Before the Federal Communications Commission
Washington D.C. 20554
In the matter of)
Amendment of Parts 13 and 80 of the)
WT Docket Nos. 00-48 and
02-102
Commission’s Rules Concerning)
Maritime Communications)
Comments by the
National GMDSS Implementation Task Force (The Task Force)
Submitted
03 September 2002
The National GMDSS Implementation
Task Force was chartered by the U.S. Coast Guard to supplement government
functions in expediting the implementation of the Global Maritime Distress and
Safety System (GMDSS) recently introduced by the International Maritime
Organization (IMO). The Task Force membership is broad-based including nearly
1000 representatives of government authorities, commercial vessel owners and
operators, recreational vessel interests, training institutions, service
agents, manufacturers, trade associations and maritime labor organizations. The
Task Force maintains a portion of the Coast Guard web site at
www.navcen.uscg.gov/marcomms/ that contains numerous GMDSS Information Bulletins,
records of Task Force meetings, and various Task Force letters recommending
regulatory action.
The Task Force has made numerous
recommendations to both the Coast Guard and the FCC, many of which have been
adopted. The Task Force comments filed on 21 July 2000 transmitted numerous
recommendations for changes to Part 80 of the Commission’s Rules in response to
Docket No. 00-48. The Task Force appreciates the opportunity to comment on the
Report and Order and Further Notice of Proposed Rule Making contained in Docket
02-102.
The Task Force comments are in two sections, the first responding to general
inquiries addressed in the Docket and the second responding to specific rule
changes proposed in the Appendix. The comments were approved at the Task Force
meeting on 8 August 2002 and refer to specific page and paragraph numbers in
Docket FCC-02-102.
GMDSS TASK FORCE COMMENTS ON GENERAL INQUIRIES
IN FCC DOCKET 02-102
Page 5, para 6 & 9. 1. Fishing Vessels and the GMDSS. The end of the exemption for Fishing
Vessels over 300 tons one year after the USCG declares Sea Areas A1 and A2
needs clarification since most are potential A3 vessels and would nominally
require VHF-DSC and MF-DSC whenever the exemption ends without regard to the
declaration of Sea Areas A1 and A2. Other aspects of GMDSS requirements such as
operator licensing, duplication, reserve power, and SafetyNET reception should
also be addressed if different from A3 requirements for SOLAS vessels.
Page 8, para 12 & 13. a. Restricted GMDSS
Radio Operator’s License. The Task Force, having recommended this License,
concurs. We question use of the term GROL for GMDSS Radio Operator’s License
since it has already been used as an abbreviation for the General
Radiotelephone Operator’s License.
Page 9, para 14 & 15. b. Credit for Proof of Passing
U. S. Coast Guard Training. The
Task Force, having recommended this action for the GMDSS Radio Operator’s
License, concurs. The Task Force further recommends extension of this concept
to examinations for the newly created Restricted GMDSS Radio Operator’s
License.
Page 12, Para 23 & 24. c. Alternative Satellite
Fittings. The FCC’s intent to authorize non-GMDSS systems for mandatory
vessels sailing in domestic waters needs more definition. It is assumed that
the intent is to permit alternative satellite systems for vessels on domestic
voyages since “domestic waters” are not defined. See also proposed rule 80.1091
on page 99.
Page 13, para 25-27. a. Watch requirements on Channel 16.
The Task Force notes that the docket fails to recognize the IMO’s recent
action to extend the channel 16 watch beyond 1 February 2005. The Task Force
further notes that it may not be possible to discontinue the channel 16 watch
in the U.S. since the limited provisions to encourage a gradual shift to
VHF-DSC fail to require all users of VHF to upgrade to DSC by a definitive
date.
Page 14, para 28-30. b. Watch Requirements on 2182
kHz. The Task Force concurs with the FCC action calling for watch on 2182
by mandatory vessels that have not yet been required to upgrade to MF-DSC.
However, the clarification provided in the erratum to Docket 02-102 also levied
a 2182 watch requirement on SOLAS vessels which have upgraded to MF-DSC and
which were earlier permitted to drop the watch on 2182 in favor of the DSC
watch on 2187.5 kHz. Most of these ships have already removed the 2182 watch
receivers previously used for this purpose and no benefit is seen to
reinstating a 2182 watch on SOLAS vessels. Since the 2182 kHz watch is not a
SOLAS requirement for MF-DSC equipped vessels, does the FCC plan to impose a
2182 watch on foreign flag vessels in U.S. coastal waters? The Task Force feels
that there is insufficient justification for re-imposing the 2182 watch
requirement on SOLAS compliant vessels and requests reconsideration.
Page 15, para 31-33. 4c. Watch Requirements for Voluntary
Vessels. The Task Force concurs with the requirement for voluntary users of
GMDSS alerting systems capable of automatically transmitting a distress alert
including position to watch the emergency channel when not communicating on
another channel. This is consistent with the Task Force’s earlier filing that
supported ITU requirements, which have been in effect for some time.
Page 16, para 35 & 36. 4d. Safety Watch by Vessels
Voluntarily Fitted on the MF/HF DSC Channels and Inmarsat A, B, and C Systems. The
Task Force concurs with the requirement that vessels watch the appropriate
distress channel on voluntarily fitted MF/HF and Inmarsat systems. Here the FCC
accepts the Task Force recommendation for connecting a navigation receiver, if
provided, to GMDSS alerting gear on mandatory vessels but not on voluntary
vessels. The FCC states that such a requirement would be difficult to enforce
but the Task Force notes that many other FCC rules are also difficult to
enforce and in the case of many of these rules, no enforcement effort is even
attempted. The Task Force repeats its earlier recommendation to include
voluntary vessels since the Coast Guard needs accurate positions for efficient
search and rescue operations; since most responsible operators of voluntary
vessels will comply when they understand the benefit; since the ITU rules on
which this is based apply to all vessels; and since new IMO rules becoming
effective 1 July 2002 now require navigation receivers on most vessels.
Courtesy examinations of recreational vessels and information provided by
service agents and manufacturers will also encourage voluntary vessel operators
to comply.
Page 19, para 42. Compulsory
Vessels, Subpart Q. The Task Force
concurs in substantial elimination of Subpart Q but objects to the retention of
the obsolete direction finder rules, 80.818 – 80.823 by renumbering as
80.288-80.293. Surely there can be no compelling need to retain obsolete
provisions of the Communications Act in the current regulations. The Task Force
does not understand the reluctance to seek revision of obsolete provisions of
the Communications Act but realizes that there are many provisions in law,
which is no longer enforced. If it is permissible to ignore the law, surely it
is not required that these obsolete provisions be republished while updating
the regulations. The Task Force assumes that the Commission does not intend to
enforce these regulations and does not intend that vessels reinstall
direction-finding equipment.
Page 21, para 46 & 47. 8. Emergency Position
Indicating Radiobeacons (EPIRBs). The Task Force concurs with this action
to phase out the 121.5 MHz EPIRBs and repeats its recommendation for approval
of use of the Inmarsat E EPIRB suitably modified to meet U.S. requirements.
Page 25, para 58 & 59. 2. Subpart B-Applications and
Licenses. Here the FCC retains their requirement that vessels not otherwise
requiring a station license, must have one if making a short international
voyage to Canada even though neither country enforces the Rule. The position is
that an international agreement with Canada would be required to waive the
station license requirement. Since this is an especially ‘hot’ item among
recreational vessels operators in the border states, the Task Force urges that
such an agreement be undertaken, possibly including a long overdue update of
the Great Lakes Agreement to incorporate appropriate GMDSS functions.
Page 31, para 77. 8. Subpart I-Station Documents. The
Task Force concurs with accepting NIMA pub 117 and the UK Admiralty Volume 5 as
alternatives to the GMDSS Master Plan. The Task Force also feels that the ITU
publications required, Lists IV, V, VI, and VII A are not only quite expensive
but of very limited value to most ships since carriage of a dedicated Radio
Officer is now optional. See also page 85, Rule 80.415.
Page 31, para 78, Log Keeping 80.409. Several Task
Force members have objected to the requirement to log all distress traffic
heard noting that there is an excessive volume of such traffic, mostly
consisting of false alerts and locations far removed from their own vessel.
Since this seems to be the new reality under GMDSS, the Task Force proposes
that required log entries be limited to distress traffic involving their own
ship, another ship within assistance range, or a situation where the distress
alert was acknowledged or relayed. (See also Task Force comments on modified
Rule 80.409).
Page 34, 13. Subpart W-Global Maritime Distress and Safety
System (GMDSS). The Note to the General Provisions of this subpart states:
“No provision of this subpart is intended to eliminate, or in anyway modify,
other requirements contained in this part with respect to part II of title III
of the Communications Act”. The Task Force notes that this sort of legal
qualifier is confusing to users who for the most part do not have access to the
Communications Act. If there is something out of date in the Communications
Act, the Commission should recommend appropriate changes. No changes have been
proposed to 80.1065 despite the fact that subparagraphs (b), (1)-(5) are
devoted to phased implementation dates all of which have now passed. The Task
Force recommends deletion of these subparagraphs.
Page 37, para 94. 80.1077and 80.359. Subpart W –
GMDSS. The FCC plans to modify Rule 80.1077 to clarify that routine calling
is not permitted on MF-DSC frequencies. There is a strong need for some routine
calling channels in the MF band. Perhaps the unused duplex MF-DSC calling channels
for public correspondence could be utilized in a manner similar to 2177.0 kHz
while waiting for the IMO and ITU to resolve the issue.
Page 41, Section IV. FURTHER NOTICE OF PROPOSED
RULEMAKING
Page 41, para 109 & 110. 1. Voluntary Restricted License. The Task Force does not suggest any
requirement that voluntary users of VHF-DSC be required to hold the FCC’s
Restricted GMDSS Radio Operator’s License. The Task Force has, however,
encouraged the Coast Guard Auxiliary and the U.S. Power Squadrons to offer a
voluntary one-day course in VHF-DSC and encouraged development of an
interactive course, which operators could take over the Internet. The UK and
some other countries require their voluntary users to complete such a course
that in the UK is offered by the Royal Yachting Association that also issues a
Certificate of Completion. Since a formal FCC Operator’s License is not
proposed, any effort to require completion of some sort of abbreviated training
might more properly fall to the Coast Guard or to state regulators.
Page 45, para 121. 9. Inmarsat-E EPIRBs. The Task
Force repeats its earlier support for the authorization of the Inmarsat-E EPIRB
system in the U.S. subject to other special U.S. requirements such as strobe
lights and homing signals. The Inmarsat E is already GMDSS approved by IMO.
Page 46, para 122-125. 10. Small Passenger Vessels. The
Task Force repeats its earlier support for requiring that mandatory vessels
upgrade to VHF-DSC, and to MF-DSC for those that operate further offshore, within
a year after the Coast Guard declares Sea Areas A1 and A2 operational. The
basis for this requirement is to have all vessels participate in the same
common distress and safety system using appropriate elements of the GMDSS. (See
also Task Force comments on 80.905).
Page 47, para 124. 10. Small Passenger Vessels. The
Task Force has no objection to relaxing GMDSS satellite rules slightly for
small passenger vessels but notes that the list of Inmarsat systems should
include the new Fleet 77 system. Although not stated, it is assumed that use of
non GMDSS Inmarsat systems would be restricted to vessels on domestic voyages.
If the FCC is contemplating authorizing a non-GMDSS Inmarsat system for this
function, it is suggested that Inmarsat Mini-M would be a more attractive
choice than the Inmarsat-M for smaller vessels despite the lack of a distress
alert button.
Page 48. para 127. 80.1083. GMDSS Rules. Several Task
Force members took exception to the statement that it would be permissible on
small passenger ships to have an additional EPIRB mounted inside the wheelhouse
near the conning station. They point out that this would be of dubious utility
in a steel wheelhouse and would thwart the “float free” capability unless
carried to a survival craft. The Task Force does not object since it is an additional
EPIRB, but suggests that a further qualification may be in order.
Page 48, para 129. 12. Electronic Mail Requests. The
Task Force repeats its support for authorizing the use of e-mail for making
official requests and reports to the FCC.
Page 49, para 131. 14. Examination Requirements for GMDSS
Radio Operators. The Task Force repeats its earlier support for this
concept of a single exam to satisfy both the FCC and USCG GMDSS requirements.
The Task Force has already recommended, and the Coast Guard’s National Maritime
Center has already accepted, an exam of 50 questions from the 300-question pool
for the Restricted GMDSS Operator’s License.
TASK FORCE COMMENTS ON APPENDIX B, FINAL RULES
Page 56,Part 13, Commercial Radio Operators;
13.7-13.201. The Task Force has no objection to the revised rules in Part
13 except to note that the information is not available to most operators since
there is no requirement to carry Part 13 on board vessels.
Page 74, 80.310Watch required by voluntary vessels. This
Rule has been revised to require voluntary vessels to watch channel 16, or
channel 70 if DSC equipped, whenever underway and not working on another
channel. This eliminates the option to be underway but “not in service” and is
consistent with new ITU rules. The Task Force concurs in this action.
Page 84, 80.409 Station Logs. The Task Force disagrees with para. (e)(1)
requiring a summary of all distress communications heard. See our earlier
comment relative to page 31, para 78. The watches are now being maintained by
the deck watch officers in lieu of
dedicated Radio Officers. Further, there is a grossly excessive number
of alerts now being heard as a result of the efficiency of GMDSS systems over
long ranges, the vast majority of which turn out to be false alerts. The Task
Force therefore recommends that vessels be required to log only distress
traffic affecting own ship, another ship within possible assistance range, and
distress alerts acknowledged or relayed.
Page 85, 80.415, para (b) (3) Line 2 Taunton
misspelled, delete “m” after Zip code; Line 3 change Ext from x3333 to x5030.
Page 89, 80.880. Vessel Radio Equipment. This new Rule permits compulsory vessels
operating beyond 100 miles to use HF SSB on calling frequencies or Inmarsat.
The Task Force believes that compulsory vessels should generally be required to
have appropriate components of the GMDSS since the Coast Guard search and
rescue system is much more efficient if all vessels are similarly equipped. The
Task Force has doubts that the Coast Guard has been able to maintain an
effective watch on HF SSB frequencies in the coastal network. Beyond MF range,
GMDSS Sea Area A3 systems are more reliable.
Page 89, 80.905.Vessel Radio Equipment. This Rule
permits small passenger vessels operating beyond 200 miles to use Amver if
underway for more than 24 hours. The Task Force recommends HF-DSC on the basis
of the advantages of a “single common distress system”. Beyond MF range, Sea
Area A3 systems are more reliable.
Page 94, 80.1071. Exemptions. This exemption
for large Fishing Vessels, and other similar exemptions, extend until one year
after the Coast Guard declares Sea Areas A1 and A2 operational. Does this mean
one year after both A1 and A2 have been declared or one year to upgrade to
VHF-DSC keyed to Sea Area A1 and one year to upgrade to MF-DSC keyed to A2?
Note that the Coast Guard expects to declare A2 in 2002 and A1 in 2006.
Page106, 80.1117. Procedure for Receipt an
Acknowledgement of Distress Alerts. The revision of paragraph (a) applies
to acknowledgement of distress alerts in all frequency bands and is not as
restrictive as the latest IMO guidance contained in COMSAR/Circ.25 of 15 March
2001 which virtually eliminates relay of distress alerts received by vessels on
VHF channel 70. The Task Force recommends adherence to the IMO operational
guidance.
Approval of Task Force Comments. The foregoing
comments were approved by the National GMDSS Implementation Task Force at its
meeting held on 8 August 2002.
Submitted by:
Captain Jack Fuechsel, USCG (Ret.)
Director, National GMDSS Implementation Task Force
7425 Elgar Street
Springfield, VA 22151
Phone: 703-941-1935
Fax: 703-941-6154
Email: gmdss@erols.com
File: fcc-3
