Journal 111 article on ECDIS

page 3

Vivian Forbes PhD (UWA), MA (Curtin), FMSIA
Adjunct Associate Professor, Curtin University and Map Curator, University of Western Australia

papers

ECDIS AND POTENTIAL LEGAL
IMPLICATIONS:
PROCEEDING WITH CAUTION
The navigation chart in use by the ship did not show the temporary replacement of a cardinal beacon with a
temporary lateral buoy…
The pilot’s electronic chart system was placed at a significant distance from where he was standing …

Abstract
The electronic chart and associated systems represents an entirely new approach to
marine navigation. Such a system is no longer regarded as simply a computergenerated display on a monitor designed to replace paper charts. An Electronic
Navigation Chart (ENC) and Electronic Chart Display Information System (ECDIS)
are real-time navigation concepts that integrate electronic chart data with various
types of positioning and navigation systems, including Global Positioning Systems
(GPS), Radar/Automatic Radar Plotting Aids (ARPA), shipboard Automated
Identification System (AIS) and the innovative International Ship Facility Security
Code (ISPS) – an integrated, total bridge navigation system.
In 1987, the Harmonisation Group of IMO/IHO was established to develop a
performance standard for ECDIS. It was perceived then, that ECDIS would be
recognised as a legal equivalent to the folio of paper charts that were required to be
carried on ships in accordance with the Safety of Life at Sea (SOLAS) Convention,
namely, that it may be used instead of the paper charts. ECDIS, as an automated
decision-making aid is capable of continuously determining a vessel’s position in
relation to the adjacent land, charted objects, unseen hazards, other vessels in the
vicinity and the prevailing marine environment.

■ At the time of departure was
the ship ‘seaworthy’ in all
respects?
■ Were the navigational aids on
board adequate and in good
working order?
■ Was the Officer guilty of
incompetence within the
meaning…?
■ Was the grounding deliberate?
■ Was there a presence of an
appropriate level of Bridge
Resource Management?
It concludes that whilst it is inevitable
that ECDIS will be universally adopted
such a system must not lull the mariner
into a false sense of security. The system
must not be seen as a substitute for the
observance of good seamanship nor for
neglect of an effective watchkeeping
throughout a voyage. ECDIS and the
paper chart, in tandem, must be seen as
more than an aid to navigation. Reliance

THE HYDROGRAPHIC JOURNAL

on computer-assisted navigation is not a
substitute for the observance of good
seamanship and for the neglect of

maintaining an effective lookout at all
times during the voyage.

Introduction
The words: ‘Land Ahoy’ shouted from the
forecastle (foc’sle) or crow’s nest of a ship
when land was sighted is a distant memory.
Now, through the speaker in the computer
of the integrated bridge system, mutters a
soft, synthesised-human voice warning:
‘Danger Ahead’ that accompanies the
announcement of alarms and flashing
lights related to the approach to hazards
during a voyage. The mariner is now awash
with computer jargon and petrified by legal
terminology.
For centuries, the sextant, the magnetic
compass, the hand-lead line and the
nautical chart were basic tools for marine
navigation. In the latter-half of the 20th
Century, more sophisticated techniques
were developed for position-finding at sea,
such as Radar, DECCA, LORAN, Satellite
Navigation and Global Positioning
Systems (GPS). By the late-1990s, new
technology evolved that combined chart
reading with position-finding, making
navigating easier and more exact.

No. 111 January 2004

ECDIS and Potential Legal Implications

This paper examines the issues that might
arise in a typical court of Marine Enquiry
especially in the context of these leading
questions and statements.

There are two basic types of electronic
navigation charts. Those that comply with
the International Maritime Organisation’s
(IMO) requirements for Safety of Life at
Sea, 1974 (SOLAS) Convention class
vessels, known as the Electronic Chart
Display and Information System (ECDIS),
and all other types of electronic charts,
regarded generically as, Electronic Chart
Systems (ECS). These concepts represent
an entirely new approach to maritime
navigation and offer a versatile and proven
system for any environment. The
electronic chart is a relatively new
technology that provides significant
benefits in terms of navigation safety and
improved operational efficiency – in a
real-time navigation system that
integrates a variety of information that is
displayed for, and interpreted by, the user.
It is an automated decision-making aid
capable of continuously determining a

vessel’s position in relation to land,
charted objects, aids-to-navigation, and
unseen hazards by utilising an integrated
bridge navigation system.
For an ECDIS to meet a minimum
level of reliability and functionality, the
IMO has developed a performance
standard for the system. This standard
specifies how an ECDIS must work in
order that it serves as an adequate
replacement for the paper nautical chart.
The IMO Performance Standards permit
National Maritime Safety Administrations to consider ECDIS as the
functional equivalent to charts required by
Chapter 20, Regulation V, of the 1974
SOLAS Convention.
In conjunction with the development
of IMO Performance Standards for
ECDIS, the International Hydrographic
Organisation (IHO) has developed
technical standards related to the digital
data format, and specifications for ECDIS
content and display. They are IHO Special
Publication 52 (S-52) that includes
appendices describing the means/process
for updating, colour and symbol
specifications, and a glossary of ECDISrelated terms; and IHO Special Publication
57 (S-57) includes a description of the
data format, product specification for the
production of ENC data, and an updating

profile.


page 4

papers

IMO has specifically requested that
member governments encourage their
National Hydrographic Offices (Services)
to produce electronic navigational charts
(ENCs) and provide the associated
updating service as soon as possible, and
to ensure that manufacturers conform to
the performance standards when
designing and producing ECDIS. Herein,
are latent and potential legal
implications. The purpose of this paper is
to highlight the legal implications for the
user of ECDIS, to discuss the roles of the
producers and suppliers of the system and
suggest that users proceed with caution. It
warns manufacturers, mariners and other
users of the legal implications that are
inherent in an integrated bridge
navigation system.

National Hydrographic Offices
(NHO) and the Nautical Chart

ECDIS and Potential Legal Implications

If a maritime nation is to maximise the
benefit to be obtained from the potential
wealth of the adjacent seas and its legal
continental shelf, then it must
systematically search for and assess that
wealth. Tools for use in this search include
the nautical chart and the bathymetric
map. The latter, in some instances may be
the responsibility of a national mapping
authority; the former, falls within the
gambit of the NHO.
One of the highest priorities of a
maritime nation and its NHO should be
the production of modern, accurate, upto-date nautical charts. Facilities for the
progressive updating of these charts must
also exist. Priorities for updating of
information would include the accurate
representation on these nautical charts of
all ports, harbours and their approaches,
roadsteads and anchorages, sea-lanes and
recommended tracks. Further recognition
must be given to convergence areas such
as those adjacent to light-vessels in traffic
separation zones and to offshore
installations such as oilrigs, oil-producing
platforms and other artificial islands.
Consideration should also be given to the
surveying and charting of less densely

navigated areas close inshore and
offshore, and finally, to bathymetric and
marine
scientific
surveys
and
investigations in the oceans and seas
surrounding the coastline.
The Hydrographic Dictionary of the
International Hydrographic Organisation
(IHO) defines a chart as being a map
specially designed to meet the
requirements of marine navigation. The
chart portrays the depth of water, the
nature of the seabed, elevations (heights)
of structures for example, lighthouses and
towers, and terrain (conspicuous to the
mariner from seaward), configurations
and characteristics of the coasts and
dangers and aids to navigation. A chart is
one of the end products of a hydrographic
survey. It is an actual instrument of

No. 111 January 2004

navigation, just as much as a
chronometer, compass, parallel ruler and
pair of dividers, radar, satellite navigator
and sextant are tools that aid marine
navigation. A chart shows such

information as the least depth,
underwater dangers and hazards of the
seabed that may pose a potential endanger
to the ship and lives of its crew. Each
chart is compiled to a natural scale.
The chart is an informative document
that accurately portrays the nature and
shape of the seabed, and it is complete in
all essential detail. The relative position
of each item of data must be portrayed
and maintained with the highest degree of
accuracy. The chart must be compatible
with all other charts in the series.
Accurate tidal data, tidal streams, seabed
data and magnetic variation should be
shown. A suite of publications, for
example, Sailing Directions or Pilots and
List of Lights complement the information
portrayed on charts.
The revised SOLAS Chapter V
Regulation 19.2.1.4 states that all ships
irrespective of size must have nautical
charts and nautical publications to plan
and display the ship’s route for the
intended voyage and to plot and monitor
positions throughout the voyage. Under
the new regulation ECDIS may be
accepted as meeting the chart carriage
requirements of this subparagraph.
For a ship to depend totally on ECDIS

for navigation, (as opposed to relying on
paper charts); under SOLAS Chapter V
Regulation 18, that system must conform
to the relevant performance standards of
the International Maritime Organisation
(IMO) presently specified in Resolution
A.817(19), Performance Standards for
ECDIS, as amended and in particular:
■ Type approval of the hardware
■ The use of official electronic charts
■ Back-up arrangements
■ Training
In accordance with the 1982 United
Nations Convention on the Law of the Sea,
which entered into force on 16 November
1994, coastal and island states are
required to deposit with the United
Nations, copies of the large-scale charts,
upon which is delineated the territorial
sea baseline system. The baseline or
datum is used by that state to measure the
seaward limits of its maritime
jurisdictional zones, for example, the
territorial sea, contiguous zone and the
Exclusive Economic Zone (EEZ). The
charts must be officially recognised by
that state. It has been suggested that,
where the scale of the chart permits,
maritime
jurisdictional

zones
–
international as well as national – should
be delineated. This premise could extend
to delimited maritime boundaries as well

(Forbes, 1987 and 1995). This point alone
illustrates that the nautical chart is more
than an aid to navigation. In the event of
an accident, the chart may be tabled as a
relevant document in the Court of
Marine Inquiry.

Cooperation in the
International Arena
Worldwide, there are 22 national
Hydrographic Offices; seven international
organisations; six major ENC/EC
producers; two producers of ECS/ECDIS;
two discussion fora; and seven other
useful links that are involved either
directly or indirectly with electronic
charting.
The United Kingdom Hydrographic
Office (UKHO) is one of the world’s
premier suppliers of navigational paper
charts and publications to international
shipping with a folio of over 3,300 charts
and 220 publications. Over three quarters
of the UKHO’s charts and publications

are sold to the merchant marine
worldwide to enable compliance with
SOLAS regulations. It has been suggested
that it will be several years before there is
global ENC coverage. In the interim, the
IMO has approved the use of raster charts,
so long as paper back-up is carried.
UKHO raster charts – the ARCS
(Admiralty Raster Chart Series) series –
are scanned images of traditional paper
charts delivered on a CD-ROM and
updated weekly. ARCS offer almost global
coverage.
At the 6th IHO/WEND Meeting
(Norfolk, Virginia, 18-19 May 2001), it
was noted that ENC coverage did not
meet user demand and that this was
inhibiting the acceptance of ECDIS. In
particular, concern was expressed about
the relatively few ENCs that were
available for commercial use at that time.
It was therefore decided that WEND
should undertake a study to determine the
state of ENC coverage. It was noted that
the study should also include:
■ The future plans for intensifying
ENC production
■ The relationship of commercially
available ENCs to the main
shipping routes of the world

■ The need for assistance and
support, including training to
meet these requirements
The International Hydrographic Bureau
therefore issued CL 67 of 2002 requesting
Member States to provide information
concerning their ENC coverage. The
results of this study, which includes cells
that are planned and in production were
presented. Manufacturers, many of whom
have Websites, offer catalogues that
provide information concerning ENC cell
that are commercially available.

THE HYDROGRAPHIC JOURNAL


page 5

Electronic Chart and Electronic
Navigation System

Vector Electronic Charts (ENC)
ENCs are vector charts that also conform
to IHO specifications. They are compiled
from a database of individual items
(‘objects’) of digitised chart data which
can be displayed as a seamless chart.
When used in an electronic navigation
system, the data can then be reassembled

to display either the entire chart image or
a user-selected combination of data.
ENCs are intelligent in that systems using
them can be programmed to give warning
of impending danger in relation to the
vessel’s position and movement.

Accuracy and Status of
GPS/DGPS
The GPS standard positioning system
available to civilian users incorporated a

THE HYDROGRAPHIC JOURNAL

Charts and maps that are compiled using
different datum will show the same
numerical value of latitude and longitude
in slightly different locations. All
geodetic datum are named. The GPS
system is based on the WGS-84 datum,
which covers the entire world. Other
datum may also cover the entire world, or
just a small portion of the planet. By
default, GPS units will depict the ship’s
position on the chart using WGS-84
(World Geodetic System-84) datum.
However, it can also depict the ship’s
position using any one of about 200
different geodetic datum. On most GPS
units the WGS-84 label is highlighted. To

change it to another system, it is a simple
task of selecting the datum of one’s choice
to suit the geographical region.
GPS gives geographical coordinate
values on the WGS-84 geodetic datum.
Many charts are on local geodetic datum
and a correction must be applied to the
GPS position before plotting. For
example, many older AUS charts are on
the AGD-66 datum; the differences
between it and the GPS datum are not
insignificant and are variable across the
country. For some charts, particularly off
the coast of Papua New Guinea, the
correction to be applied to GPS cannot be
calculated and these charts display a
specific warning to this effect. Use of GPS
alone on these charts is hazardous. Many
GPS receivers have the capacity to
automatically
convert
between
commonly used geodetic datum and
WGS-84. Mariners need to monitor this
feature closely as there is a danger of
applying a correction which has already
been applied by the receiver.
In Australia, a datum called Geodetic
Datum of Australia (GDA-94) provides a
single standard for collecting, storing and

applying spatial data at all levels – local,
regional, national and international. The
GDA-94 provides very significant and
substantial benefits to those using satellite
positioning and/or operating nationally or
internationally, for example, the national
hydrographic service. It also provides
direct
compatibility
with
GPS
measurements and mapping or GIS that
are based on the geodetic datum. It
minimises the need for casual users to
understand datum transformation and
reduces the risk of confusion as GPS, GIS
and navigation systems become more
widely used in commercial and
recreational activities.
In the Australian context, the
difference between GDA-94 and AGD
coordinates will vary on an average of 200
metres in a north-east direction because
of the different models. The actual size
and orientation of the change will vary
slightly from place to place. For example,
in the south-west of Western Australia,
the difference may be 175 metres, whereas

No. 111 January 2004

ECDIS and Potential Legal Implications

Raster Nautical Charts
RNCs are raster charts that conform to
IHO specifications and are produced by
digitally scanning a paper chart image.
The image may be either the finished
chart itself or the stable colour bases used
in the multi-colour printing process. The
resulting digital file may then be displayed
in an electronic navigation system where
the vessel’s position, generally derived
from electronic position fixing systems,
can be show. Since the displayed data are
merely a digital photocopy of the original
paper chart, the image has no intelligence
and other than visually, cannot be
interrogated. IHO Special Publication S61 ‘Raster Nautical Chart Product
Specification’ provides guidelines for the
production of raster data. IMO resolution
MSC 86(70) permits ECDIS equipment
to operate in a Raster Chart Display
System (RCDS) mode in the absence of
Electronic Navigational Charts. The
RCDS mode of operation is described in
Appendix 7 of the IMO Performance
Standard for ECDIS.

Geodetic Datum and the

Nautical Chart

papers

The concept of an electronic chart (EC)
was conceived a number of years ago. A
whole new intelligent ship electronic
navigation system (ENS) has evolved
with the onset of Global Positioning
Systems (GPS), other radio navigation
techniques, computer technology and
electronic charting.
In about 1987, the concept of
combining the ship’s position from
LORAN-C or DECCA with an image
from the RADAR, on a computer screen
whose backdrop comprised a scanned or
digitised image of a portion of a part chart
of a particular geographical region was
warmly received (Weeks, 1992:94).
Furthermore, the possibility that the
electronic chart could be corrected and/or
updated by inserting a floppy disk or CDROM would eliminate the tedious process
of manually correcting the charts that was
intended to be used during a voyage.

deliberate degradation of the system’s
accuracy using a technique known as
Selective Availability when it was
introduced in 1993. Horizontal positional

accuracies of 100 metres, at ninety-nine
95 per cent of the time were
guaranteed. However, on 1 May 2000, the
US Department of Defense discontinued
the use of selective availability and a
much higher degree of accuracy
immediately became available. A new
performance standard for GPS was
published in October 2001.
The new horizontal accuracy standards
are based on ‘Signal in Space’ errors. A
stated global average error from GPS
signals of no less than 13 metres and worst
site error of about 36 metres is now
guaranteed. The signal received by the
user on the ground is subject to other
variable influences not included in the
standards and the actual accuracy
achieved will vary with influences of
ionospheric conditions, geographic
location, time of day, and sophistication
of the receiver. A worldwide study over 24
hours at a period of high solar activity was
conducted in June 2000 to determine the
actual accuracy achieved by a
representative single frequency receiver.
The results of the tests were in the
vicinity of 95 per cent of the world-wide
coverage had accuracy better than 16.4
metres at 95 per cent of the time, and all

of the world-wide coverage had an
accuracy of better than 23 metres at 95
per cent of the time. Reliance on GPS for
marine navigation has provided a
quantum leap in navigational accuracy
and reliability, however, it is not infallible
and it is entirely possible for large errors
caused by an ‘unhealthy’ satellite to go
undetected for many hours. Mariners are
thus advised not to put total and
absolute reliance for the safe navigation
of their vessel solely on GPS. It is
stressed that where possible the vessel’s
position must be independently verified
by other means such as radar, gyro
bearings, echo-sounder, and log.
Differential GPS involves the use of
reference stations ashore whose
geographical position is very precisely
known. By measuring the distance
measurements to all satellites in view and
using the surveyed position of the station’s
antenna DGPS is able to: 1) monitor the
integrity of the GPS satellite
transmissions and immediately notify
users to disregard any satellite operating
outside specification; and 2) provide
differential corrections in order to
improve the accuracy of the navigation
solution. For example, the Australian

Maritime Safety Authority’s (AMSA)
DGPS network provides DGPS coverage
to approximately 60 per cent of the
Australian coast. Accuracy of the
AMSA’s DGPS network is specified to be
better than 10 metres at 95 per cent of
the time.


page 6

papers

in the offshore region of northern
Queensland it may be 207 metres. It is
also important to note that grid
coordinates (derived from a projection)
and geographical coordinates (Latitude
and Longitude) depend on the datum and
both sets of coordinates will vary between
the datum used. In other words, a feature
on the ground will have different sets of
geographical and grid coordinates
depending on the datum adopted. The
Australian Height Datum (AHD) will not
be affected by the adoption of the GDA94.
The GDA-94 employs a more accurate
model which is endorsed by the
International Association of Geodesy
(IAG) and to which WGS-84 is being

aligned. For all practical purposes, the
GDA and WGS-84 are the same. The
difference is of the order of 10
centimetres.
In an example taken from the nautical
chart series of Western Australia, WA 966
– Cape Naturaliste, Edition 2 (Australia
West Coast, compiled and produced
Department
of
Planning
and
Infrastructure,
September
2001),
notations appear in the legend box
relating to Satellite Derived positions and
the Geodetic Datum, which states that:
■ Positions - Positions are related to
the Map Grid of Australia, Zone
50, based on GDA 94. For GPS
use, this approximates WGS 84.

ECDIS and Potential Legal Implications

■ GDA - The location of points on
this chart are referenced to the
Geocentric Datum of Australia
1994 (GDA 94) and will differ by
approximately 200 metres to the

same points shown on charts
referenced to the Australian
Geodetic Datum 1984 (AGD 84).
All heights remain the same.
For further information, contact
Department of Land
Administration.
■ Sources - From the latest
information available to
Department of Planning and
Infrastructure, including Royal
Australian Navy surveys of 1975
and other surveys of 2001.
The chart user is warned thus:
The information provided on this chart
is subject to change. All such changes
of a safety or navigational nature will
be promulgated. Ensure that the latest
edition of the chart is used at all times,
and kept corrected with the relevant
Notice to Mariners.

Carriage of ECDIS by
Australian Registered Ships
Under the terms of SOLAS Chapter V
Regulation 19.2.1.4, an ECDIS, which
meets the performance standards of IMO

No. 111 January 2004

Resolution A.817(19) as amended, may
be accepted by a national authority as
meeting the chart carriage requirement as
specified in that regulation. AMSA is the
national authority in this context.
Beyond near coastal waters, (defined as
being outside the Australian Economic
Exclusion Zone) AMSA requires full
compliance with SOLAS requirements
for ECDIS when being used as the
primary means of navigation. This
includes the carriage of an ‘appropriate
folio’ of paper charts as complement to
the ECDIS when navigating on raster
scanned charts, that is, in the Raster
Chart Display System (RCDS) mode of
operation.
For ships within or near coastal waters
a safety case (risk assessment) can be
presented to AMSA, which if accepted
will allow operators to dispense with the
need for paper charts to be carried when
ECDIS is operated in the RCDS mode.

Potential Errors in Marine
Navigation
A difference of the order of 10
centimetres in the marine environment
may be acceptable, but what of a
discrepancy of between 175 and 300

metres. Will your ship be ‘virtually
grounded’? It has been suggested (Casey,
1996:1) that on a number of occasions
chart data, particularly in canals, locks,
harbours, ports and alongside wharves
could not withstand the resolution of the
ECDIS ‘zooming’ function. In many
instances, the result has been that the
ship’s image on an ECDIS display is
depicted as overlapping the dock or jetty.
There are many contributing factors
that may suggest that the ship’s image on
the ECDIS screen is portrayed where ‘it
does not belong’. These are due to GPS
errors; DGPS errors; ECDIS errors;
Installation errors; ENC conversion
errors; chart errors; and hydrographic
survey errors. There is also the factor of
human-induced error. Consider this
finding by the regulatory authority:
The pilot went to his electronic chart
system, which had reverted to a blank
screen stand-by mode. He tapped a key
and when the chart was restored he
suddenly realised that he had ordered the
course alteration too soon. [See Annexe,
below].
The potential GPS error has been
previously discussed. The DGPS is a
complex system as it includes all of the

complexity of the GPS and all of those
things that can contribute to minor, but
cumulative errors when relying on a single
reference station. The errors induced by
DGPS are unlikely to cause mariners
trouble. It is important, however, to guard
against the unnoticed loss of DGPS
signal. It is beyond the scope of this paper
to offer an in-depth discussion of these
potential errors.

Manufacturers of ECDIS integrate the
DGPS information received with ENC
data, to generate the ship’s position on the
ECDIS monitor. Errors in the accessed
data may impact on what is portrayed on
the monitor. Whilst it is inconceivable
that an error in the ECDIS programming
could lead to serious problems it is
nevertheless, difficult to stimulate all
marine-related conditions in any testing
programme. An algorithmic error will,
sooner or later, reveal itself.
Installation error, usually a one-time
error, results when an incorrect value is
used for the GPS antenna position on
board the ship. For example, an error of
10 metres in each of the ‘x’ and ‘y’
coordinates of the positioning would
equate directly into a similar error in the

shape of the ship depicted on the monitor.
When discovered and corrected, it will
not recur unless the incorrect values
reappear each time the system is bootedup – a concept used, when the system is
checked for viruses and general
verification of both the hardware and
software.
Even a faulty ground wire could result
in loss of GPS signals. Although ECS are
programmed to switch to dead reckoning
in cases of a loss of GPS, a faulty system,
undetected by the officer(s) on watch,
may continue to estimate the ship’s
position from incorrect data. The concept
of quality control is required at all phases
in the production and utilisation of an
ECDIS product. Errors may result in the
conversion process when data from an
ENC is used by the manufacturer of an
ECDIS system. Whenever data is
converted from one form to another,
there is the risk of under- or overinterpretation. However, standards have
been established in S-57 Edition 3 and
other IMO and IHO specifications.
A common source of error exists in the
underlying data from which the ENC is
derived. Such errors are a result of the
‘inappropriate’ scaling of the chart data
caused by: survey errors; horizontal datum
errors and uncertainties; unreported

changes; and obsolescent survey
technology. Survey errors can be caused
by a variety of reasons. The data obtained
from the survey is conveyed to the chart
but at a scaled down version. Recall that a
three-dimensional ‘real world’ is portrayed
on a two-dimensional flat piece of paper –
the paper chart, whose maximum
dimension maybe up to an A/0 (841x1189
mm) format. Consider then, the
information contained on that paper
chart, now depicted on a monitor. When
ECDIS is used for docking and
manoeuvring, the navigator may prefer
scales of up to 1:500 and not 1:2 000 or
smaller. A displacement error of 1mm (+
or -) on the screen equates as five metres
on a chart of scale 1:5 000. In the
conventional sense, there was never a
need for very large-scale charts.

THE HYDROGRAPHIC JOURNAL


page 7

Legal Issues: ECDIS & the User
■ Were the navigational aids on
board adequate and in good
working order?

■ Was the ship seaworthy in all
respects?

THE HYDROGRAPHIC JOURNAL

Civil Liability
Recent developments in civil law have
imposed
increased
liability
and
responsibility on Government Agencies
and Authorities that provide services to the
public. The NHO, as an agent to the
Government of a State, providing reliable
information to the user of its products, must
be aware of the legal responsibilities and
duties and to the extent to which the
Government may be liable for shipping
casualties and other marine accidents.
There are three primary elements of
liability. They are: Product Liability; Strict
Liability; and Contract Liability.
In contract liability there exist warranties
– expressed and implied. In the former
instance, these are basically what the
manufacturer and seller describes about the
product; any promises they make about it;
any advertisements and photographs
relating to that product that implies that

the item will perform in the described
manner. The latter is based on the premise
that the product should be suitable for the
purpose for which it was intended. Product
liability exists when the seller is liable for
negligence in the manufacture and sale of
any product which may reasonably be
expected to be capable of inflicting harm to
the user if it is defective. The concept of
strict liability is that liability that is
attached to the manufacturer. The
distinction here relates to the burden of
proof and negligence. This legal concept
applies even though a manufacturer has
taken all possible care in the preparation
and sale of the product and even if the user
has not purchased the item from the
manufacturer or negotiated into a contract
with the manufacturer.
National Hydrographic Offices, as
producers of digital data through which
electronic charts are produced will have
responsibility for these products. They will
be responsible for the accuracy of the data,
and they will be liable for any negligence

that is involved; liable at least to the extent
that their Government allow themselves to
be liable. However, if the NHO is only
producing the paper charts and these

charts, in turn, are copied by the EC
manufacturer to create a digital data base,
then the NHO would only be responsible
for the information that is contained on the
paper chart. If a mistake exists on the paper
chart and it is thereby copied by the
manufacturer that becomes one issue, if the
error has been introduced in the process of
copying, that is another problem altogether.
If the product is packaged by the
manufacturer and sold to a user through an
independent seller – Chart agent – and the
seller does not modify the product or its
package, then the seller would not normally
have any strict liability to be concerned
about. The manufacturers of ECDIS and
associated equipment are responsible for
the design of the hardware and software
that they produce. Their liability exists
independently of the existence of
contractual relationship. The standard of
care and the professionalism required of
them is significantly higher in the context
of product liability. The manufacturer is
obliged: to produce a product that is free of
design or physical defect; to instruct the
user in the proper utilisation and handling
of the product; and to warn the user of the
dangers it knows or ought to know are
inherent in the product’s use.

Legal liability may be based either on
contract or in tort. A Contract is a legally
binding
agreement
upon
legal
consideration to do or abstain from doing
some act and it maybe written or verbal. A
Tort is a civil wrong independent of
contract that gives rise to a claim in
damages. In the former, the liability will
arise if there is an agreement to supply an
accurate chart and the supplier provides an
inaccurate chart. If there is a breach of
contract the user can then sue the supplier
for any damages resulting from the breach.
However, the more common case is a claim
in negligence. The user of the product sues
the Government for the negligence of a
person to act carefully where the law
imposes on that person an obligation to do
so accordingly.
Most manufacturers and suppliers would
state that their product meets and exceeds
IMO and IHO standards. They would
suggest that the equipment possesses a ‘userfriendly graphical interface’ and that
simultaneous overlay of raster and vector
images could be displayed. Furthermore,
they would stress that GPS simultaneously
facilitates the preparation and training for a

voyage providing insurance for a safe
navigation.
Safety and Regulatory Aspects
■ At the time of departure was the
ship ‘seaworthy’ in all respects?
■ Was the grounding deliberate?

No. 111 January 2004

ECDIS and Potential Legal Implications

In general, a ship is not considered
seaworthy unless it has an adequate
portfolio of charts to cover its intended
voyage or voyages. Electronic charts are an
aid to navigation. New navigation
technologies and systems have been
introduced in order to reduce incidence of
shipping casualties. It could be argued that
such technology has also been introduced
at the expense of reduction in ship’s
personnel. There are five major actors that
have input into the effective operation of
these equipment and systems. They are
the NHO (hydrographer, cartographer and
printer) who carry out the survey and
compile the chart; the manufacturer of
ECDIS; the regulating authority; the
shipowner; and the user or mariner.
It is the responsibility of the NHO to

ensure that the information contained on
the chart is accurate and offers an
adequate delineation of the facts which
have been ascertained from the surveys
and other secondary sources. The NHO
does not have a duty to search out
obstacles and record them, unless they are
obvious or readily ascertainable. However,
failure to correctly describe the
characteristic of a light on a buoy or to
depict a shoal extending over the range
line of the chart could be perceived as
misleading and hence a misrepresentation
of the fact.

How confident can the mariner feel
about using digital data in an electronic
form? What are the liabilities and whose
copyright exists on the data? Is there a backup system in the event of total power failure
on board the ship? Is there a voice data
recorder and some means of archiving the
data that relates to a ship’s passage, say in
the past 12 or 24 hours or for the duration
of the voyage. Such concerns are not new.
They have been debated at various fora
since 1990.
The three legal issues relating to the
ENC problem are (a) copyright, (b) safety
and regulatory aspects and (c) civil liability.
These issues are not new. They exist in the

current regime of paper charts. Mukherjee
(1990:18) notes that in the electronic
media – the new regime – there are old
issues that have new implications. There
are many more persons involved in the
production of electronic chart and the
electronic systems that use the chart data.

papers

A concept, termed ‘Blind Navigation
Aid’, is capable of guiding a vessel into a
channel and towards its berth by entering
the ship’s intended track numerically
without reference to the chart. This is
made possible when an Electronic
Navigation System (ENS) is used in
conjunction with DGPS. The concept is
fine in principle, but what of the
unknown quantity? For example, an eddy,
change in wind strength and direction,
the onset of a sandstorm, or another vessel
approaching but changes its intended
action at the last moment` to complicate
the matter, as is often witnessed in
confined waterways, such as a harbour or
approaches to a navigation channel.
In such instances, there is no substitute
for local knowledge. Indeed, any
unreported changes could result in

instances where an ENC has not yet
incorporated new features, such as
reclaimed land, a new jetty or a drifting
buoy. Here, the Notices to Mariners play a
vital role in offering safety to navigation
and in the process of updating the charts
in a folio or in digital media whether it is
ECDIS, ENC or other ENS.


page 8

Many technical problems and ‘glitches’ may arise prior to sailing, during the voyage and
indeed whilst the ship is entering the harbour at the end of the voyage. Let us examine
four prime cases:

papers

Problem 1 – The computer system may consistently crash immediately on starting the
programme.
Solution – this usually indicates that the chart object database that is created by the
program has been corrupted. The chart object database stores all chart objects used by the
system. Unfortunately the only fix to this problem is to delete the chart object database
before you run the program which means you will lose all the chart objects held by the
system unless you have previously Archived them to a file. For this reason it is recommended
that you regularly Archive all your chart objects to a file in case your chart object database
becomes corrupted. To delete the chart object database, delete the senc directory, which is
found under C:/Program Files/???. Then run the program and it should not crash. You can
now import any chart objects that you have previously exported to a file.
Problem 2 – The ship’s GPS is switched on and receiving a signal, but a ‘GPS Failure’

warning is given.
Solution - check that the system is set up correctly for the GPS .The usual setting for a
GPS would be either COM1 or COM2 with a baud rate of 4800. Check that the GPS
is actually plugged into the COM port you specified to the system’s manual. Check the
user manual for your GPS or contact the GPS manufacturer to ensure that your GPS is
sending out NMEA 183 data. Most GPS units can do this, but they may need to be
configured to do so. If you are using the serial cable supplied with the software to run a
GPS and an autopilot off the same port, ensure this is wired up correctly.
Problem 3 – The ship’s autopilot is not responding to the ENC.
Solution – check that the ENC is set up correctly for the autopilot. Also ensure that it
is set up to send the correct NMEA sentences; look in the autopilot manual to see what
NMEA sentence it needs. Please note that autopilot data will only be sent if ‘Route
Tracking’ is turned on, and the ship is under GPS control with a valid GPS signal or in
Dead Reckoning mode with ‘Use autopilot on dead reckoning’ turned on. If you are
using the serial cable supplied with the ENC to run a GPS and an autopilot off the same
port, ensure this is wired up correctly.
Problem 4 – The ECS had reverted to a blank screen stand-by mode. On tapping a key
the chart was restored but the course alteration had been ordered prematurely. The ECS
was placed at a significant distance from where the Officer was standing, with its display
in power-saving mode at a critical moment.

ECDIS and Potential Legal Implications

Amendments to Chapter V of SOLAS now makes mandatory the fitting of Voyage Data
recorders (VDR) units – the equivalent to the ‘black box’ placed on aircraft – on all new
ships of 3000 gross registered tons or more and all passenger ships and roll-on/roll-off vessels.
Copyright
In the current law of copyright, which is developing rapidly by way of legislation as well as
court decisions, copyright subsists in databases. In the case of ECDIS, it is likely that private
entities will collect and hold data. The Governments, through their national hydrographic

office, will also own the data. Computer software is now copyrightable in most jurisdictions.
There is good reason to argue for protection of electronic software. On the other hand,
copyright should not be used to control either the paper or electronic chart. The rationale
for this justification was based on three factors:
1. The paper chart lacks both the morality aspect and the commercial/economic
aspects protected by copyright
2. Even if copyrighting charts cannot be justified in common law, charts are
copyrighted under statutory law which overrides common law. The stated
objective of the statute is safety of marine navigation
3. It is not necessary to use copyright as a means of ensuring safety since there are
other ways to accomplish the objective (Mukherjee, 1990:112)
Carter (cited in MacDougall and Acheson, 1990:110) suggests that three major issues will
come to the fore in the event of a marine accident which relates directly to the use ECDIS
and liability:
1. What is the evidence from ECDIS that can be taken to court in the event of an
accident?
2. How are ‘due diligence’ and ‘seaworthiness’ to be determined in the context of
ECDIS?

No. 111 January 2004

How much information is enough on
ECDIS: where do the responsibilities lie
for changing the ECDIS database and for
updating the ECDIS? As events leading up
to a marine accident and contributing to
the cause can sometimes be unique several
basic questions are asked:
1. Was the chart being used at the
time of the accident?

2. Were other aids to navigation in
use, for example, radar, echo
sounder and other distancemeasuring device?
3. Have the ship’s logbook entries
been altered?
4. Was the officer of the watch
competent to use ECDIS?

Conclusion
ECDIS is an effective tool for safe
navigation, provides real-time information for the mariner and will inevitable
be universally adopted. ECDIS has
demonstrated, particularly in times of
reduced visibility, its cost-effectiveness to
shipping as delays in berthing can be
reduced or eliminated. It is a sophisticated
object database that maintains the
mariner’s navigations objects such as
waypoints, routes, and specific points of
interest and provides very good security
for the user’s navigation data. However,
the mariner needs to have total
confidence in the capability and
limitations of the equipment.
Such a system must not lull the mariner
into a false sense of security. Mariners
must ensure that they do not depend
solely on one system without some means
of occasional cross-referencing or
verification. Audible and visual alarms

must be heeded. The system must not be
seen as a substitute for the observance of
good seamanship nor for neglect of an
effective watchkeeping throughout a
voyage. ECDIS and the paper chart, in
tandem, must be seen as more than an aid
to navigation. ECDIS integrates a number
of key components into a single system.
Thus, the degree of reliance placed
on electronic charts, other nautical
publications and navigational systems
produced by the national authorities and
manufacturers of the equipment
potentially exposes not only the
hydrographers and marine cartographers –
the spatial scientist – but also the
Government.
The legal implications for the misuse or
wrong interpretation of the data are the
same in the current regime as they will be
for the electronic media. The only change
is that there many more entities that must
share the responsibilities. The mariner and
user of the integrated system must be
aware of the terms and conditions that
come with the equipment and of the
warranties – expressed or implied – and

THE HYDROGRAPHIC JOURNAL

page 9

other small print documents they sign.
They should proceed with caution at all
times, maintain an effective lookout and
observe the standards of good seamanship.

Mariners are thus advised not to put total
and absolute reliance for the safe
navigation of their vessel solely on GPS
and manufacturers are warned that they

are liable for warranties which they
express or imply to their clients through
advertising or responses to enquiries.

papers

Annexe
Investigation Report No 181 – Summary
Date: 19 July 2002
Ship’s name: ANL EXCELLENCE

THE HYDROGRAPHIC JOURNAL

The report conclusions include:
■ The pilot did not follow his normal
procedure of checking the position of
the course alteration using his portable

electronic chart system.
■ The temporary buoy marking the
original position of the original east
cardinal beacon E5 (the turning mark)
was obscured by rain.
■ The green light on the temporary
buoy was not as conspicuous as a white
light, which would normally be
associated with a cardinal navigation
mark.
■ Although not suffering from
chronic fatigue, the pilot’s performance was probably affected by the
trough in his circadian rhythm
associated with the hours between
0400 and 0600.
■ The pilot’s electronic chart system
was placed at a significant distance
from where he was standing, with its
display in power saving mode at a
critical moment.
■ The bridge team did not detect the
erroneous helm order and failed to
challenge the pilot.
The report recommends that:
■ Where port authorities use a buoy
or other temporary aid to replace an
established navigation aid, the shape
and the light characteristics of the
temporary aid should be consistent
with those of the aid it replaces.

■ Brisbane Marine Pilots should
review the power management settings
and placement of a pilot’s portable
electronic chart system to ensure that
the information displayed remains
easily visible from the pilot’s conning
position at all times during a pilotage.

Type: Grounding

Conclusions
These conclusions identify the different
factors contributing to the incident and
should not be read as apportioning blame or
liability to any particular individual or
organisation. Based on the evidence
available, ANL Excellence grounded on
Middle Banks on 19 July 2002 as a result of
the pilot erroneously ordering an alteration
of course at the starboard lateral beacon E3
instead of at the temporary starboard lateral
buoy marking the position of the original
east cardinal beacon E5. The following are
considered to be factors in the incident:
The pilot did not follow his normal
procedure of checking the position of the
course alteration using his portable
electronic chart system. The temporary
buoy marking the original position of the
original east cardinal beacon E5 (the

turning mark) was obscured by rain. The
green light on the temporary buoy was not
as conspicuous as a white light, which would
normally be associated with a cardinal
navigation mark. Although not suffering
from chronic fatigue, the pilot’s
performance was probably affected by the
trough in his circadian rhythm associated
with the hours between 0400 and 0600. The
pilot’s electronic chart system was placed at
a significant distance from where he was
standing, with its display in power saving
mode at a critical moment.
The bridge team did not detect the
erroneous helm order as a result of: Both the
Master and Mate were probably fatigued as
a result of their hours of work during the
passage through the Great Barrier Reef,
which was exacerbated by the ‘time of day’
effect. Neither the Master nor the Mate
were sufficiently aware of the ship’s
situation, at the time, to challenge the
pilot’s premature order for the course
alteration.
Insufficient attention was paid to the
ship’s radar display. The navigation chart in
use by the ship did not show the temporary
replacement of E5 cardinal beacon with a
temporary starboard lateral buoy marking
the southeast extremity of Middle Bank.

The interpersonal tension between the
master and mate effectively nullified the
active participation of one qualified
navigator in the bridge team.
Source: Australian Transport Safety
Bureau, Web page accessed on 23 May
2003, for the Report of the Grounding of
the ship ANL Excellence at 0318 hours 19
July 2002 - www.atsb.gov.au/index.cfm
This source contains many other reports
of maritime casualties in Australian waters.

No. 111 January 2004

ECDIS and Potential Legal Implications

At 0318 on 19 July 2002, the Liberian flag
container ship ANL Excellence embarked a
pilot off Point Cartwright, Queensland, for
the passage to Fisherman Islands container
terminal in the Port of Brisbane. After
arriving on the bridge, the pilot set up a
portable electronic chart display equipped
with a differential global positioning
system, to allow him to independently
monitor the passage to the berth. The
pilotage proceeded routinely. There were
no other movements within the port or
the approach channels during this time.
The weather was reasonable, though

visibility was reduced at times by passing
rain showers.
At 0518, ANL Excellence passed
beacon E1 and entered the East Channel.
Rain was falling at this time and the bridge
window wipers were operating. Ahead, the
starboard lateral beacon E3 and the port
lateral beacons E2 and E4 could be seen. A
temporary, starboard lateral buoy was
marking the position of the cardinal
beacon E5 which had been destroyed by a
ship some 15 months previously. This
temporary buoy was not seen by anyone on
the bridge. As the vessel passed starboard
lateral beacon E3, the pilot ordered
starboard rudder to bring the ship to a
heading of 240° and then called Brisbane
Port Control to advise that the ship would
be at the entrance channel at 0600.
The master, sitting in front of one of
the two radars, realised that the relative
bearings of beacons E4 and E2 were
changing and went to the helmsman to see
what was happening. The pilot went to his
electronic chart system, which had
reverted to a blank screen stand-by mode.
He tapped a key and when the chart was
restored he suddenly realised that he had
ordered the course alteration too soon.
The main engine was stopped and put

astern, but ANL Excellence grounded
before the ship had begun to slow.
The ship was re-floated on the high
tide of the afternoon of 19 July 2002, using
its main engine and with the aid of tugs.
Following an inspection of the hull, both
internally and externally on 20 July, the
vessel was cleared by the Australian
Maritime Safety Authority, and its
classification society to continue in
service.

Report Released: 19 May 2003
Location: Moreton Bay, Queensland


page 10

Acknowledgements

papers

The author acknowledges with thanks the invitation from Captain Wilson Chua, Maritime and Port Authority of Singapore, to
participate in this conference and to Mr Wayne Winchester of the Marine Branch of the Department of Planning and
Infrastructure, Western Australia for verifying certain aspects of charting in Western Australia.
This paper was originally presented at the 2nd International ECDIS Conference, 7-9 October 2003, Singapore and is reproduced
with the kind permission of the organisers.

REFERENCES
Alexander, L. ‘Implementing ECDIS:

Challenges
and
Opportunities’,
Contour, Summer, 1995, pp 4.
Canadian Hydrographic Service.
Electronic Chart Pilot Project Final
Report, 1994, CHS, Ottawa.

International Hydrographic Organisation (1991) Glossary of ECDIS-related
Terms, Rev. 1.1, Special Publication S-52,
Appendix 3, IHB, Monaco, 1991.

Casey, M J. ‘Hey! Why is my Ship
Showing Up on the Dock?’ Contour,
Fall, 1996, pp p.

Johnansson, K and Laitakari, I. ‘Digital
Revolution of Navigation – Exploiting
ECDIS and production of Electronic
Navigational Charts’, 1997, paper at
web
address
www.esri.com/base/
common/ userconf/proc97.

Coochey, J. ‘An Economic Evaluation
of hydrographic Charting with Special
Emphasis of the Australian Case’, IHR,
LXX (1), 1993, pp 91-101.

Kerr, A J. ‘Conceptual Model of a
Regionally Integrated data base for
ECDIS’, International Hydrographic
Review, LXXI (2), 1994, pp 37-45.

Forbes, V L. Law of the Sea, Nautical
Charts and the Delineation of
Maritime Limits’, Paper presented
at the SEAPOL International
Conference, 1987, Bangkok.

Kerr, A J. ‘A Worldwide Database for
Digital Nautical Charts’, IHR, LXXII
(2), 1995, pp 97-109.

Kite-Powell, H L and Jin, D. ‘Safety
Benefits of Digital Navigation’, IHR,
LXXIII (1) 1996, pp 65-75.
Knight, P. ‘Chartmaking by the Private
Sector’, Proceedings of the Hydographic
Surveyors Association, Fremantle, 1997,
pp 109-112.
MacDougall, J R and Acheson, S M.
(Editors) Proceedings of the International
Conference on Maritime Law and the
Electronic Chart, Canadian Hydrographic Association, Ottawa, 1990.
Mukherjee, P K. ‘Copyright Control of
the Nautical Charts – The Pros and
Cons’ in MacDougall and Acheson
(eds) Proceedings of the International

Conference on Maritime Law and the
Electronic Chart, 1990, pp 29-31.

Kerr, A J. ‘International Perspectives
on ECDIS’, IHR, LXXIII (1), 1996, pp
115-125.

Rowland, B and Furness, R. ‘Australian
Digital Navigation Charts’, Paper
presented at the Mapping Sciences
Institute of Australia Conference in
May 1998 at Fremantle.

Halls, I. ‘Raster Formats used in
Hydrographic Charting’, IHR, LXXIII
(1), 1996, pp 43-53.

Kite-Powell, H L and Gaines, A G.
(1995a) ‘Evaluation of a Technological
Standard for Electronic Chart Systems’,
Marine Policy, 19 (3), pp 185-198.

Vadus, J R. ‘Electronic Nautical
Charting: Economic Value and Role in
Sustainable Development of Marine
Transport Operations’, IHR, LXXIII
(1), 1996, pp 30-42.

Halls, I, Wild, S, O’Neil, P and Furness,
R. ‘Attention All Mariners – Official

Electronic Charts Have Arrived’,
Proceedings. of the Hydrographic Society
of Australia Conference, Fremantle,
1997.

Kite-Powell, H L and Gaines, A G.
‘Provisions and Evaluation of the IMO
Performance for Electronic Chart
Display and Information Systems’,
Journal of Maritime Law and Commerce,
26 (2), 1995(b), pp 197-214.

Forbes, V L. The Maritime Boundaries of
the Indian Ocean Region, Singapore
University Press, Singapore, 1995.

ECDIS and Potential Legal Implications

Weeks, C G. ‘ECS or ECDIS – or ENS’,
The Hydrographic Journal, No. 61, July
1991, pp19-22.
Weeks, C G. ‘The Price of ECDIS – Is
It Worth Paying?’ IHR, LXIX (1), 1992,
pp. 93-102.

Useful Websites
www.hydroservice.no/Links/
www.hydro.gov.au/
www.magellan.com.au/news/index.htm?area=Press+Releases&style=full
www.amsa.gov.au/amsa/mn/MN2002/mn0702.htm

www.atsb.gov.au/marine/incident/incident_detail.cfm?ID=181

No. 111 January 2004

THE HYDROGRAPHIC JOURNAL


page 11

biography

New

Special Publication No. 3
Hydrographic Surveying as a Career

A new format, full-colour version of this invaluable, popular Special
Publication is due to be published over the coming months.
In addition to being available via the Society’s website, SP 3 will
continue to printed in booklet form, with the addition of new loose-leaf
appendices.
Hydrographic Surveying as a Career is provided free of charge to
careers offices and fairs, trade exhibitions and to students, of all ages,
interested in pursuing a career in hydrography.
Sponsors are currently being sought for this very worthwhile
publication. The valuable financial assistance offered by sponsors will
naturally be acknowledged within the publication.
If your company would like to discuss sponsorship of this new version
of SP 3 please contact:

The Hydrographic Society
PO Box 103, Plymouth, PL4 7YP, United Kingdom

Tel and Fax: +44 (0)1752 223512
E-mail:

No. 111 January 2004

ECDIS and Potential Legal Implications

SPONSORS NEEDED

THE HYDROGRAPHIC JOURNAL

papers

Dr Vivian Louis Forbes is Map Curator at the University of Western Australia and an Adjunct
Associate Professor at the Department of Spatial Sciences, Curtin University. He is professional,
practising cartographer, marine political geographer, lecturer in spatial sciences and marine affairs
and former British Merchant Naval Officer. He is a professional cartographer, lecturer, supervisor to
Graduate and Under-graduate students at UWA and Curtin University and is a Research Associate of
the Maritime Institute of Malaysia.
Dr Forbes has developed expertise in international law particularly as it relates to maritime and
terrestrial political boundary determination, law of the sea and associated issues; practical experience
in terrestrial and hydrographic surveying; lecturing in Law of the Seas issues, spatial sciences and
political geography; and has many years of practical experience in cartography. He has an excellent
understanding in the problems of maritime boundary determination especially in the regions of
Southeast and East Asia and those ocean areas surrounding the Australian continent.
His research interests are in the disciplines of cartography, marine political geography and
maritime studies. He lectures in these topics and has published widely on these themes. The main focus of his research is on

maritime boundary delimitation and geopolitical issues. He has specialised on Indian Ocean maritime affairs and international
boundary issues of East, South and Southeast and Southwest Asia. He has presented a number of papers at conferences and
seminars at national and international fora and conducted workshops on the cartographical concepts and geopolitical concerns in
determining maritime boundaries.
He is the author of a number of books that include The Maritime Boundaries of the Indian Ocean Region (1995) and Conflict
and Cooperation in Managing Maritime Space in Semi-enclosed Seas (2001), an atlas and has been consulted on matters relating
to maritime and terrestrial boundaries and has appeared as a witness at Joint Standing Committee on Treaties Sessions for the
Australian Federal Senate in relation to the delimitation of Australia’s maritime boundaries with Indonesia in 1997 and East Timor
in 2002. He has presented on an annual basis (September 2002 and 2003) Workshops on maritime boundary issues at the
Maritime Institute of Malaysia in Kuala Lumpur.
Dr Forbes has developed a close honorary research/working relationship with MIMA since its inception through attendances at
Conferences, Seminars, publication of Occasional Papers, an Atlas of Malaysia’s Maritime Space, Bulletin Articles and presenting
Workshops on the cartographic aspects and geographical concepts of maritime boundary delimitation.