National GMDSS Implementation Task Force
% 7425 Elgar Street;
Springfield VA 22151
03 September 2002
Secretary
Federal Communications Commission
445 12th Street S.W.
Washington D.C. 20554
PETITION TO REQUEST THAT FCC COLLECT FULL MMSI DATA SET
The GMDSS Task Force. The National GMDSS Implementation Task
Force is chartered by the U.S. Coast Guard to supplement government functions
in expediting the implementation of the Global Maritime Distress and Safety
System (GMDSS) 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, most of which have been
adopted.
Background. The U.S. Coast Guard has indicated
that Search and Rescue Operations could be significantly improved if the data
base on radio equipped vessels contained important descriptive information and
contact telephone numbers in addition to the brief owner identification
previously collected as part of the licensing procedure. Accordingly, the U.S. submitted a recommendation to the
International Maritime Organization’s (IMO) Communications Search and Rescue
Subcommittee (COMSAR) identifying the additional fields which would facilitate
the validation of distress alerts. The U.S. proposal was adopted within COMSAR
and following the IMO practice, submitted to the IMO Maritime Safety Committee
(MSC) for approval and in turn forwarded to the IMO Assembly and adopted as IMO
Assembly Resolution A.887(21) on 25 November 1999. A copy of the Assembly
Resolution is attached to this petition. The international registry for ship
identities maintained by the International Telecommunications Union was also
expanded accordingly.
This action was especially timely with the introduction of
the GMDSS which provides for the automatic transmission of distress alerts
which include the new Maritime Mobile Service Identity (MMSI) along with the
position of the vessel in distress. The GMDSS has been essentially implemented
on large treaty vessels but work remains in upgrading the shore networks and
implementing the automation feature, Digital Selective Calling (DSC), on
non-treaty vessels. In the U.S. the huge number of recreational vessels using
VHF radio will gradually upgrade to DSC under the provisions of an FCC Order requiring
that all new maritime VHF radios submitted for type approval after the summer
of 1999 must have a DSC capability and accordingly must register for the unique
MMSI number which will identify them.
Because the Commission has earlier acted to register recreational
vessels using only VHF radio ‘by Rule’ rather than requiring individual
licenses, it became appropriate to establish a streamlined method of assigning
MMSI numbers without requiring recreational vessel operators to apply for
station licenses. After considerable study and negotiations, the Commission, in
cooperation with the Coast Guard, established a method whereby private
organizations seeking to issue MMSI’s, upon completion of a Memorandum of
Understanding between the Commission, the Coast Guard and the organization, are
authorized to issue MMSI’s to vessel operators. BOAT U.S. was authorized to
issue MMSI numbers to applicants who did not otherwise require a station
license and this procedure was later extended to Sea Tow International and MariTEL.
These organizations are required to collect the full data field recommended by
the IMO and to pass the information to the U.S. Coast Guard to be included in
its national data base. The Coast Guard expanded its data base to accommodate
the additional data fields.
The Problem. The Commission, however, has not expanded its own data base
and does not collect the additional data fields when registering vessels for a
station license and/or issuing an MMSI.
Informal approaches to the Commission have elicited a
response that the information is not required by the FCC for the licensing
process. While acceptable from the Commission’s perspective, the whole
motivation for the change was to significantly improve search and rescue
procedures. The recommendation was developed in the national interest with
participation by Commission representatives and adopted by the appropriate international organizations. The
subsequent failure of the Commission to make the necessary changes to its
databases defeats the purpose for which the international process was upgraded.
The GMDSS Task Force has received several complaints from
vessels which are required to hold a station license either because they carry
additional radio systems or because they go on international voyages. These
vessels want their full data recorded to enhance the safety of their voyages
and object to the fact that the additional data fields are not being recorded
in the Commission’s registration data base and not being transmitted to the ITU
for the international database used by foreign RCCs.
One reason that the additional data fields are needed is
that the efficiency and ease of use of the new GMDSS radio systems has resulted
in a substantial increase in the inadvertent transmission of false alerts,
particularly by vessels using the system voluntarily whose operators are not
required to be trained or licensed. The Coast Guard utilizes the information
available from numerous data bases including the Commission’s MMSI data base to
enhance its response to GMDSS distress alerts including the prevention of
unnecessary launching of search and rescue assets. The validation process is
severely impeded without access to the additional data fields as the
information contained in those additional fields is considered essential for
search and rescue purposes.
Homeland Security. The Task Force considers
the search and rescue requirements ample justification for the action proposed
but points out that the new heightened homeland security requirements also
strongly favor collection of the additional data fields for the national
database. In fact, homeland security considerations may well demand additional
rulemaking requiring that certain categories of vessels be mandatorily equipped
with appropriate radio systems and required to maintain a mandatory listening
watch while underway in addition to being registered in the database.
Action Recommended. The GMDSS Task Force
strongly urges the Commission to expand its data base to accommodate the
additional data fields in accordance with the IMO recommendation and that its
Application Forms be revised to require submission of the expanded data when
applying for a station license and when renewing such licenses.
The Task Force contends that failure to do this is a
detriment to maritime safety and reflects poorly on the U.S. for failing to
adopt a position that it advocated internationally and as a world leader in
Search and Rescue matters.
Approval. This Petition was approved by the National
GMDSS Implementation Task Force at its regular meeting on 8 August 2002.
Submitted by:
Captain Jack Fuechsel, USCG (Ret.)
Director, GMDSS Task Force
7425 Elgar Street
Springfield, VA 22151
Phone: 703-941-1935
Fax: 703-941-6154
Email: gmdss@erols.com
Attachment: IMO Assembly Resolution A.887(21) of 25 November
1999
File: fcc-mmsi.doc
INTERNATIONAL MARITIME ORGANIZATION
E
IMO
ASSEMBLY A 21/Res.887
21st session 4 February 2000
Agenda item 9 Original:
ENGLISH
RESOLUTION A.887(21)
adopted on 25 November 1999
ESTABLISHMENT, UPDATING AND RETRIEVAL OF THE
INFORMATION
CONTAINED IN THE REGISTRATION DATABASES FOR THE
GLOBAL
MARITIME DISTRESS AND SAFETY SYSTEM (GMDSS)
THE ASSEMBLY,
RECALLING
Article 15(j) of the Convention on the International Maritime Organization
concerning
the functions of the Assembly in relation to regulations and guidelines
concerning maritime safety,
RECALLING
ALSO regulation IV/5-1 of the International Convention for the Safety of
Life
at Sea (SOLAS), 1974, as amended, which requires that each Contracting
Government undertakes to ensure that suitable arrangements are made for
registering Global Maritime Distress and Safety System (GMDSS) identities and
for making information on these identities available to rescue co-ordination
centres on a 24-hour basis,
RECOGNIZING
the need to continuously update the information contained in the
registration
databases for the GMDSS, RECOGNIZING ALSO that the information in such
registration databases is essential for search and rescue purposes,
HAVING
CONSIDERED the recommendation made by the Maritime Safety Committee at its
seventieth session, 1. ADOPTS the Recommendation on the Establishment, Updating
and Retrieval of the Information Contained in the Registration Databases for
the GMDSS set out in the Annex to the present resolution;
2.
RECOMMENDS Governments to ensure that the information contained in the
registration
databases for the GMDSS and their continuous updating and availability to
rescue co-ordination centres is in accordance with the annexed Recommendation;
3.
REVOKES resolution A.764(18).
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ANNEX
RECOMMENDATION ON ESTABLISHMENT, UPDATING AND RETRIEVAL OF
THE INFORMATION CONTAINED IN THE REGISTRATION DATABASES FOR THE GLOBAL MARITIME
DISTRESS AND SAFETY SYSTEM (GMDSS)
1 All
identities that may be used for identifying ships in distress should be
registered in accordance with this resolution and the data should be updated
whenever it changes.
2
Every State requiring or allowing the use of these GMDSS systems should make
suitable arrangements for ensuring registrations of these identities are made,
maintained and enforced.
3
Those responsible for maintaining registration databases for GMDSS equipment
should ensure that any MRCC can immediately access the registration data at any
time.
4 Means
should be provided for the GMDSS equipment licensee, owner or the ship's master
to easily and expediently update emergency information in the registration
database.
5 All
databases for GMDSS equipment should have an identical data format to permit
immediate
access among each other.
6 All
equipment using Maritime Mobile Service Identities (MMSIs) should be
registered, if appropriate, with the International Telecommunications Union in
accordance with established procedures.
7 All
Inmarsat equipment should be registered with Inmarsat.
8
Registration databases should include the following information, noting that
the data elements listed are not necessarily those maintained by the radio
licensing authority and that not all of the following entries need to be
notified to the ITU as long as the national database is identified and is
accessible 24-hours per day:
.1 ship name;
.2 Maritime Mobile Service Identity (MMSI);
.3 radio call sign;
.4 EPIRB identification code (if applicable) and its
homing frequency;
.5 country (ship flag State; may be derived from MMSI and
call sign);
- 3 -
.6 ship identification number (IMO number or national
registration number);
.7 brief ship description (type, gross tonnage, ship
superstructure, deck colours,
identifying marks, etc.);
.8 name, address, telephone and (if applicable) telefax
number of emergency contact
person ashore;
.9 alternative 24-hour emergency telephone number
(alternate contact ashore);
.10 capacity for persons on board (passengers and crew);
.11 radio installations (Inmarsat-A, B, C, M, VHF DSC,
etc.) for ship and survival
craft;
.12 identification numbers for all radio systems
available;
.13 type and number of survival craft; and
.14 date of last modification of database record.
9 For
406 MHz satellite Emergency Position Indicating Radiobeacons (EPIRBs), the
country
of registration should be coded in accordance with one of the following
principles:
.1 if the registration database is maintained by the
ship's flag State, use the Maritime
Identification Digits (MID) of the flag State;
.2 if the registration database is not maintained by the
ship's flag State, use:
.2.1 the MID of the flag State, and inform all
concerned where the unique database
containing its registry of 406 MHz satellite EPIRBs is
located; or
.2.2 serialized protocol with the MID of the country which
is maintaining the
database.
10
The data record of ships to which SOLAS chapter IV applies should be reviewed,
and the database information should be updated annually. Other ships should be
encouraged to update their data records annually or at least every other year.
11
Authorities maintaining or using databases should ensure that information
described in
- 4 -
paragraphs
8.4, 8.8, 8.9 and 8.12 above supplied for GMDSS equipment registration is used
only by appropriate recognized SAR authorities.
12
Every State should:
.1 maintain a suitable national database, or co-ordinate
with other States of their geographical area to maintain a joint database; and
additionally,
.2 for ships which are
using GMDSS frequencies and techniques or which are sailing internationally,
ensure that the data records of these ships are notified to an international
database (e.g. updated ITU database).
13
States should also:
.1 promulgate clear and timely guidance to manufacturers,
agents and users on the appropriate coding, registration and updating
procedures;
.2 co-operate closely with other States, manufacturers,
owners and organizations to help resolve any registration or
information-retrieval problems that may arise;
.3 formalize co-operative arrangements between the parties
concerned for the maintenance of the joint database;
.4 encourage manufacturers and distributors to advise
customers, upon purchase of GMDSS equipment, about registration requirements,
and refer unresolved coding and registration issues to proper national
authorities for resolution; and
.5 encourage manufacturers and distributors to educate
users about the maintenance of GMDSS equipment.
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