has to comply with the 2.5 degree antenna beamwidth. No display size requirement and stabilization is optional. Your existing radars might could be made compliant if they're capable of north up, and most are, by inputing heading. However, with a magnetic compass only, you'd probably have to use a GPS/Satellite compass for that.