The UK has taken the unique and forward-thinking regulatory position that all its waters should be open to autonomous vessels. Yet the phrase "regulation is a barrier to autonomy" has been uttered in some form at every maritime autonomy conference I’ve attended for the past 5 years.
Whether these regulatory barriers are real or perceived, the full potential of this open approach to maritime autonomy is yet to be realised.
Yes, autonomous vessels are operating commercially in UK waters today and have been for some time. But these operations are only truly unmanned in open waters, in other words where the risks to navigation are minimal.
Unlocking autonomy’s potential in inshore waters
The key to unlocking autonomy’s potential lies in enabling autonomy in navigationally constrained port and coastal waters, what might be considered the tricky "last blue mile" when moving to or from open water to berth.
It’s within these waters that significant barriers to operating unmanned vessels need to be addressed.
Some of the standard risk control measures used today, like the presence of a guard vessel or embarked coxswain, or deconfliction by closing off areas of sea space to other traffic, present significant cost, safety, and operational constraints on the day-to-day use of autonomy. In many cases they negate the entire business case.
There is little commercial reason to operate an unmanned patrol vessel, for example, if it must be accompanied by a manned one.
Of course, a progressive risk and evidence-based approach is needed when introducing any new technology. The problem is the application of onerous risk control measures without a process for safely lifting them.
Around the world, there exist robust, practicable and effective systems for managing risk in ports and harbours. In the UK these flow from the Port Marine Safety Code and include the use of navigation risk assessment (based on the IMO Formal Safety Assessment methodology) and a port safety management system.
There can be an issue with "translating" the risk assessment approach taken by autonomous vessel operators into a language that is compatible with the approach taken by port authorities, but it has been shown that bridging this divide allows port authorities to frame the risks associated with unmanned vessel operation within the existing risk landscape in their jurisdiction.
Importantly, this process identifies the key assumptions around equivalence and the safety metrics needed to manage the risks associated with the integration of unmanned vessels into existing operations.
This opens the door for the development of a pre-defined process to take unmanned vessels from trials to full commercial operations, with the possibility of lifting risk control measures if certain thresholds are met.
Ultimately, it enables an authority to treat Maritime Autonomous Ship Systems (MASS) like any other vessel.
The beauty of this approach is that a single process can be adapted quickly and easily as technology progresses. For larger or faster vessels, higher degrees of autonomy or for multi-modal autonomy.
Using Navigation Risk to enable MASS trials
The assertion that “MASS can’t operate here, it’s too risky” is often based not on quantitative analysis but on qualitative experience. And fair enough, as the authorities are the ones ultimately responsible for the safety of all water users in that area. Yet this cannot be the enduring answer if we are to realise the many benefits of autonomy.
Deconfliction by closing off whole areas of water space for the exclusive use of MASS may be the easiest way to fulfil this responsibility and ensure safety. But it’s not a long-term solution; it’s disruptive to existing operations and means we’re testing these autonomous systems in artificial environments.
Could a navigation risk-based approach offer a more practicable solution?
We know that navigation risk is not static. It may vary geographically, at different times of day or year and according to different meteorological or tidal conditions, for example.
We also know that navigation risk can be accurately quantified, modelled and assessed by combining mariner expertise with the right data.
We believe a consenting process for MASS operations based on navigation risk would enable deconfliction without closing off areas of sea space, by identifying times and routes where risks to other water users are minimised.
Such an approach would provide a “grey scale” of complexity, enabling MASS operators to progress from early testing to full operation via a series of stepping-stones, rather than the all-or-none approach of moving from a designated test area into full commercial operation.
Importantly a navigation-risk based approach would take into account the characteristics of the MASS in question, so we’re not applying the same risk control measures to both small/slow remotely operated craft and larger, faster fully autonomous vessels. And it could be easily adapted to keep pace with technological developments – as new systems or higher levels of autonomy reach maturity.
Having a standardised trials process based on navigation risk would provide clear benefits to MASS operators, allowing them to move to new areas of operation without having to start from scratch.
Any authority that can provide a standardised process for moving from trials to commercial operation, over a fixed timeframe and with pre-defined criteria for success, would be enormously attractive to MASS operators and end-users.
If the UK is to capitalise on our brave regulatory approach that all UK water space is open to maritime autonomy, we need a standardised process for taking MASS through trials and into day-to-day commercial operation.
We would argue that navigation risk assessment is a key part of that process.
Prepared by Tim Wilkes, Innovation Lead.
NASH Maritime is a recognised authority in navigational risk assessment and regularly works with MASS operators, port, and national authorities. To discuss how we can help enable the safe integration of autonomous operations with day-to-day maritime operations, get in touch
References
The Port Marine Safety Code [Port marine safety code - GOV.UK (www.gov.uk)] applies to all harbour authorities and other marine facilities, berths and terminals in the UK.