This public comment expresses strong concern about proposed
discontinuation of numerous Aids to Navigation throughout
District 1.
Background
I am co-owner of a recreational auxiliary sail boat, 40 feet
LOA, Displ. 18,800 lb., home port Sippican Harbor, Marion MA.
We ordinarily frequent coastal waters from Watch Hill, RI to
Chatham MA, but include all of District 1 in our cruising
range.?
The vessel is equipped with chart plotter, radar, AIS and
depth sounder, as is common for vessels of her type and
intended service. We navigate using all available aids to
navigation, electronic and traditional, and keep paper charts
aboard. Ordinarily, GNSS positioning via the chart plotter is
our primary reference. We have waypoints covering all routes
that we have used, and when we plan to visit a new
destination, we set up waypoints and a route. Almost all of
our waypoints are approximate locations of buoys.? We steer
from waypoint to waypoint, using bearing and COG derived from
GNSS before the buoy is in sight, then steer to it visually,
cross-checking with the indicated position on the chart
plotter and depth soundings. We also cross-check any other
visual aids, such as ranges. When we are under sail to
windward or downwind (and thus not able to sail the rhumb
line), we use our plotted position including charted depth,
the chart plotter's sailing features, and visual relative
bearing to the waypoint to determine the layline.? In poor
visibility, we augment the GNSS-derived bearing with radar. I
believe this navigational routine to be prudent and
appropriate for a recreational vessel of our size.
Our electrical system is basic and typical for our type and
length, with no redundancy: one bank of four batteries for
ordinary operational needs, plus a backup starter battery, and
one alternator. All electronic navigation depends solely on
this DC electrical system. We have one chart plotter. We also
have mobile phones, but find that service is intermittent in
places; we would not rely on them for safe passage.
In summary, visual Aids to Navigation are essential for safe
operation of our vessel.
General Observations
The putative premise of proposed discontinuation of so many
buoys is flawed. It is based on an assumption that GNSS, ENC
and ECS can be a total substitute for visual sightings. This
is false. It is said that the prudent mariner never relies on
a single aid to navigation. Removing aids to navigation
undercuts this principle: too much can go wrong.? Electronic
navigation depends entirely on the integrity of GNSS, the
vessel's electrical system, and at least one functioning chart
plotter. Yet there is serious concern that hostile actors will
jam or spoof GNSS systems; also the US DoD retains the ability
to dilute precision of GPS for civilian users. Not only would
loss of GNSS deprive all vessels of electronic positioning; it
would also disable cellular networks (and thus smartphone
applications), which critically depend on GPS for timing and
synchronization.? Further, consumer-grade chart plotters do
not have the redundancy required for ECDIS, are engineered for
cost rather than reliability, are frequently exposed to the
weather, and are operated at ambient temperatures outside the
Max/Min Temperature parameters of their components. DC
electrical systems on smaller vessels are not redundant and
have multiple single points of failure. Lightning strikes are
a hazard, especially to sailboats, and can destroy all
electronic devices onboard. Cellular coverage is incomplete,
including many inshore areas, and navigation apps depend on
connectivity to retrieve cartography. Finally, electronic
navigation is subject to human error. In summary, primary
navigation using GNSS and ECS is great but not highly
reliable, and MUST be backed up with traditional methods for a
reasonable margin of safety.?
Several proposed changes would remove alternating red and
green buoys from a pair marking a channel. This is a false
economy. Helmsmen need both to visualize the edges of the
channel, particularly when keeping clear of a large vessel.
The process (or lack of one) is a serious problem.
Ordinarily, the Coast Guard discontinues a few AtoN on
occasion, after proper studies and public engagement well in
advance of required notice in the LNM. ? The timing and scope
of this project strongly suggest that it is motivated by
political pressure to cut expenses, regardless of potential
consequences. It is shameful that DHS would order such hasty
and heedless action at the expense of safety (and probably
against the better judgement of USCG careerists).
Below are comments on proposed changes in some of the areas
that I know well. They should be taken as examples. Many other
proposed discontinuations would be equally ill-advised, and by
highlighting these I by no means depricate the importance of
others.
Woods Hole Passage
Woods Hole is the primary entry to Vineyard Sound and
Nantucket Sound from Buzzards Bay and the Cape Cod Canal. It
is heavily trafficked by recreational vessels in season, some
throwing wakes and/or operating at excessive speeds. A mariner
unfamiliar with these waters would inevitably be disoriented
upon entering the passage from either direction. The channels
that appear as "Broadway" and "The Straight" on the charts are
narrow, and surrounded by rocks. Currents peak at 4.4 kts or
more, uncomfortably close to the maximum speed of a smaller
auxiliary.? I consider Woods Hole Passage to be the most
dangerous area of our cruising grounds, and even after
hundreds of transits, treat it with utmost respect.
The turn from The Straight to Broadway is particularly
hazardous as the head current becomes a cross current with the
turn.?Eastbound, buoy G'5' marks the start of that turn,
critically on a strong flood current.? In season, groundings
on Middle Ledge occur about once a week because confused
helmsmen try to pass to the wrong side of G'5'; removing it
would make these occurrences more frequent. R'4A' is an
important visual reference for judging side-slip toward the
edge of the channel and provides a visual assist for judging
the current. G'7' delineates the edge of the channel as the
vessel makes the turn from the northern branch. Westbound in
flood current, R'2', R'2A' and R'4' together form a visual
reference for the eastern edge of the channel. Eastbound, R'8'
and R'6' form a range and provide an initial visual reference
for the current. G'11' and G'13' are major waypoints and
visual references for passage to Woods Hole from Buzzards Bay.
Similarly, Nobska Point Lighted Bell is the primary visual aid
for navigating from West Chop to the eastern channel.
Buzzards Bay
Frequent tugs with barge in tow in the shipping channel are a
hazard to small, slower vessels. AIS has been a great help,
but in case of failure (or as a cross-check), the helmsman
must judge the width of the channel in order to decide how
best to keep clear. This is a case where removing either buoy
of a red-green pair presents a navigational challenge.
Felix Ledge G'3' (Quicks Hole) marks an isolated rock. Safe
passage from the North from Lone Rock G'LR' can be had by
visually splitting the distance between G'3' and R'2'. The
current runs strong, and visual reference to any side slip is
necessary.
New Bedford SE approach buoy R'2SE' marks safe water to the
south of a reef extending from West Island. For vessels
transiting between New Bedford or Padanarum and Mattapoisett,
Marion, Wareham, or the Cape Cod Canal, it marks a course
change, making it a primary visual aid.
New Bedford SW approach buoy Fl.R'8' Bell marks a waypoint on
the route to Padanarum from the south, or from the east under
sail in prevailing southwest winds. It lines up with Middle
Ledge RG'AB' Fl.R Gong to form a range on the approach to
Padanarum.
Cuttyhunk fairway buoy RW'CH' is the main visual aid marking
the entrance to Cuttyhunk Harbor. While we usually use G'1E'
as our electronic waypoint, the fairway buoy would be
essential if we had to navigate visually to Cuttyhunk from
Buzzards Bay.
Westport Harbor is marginal for us because of depth. If we
were to go there, Westport Harbor Entrance Lighted Bell G'1'
would be an essential waypoint for lining up with the channel
and avoiding the ledge to the northwest.
Vineyard Sound
Squash Meadow East End Bell Buoy and Squash Meadow West End
bifurcation buoy mark a hazardous reef and no-go zone between
them.
The two red buoys southwest of Sow and Pigs reef mark a
notorious patch of water, the site of many shipwrecks.
Eldridge explained how the set of the current draws vessels
into the rocks. Any vessel navigating visually is at risk,
particularly if they are not aware of Eldridge's? advice.
Nantucket Sound
Tuckernuck Shoal buoy G'3'and Cross Rip Shoal South End buoy
are critical primary visual waypoints for the route from
Nantucket to Martha's Vineyard and Woods Hole. We use them to
check our progress and course, and would need them if unable
to use ECS.
Every season, a few boats run aground on the Nantucket
breakwater. Frequent ferries make the narrow channel hazardous
to slow-moving recreational vessels.? Nantucket Harbor channel
buoy G'1' is essential to lining up a vessel navigating
visually to the channel approaching from the North, since the
range at Coast Guard Station Nantucket is not visible from
there without binoculars. Northbound, it marks edge of the
channel, and we steer to it to keep clear of ferries and other
faster vessels using the middle of the channel.
The approach to Hyannis Harbor is tricky to navigate because
of all the rocks, particularly Bishop and Clerks. The buoyage
system there gives the navigator several options for passage
between them.
Chatham Roads Bell G'3' and particularly Stage Harbor
entrance lighted bell R'SH' help the navigator line up their
vessel to the narrow entrance to Stage Harbor.
Block Island Sound
Fl.R'2' is a primary visual marker along several routes
between New Harbor, Block Island and points north and east.
Between Fishers Island and Watch Hill, RI
The passage from Rhode Island Sound to Fishers Island Sound
is another route that I treat with extra respect. I consider
it poorly marked as it is. The passages between sections of
reef are narrow and through shallow water, and the current is
strong. Watch Hill GR'WH' marks a shallow that is not a
serious problem for our draft, but which I would avoid in
inclement weather. I would not ordinarily choose to use Catumb
Passage but the line between G'3C' and G'1C' is navigable if
necessary. Lords Passage is a preferred alternative to Watch
Hill Passage, as RW'L' lighted whistle, G'7' and R'2L' mark a
triangle of relatively deep water.? Wicopesset Rock G'1' marks
an isolated rock that is a hazard on the route to East Harbor
Fishers Island from the east, and G'7' and G'9' are part of a
string of green buoys marking that route and the unsafe water
to the south. Stonington Harbor Channel R'1' and G'3' mark
safe passage into Stonington, as well as isolated rocks.
Bob Fields
Peter
Milady S42
Tim Dokken
Keith Bucklen
Jim Harman
Allan