Medway and Swale Boating Association

A little outside the Medway area, but could affect local boaters heading for Holland via Harwich.

With effect from 1st November, 2024 the revised 2024 PLA General Directions came into effect.​ This appeared to have implications to East Coast sailors. Roger Gaspar, the author of “Crossing the Thames Estuary” queried it with the PLA. Their response is below:

“The PLA General Directions for Navigation were recently reviewed and, following consultation, were amended. However, GD 17.5 (which prohibits vessels with draught less than 6.0m using the Black Deep except with VTS permission) was not amended in the recent review exercise and so continues in force unchanged as it has done for several years now. You are correct that the purpose of this regulation is to separate smaller vessels which are capable of safely using the other channels from the largest ships which, by reason of their draught, can only navigate in or out of the Thames via the Black Deep & Knock John Channels. By reducing the density of traffic in this area, we hope to afford greater searoom (as far as practicable in a narrow channel) to these very large ships and reduce the risks of traffic conflicts. Additionally, one-way working is in force when ultra-large containers ships are transiting the Knock John Channel (as per GD 17.1f, although a secondary channel has been established (GD 17.2)), so excluding small ships from these channels reduces risks of traffic congestion in the one-way working zone.

PLA regulations (such as Thames Byelaws, General Directions and Pilotage Directions) do apply to pleasure vessels in the Thames, although there are sometimes other qualifiers (for example, size or area limitations) which operate to disapply certain regulations in certain cases. In this case, GD17.5 does indeed apply to small pleasure vessels, who must not use the Black Deep Channel except with permission from London VTS. I understand that smaller pleasure vessels, possibly using a handheld VHF radio, may have difficulties communicating with London VTS while out in the Estuary. We recently had a yacht skipper telephone us the day before making his passage to discuss using the Black Deep, as he anticipated being unable to effectively communicate by VHF while afloat at the relevant position, and this may be an option for sailors to consider.

In terms of a small pleasure vessel wishing to cross the Black Deep east-west while on passage, I think it is unlikely that London VTS would refuse permission (except, perhaps, requiring the pleasure vessel to wait a short time for underway large vessel traffic to pass). In the case of a small pleasure vessel wishing to navigate along the Black Deep Channel as far as Foulger’s or Fisherman’s Gats, I also think it is unlikely London VTS would refuse permission (again, with the exception of possible short-term waiting for traffic). However, I would expect London VTS to refuse permission to a small vessel wishing to navigate along the Black Deep and on through the Knock John Channel. Circumstances where permission for a small pleasure vessel to use any part of the Black Deep may be refused may include (but are not limited to) restricted visibility, heavy weather, on-going incident response in the vicinity, project towage or other non-routine vessel navigation operations. The officers at London VTS are authorised to act on behalf of the Harbour Master and have discretion to make decisions in the interests of safe and orderly traffic movements based on their professional judgement at the time.

To summarise:

Recreational sailors should, if reasonable, consider avoiding the Black Deep entirely (and ideally all of the channels used by large commercial vessels). If doing so would be unreasonable and it is intended to use the Black Deep, recreational sailors must request permission from London VTS in advance of proceeding into the Black Deep and must be aware that it is possible permission may be refused. If VHF communications difficulties are expected, recreational sailors should make advance contact with us by telephone to discuss their intentions and, additionally, still attempt to call London VTS by VHF at the relevant time. It is likely (but not guaranteed) that, under normal circumstances, permission will be quickly granted to small pleasure vessels wishing to cross the Black Deep Channel east-west or wishing to proceed along the Black Deep bound to or from Foulger’s or Fisherman’s Gats, but not onward passage via Knock John.

In case of an incident, whatever the wider circumstances, I imagine that, in any investigation, a dim view would be taken of a recreational sailor who either failed to research the applicable port authority regulations and/or failed to comply with those regulations while inside the port authority’s area of responsibility.

It is important that pleasure vessel masters, including recreational sailors, intending to navigate within the PLA’s area of responsibility study our regulations in advance. While the majority of our regulations may not apply to them, they should identify those which do and ensure they comply. It is essential that all vessels comply with the International Collision Regulations (‘Colregs’) – for example, every year (unfortunately), we deal with a small number of yachtsmen who fail to appreciate that, where Rules 9 and 18 conflict, the requirements of Rule 9 prevail.

The HM team responsible for liaison with recreational mariners can be emailed at recreation@pla.co.uk or by telephoning 01474 562200 during office hours and asking for the harbour master team.

Outside of office hours, London VTS can be reached (24/7) on 01474 560311 or via VHF ch. 69 (east of Sea Reach 4) or ch. 68 (west of SR4).”

Comment by Roger

I believe the above is clear. We must comply. I regret that I had not previously warned of this requirement. At the time I wrote the First Edition, the requirement was not in force and subsequently I had relied on the marginal notes on UKHO charts when updating the Second and Third Editions. Unfortunately the marginal notes made/make no mention of any requirement for permission so I was not alerted. I apologise for that.

Generally I think there will be little problem seeking permission for crossing the Black Deep to and from either the SW Sunk and Little Sunk into Fisherman’s Gat and Foulger’s Gat; indeed it is a wise precaution. Lateral use, e.g. to or from either Gat to Sunk Head does of course involve more time (11nm approx) so the PLA would have more to consider. I deliberately survey the Little Sunk quite carefully so as to be able to recommend using it as a safe crossing point rather than the lateral use of the Black Deep; frankly there is little advantage using lateral use of the Black Deep, indeed adds a little distance. I do appreciate some might prefer to avoid crossing the Sunk Sand but many, many do.

I have been asked if the Black Deep and Foulger’s Gat are in the PLA Seaward Area. What is relevant for the General Directions is the extension of their Pilotage Area. The General Directions apply within such area so both are included . I have also been asked for the definition of the Black Deep. Given that there is very little ‘room’ outside the lateral buoyage (and between Nos 1 and 3 the sand is particularly steep-to) my view is that trying to ‘squeeze through’ and trying to define the Black Deep isn’t worthwhile. But that is just my view.

You will have noted about the Knock John channel above. For shipping the DW channel is very narrow and not straight. Although there is a secondary channel, you will have noted that I have not recommended a route using the Knock John. Between the Medway/Thames and the Suffolk rivers it is shorter to use the Barrow Deep and infinitvely easier than the Knock John/Black Deep. On a slightly different area I would like to add that I continue to NOT recommending using the Middle Sunk (i.e north of the Fisherman’s Gat). It is not fully surveyed there and it is not straight forward.

My experience with the PLA has been very positive. Calling up VTS has been very useful and helpful. The response is full and clear. I think use of an early telephone call might be the best course of action if you intend to use lateral use of the Black Deep.