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DRAFT PETITION TO FCC ON COLLECTION OF MMSI DATA

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 Organizationís (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 Ďby Ruleí 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 MMSIís, upon completion of a Memorandum of Understanding between the Commission, the Coast Guard and the organization, are authorized to issue MMSIís 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 Commissionís 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 andadopted 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 Commissionís 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 Commissionís 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).

 

- 2 -

 

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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