U.S. GMDSS IMPLEMENTATION TASK FORCE Captain Jack Fuechsel, Exec. Director 7425 Elgar Street Springfield, VA 22151 30 April 1999 Thomas J. Sugrue Chief, Wireless Bureau Federal Communications Commission 445 12th Street S.W. Washington, DC 20554 Dear Mr. Sugrue, 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) now being introduced by the International Maritime Organization. The Task Force membership is broad-based including government authorities, commercial vessel owners and operators, training institutions, service agents, manufacturers and maritime labor organizations. We have previously forwarded several Task Force recommendations to the Coast Guard and FCC on GMDSS issues. The Task Force has been aware that Part 80 of the FCC Rules is long overdue for revision, particularly with respect to Subpart W dealing with the GMDSS. The Task Force has compiled a series of recommendations for revision of the Rules both to accommodate GMDSS and in some cases to suggest other obsolete sections which should be updated. After several months of review in various subgroups, the Task Force approved the final section of these recommendations at its meeting on 30 March 1999. It is realized that a Petition for Rulemaking would be the correct format in which to present the recommendations but the scope of the recommendations are so broad as to require some degree of guidance from the FCC as to how Task Force expertise can best be focused on issues where you desire further input. The Task Force stands ready to assist the FCC with any GMDSS implementation issues on which our input might be desired. Sincerely, JACK FUECHSEL Enclosure: Task Force recommended changes to FCC Rules NATIONAL GMDSS IMPLEMENTATION TASK FORCE GMDSS Task Force recommended Changes to FCC Rules The following tabulation is a list of FCC Rules which appear to require deletion or modification to accommodate GMDSS implementation. The list also includes some articles not directly related to GMDSS which also appear to need updating. In some cases, formal recommendations for change have already been made to the FCC. In most of the following entries, only a brief comment on the need for a change is noted rather than provision of specific new wording. This list has been compiled from the latest published version of Title 47, U.S. Code Part 80, revision of 1 October 1997. 80.5 Definitions. "Categories of vessels" - expand definition which describes every non-passenger vessel as a cargo vessel recognizing special requirements for fishing vessels and recreational vessels. "Digital Selective Calling" - expand to refer to GMDSS usage in Sub Part W. "Distress Signal" - expand to refer to GMDSS distress alerts. "Safety Signal" - expand to describe GMDSS usage. "Urgency Signal" - expand to describe GMDSS usage. 80.15 (e) Class C EPIRBs - Delete (1), not authorized after 1 February 1999. Under (2) delete (ii) which restricts use of Class A & B EPIRBs to areas beyond VHF coastal coverage. 80.19 Standard Forms - In table suggest use of email in addition to Letter/Telegram for certain functions and broader acceptance of such informal communications which contain the needed information but are not on the official FCC form. 80.29 Changes during license term - authorize email along with written notice. 80.51 Ship earth station licensing - remove old verbiage about the Marisat system 80.57 Canada/USA channeling arrangements for VHF maritime public correspondence - This whole section seems overdue for a general updating. Consideration should be given to including DSC on VHF operations in the Great Lakes since both administrations plan VHF-DSC. Any changes would need to be coordinated with the Canadian government. 80.59 Compulsory ship inspections - This whole section needs updating in view of the new privatized inspection program. 80.61-80.83 Station requirements - Needs updating, contains obsolete telegraphy information and omits any mention of DSC. 80.86-80.90 Operating procedures - Needs general updating. 80.91 Order of priority of communications - Include GMDSS alerts in priorities. Needs to be consistent with ITU Regulations. 80.93 Hours of service - Add to (d) a requirement that voluntary ships equipped with DSC systems and/or Inmarsat ship earth stations maintain an automatic watch on the appropriate distress and safety calling frequencies and the appropriate frequencies for the automatic reception of meteorological and navigational warnings and other information to ships in accordance with ITU WRC 97 Article S31 MOD S31.17 Section 8 and MOD S 31.20 Section 9. (See also recommended action for Section 80.310). 80.97-80.100 - Radiotelegraph procedures - Consider whether it is timely to delete radiotelegraph procedures. 80.102 Radiotelephone station identification - Procedures should recognize the inherent identification included in Inmarsat, DSC, and EPIRB transmissions. 80.103 Digital selective calling (DSC) operating procedures - OK for private DSC systems but section should be expanded to reference the DSC operational guidance contained in Sub Part W for GMDSS. 80.116 Radiotelephone operating procedures for ship stations - Section should make reference to DSC procedures and drop reference to silent periods on 2182 khz. 80.141 General provisions for ship stations - Drop section (c), (1) on compulsory radiotelegraph ships. 80.145 Class C EPIRB - Drop, not authorized after 1 February 1999. 80.146 Watch on 500 khz - This watch is not required under GMDSS. 80.147 Watch on 2182 khz - Watch on 2182 khz is not required under GMDSS except upon receipt of a DSC alert on 2187.5 khz. See also Task Force comments on sections 80.305 and 80.901-935. (Note: requires amendment to Great Lakes Agreement). 80.148 Watch on 156.8 Mhz (channel 16) - Modify to recognize VHF-DSC watch requirement and extension of channel 16 watch until 1 February 2005 on GMDSS ships. 80.151 Classification of operator licenses and endorsements - Include GMDSS Radio Operator's License and new Restricted GMDSS Radio Operator's License as recommended by Task Force Petition of 14 January 1998. 80.157 Radio officer defined - Add GMDSS Radio Operator with appropriate text changes and reference to Subpart W. There is no GMDSS requirement for Radio Officers operating radiotelegraph stations. 80.159 Operator requirements of Title III of the Communications Act and the Safety Convention - Update for GMDSS Operator Licenses, consider changing references to radiotelegraph licenses which are not required for GMDSS. (There are a number of needed changes to the Communications Act of 1934 which the FCC should recommend to Congress). 80.161 Operator requirements of the Great Lakes Agreement - If VHF-DSC is adopted for use in the Great Lakes and the inland rivers as part of the Coast Guard's National Distress System, consideration should be given to requiring VHF- DSC in lieu of VHF without DSC for compulsory vessels with an effective date 6 months or more after the Coast Guard completes upgrade of it's coastal network to VHF-DSC. If this is done, the appropriate required license would be for Restricted GMDSS Radio Operator. (Note: requires amendment of Great Lakes Agreement). 80.165 Operator requirements for voluntary stations - Include terrestrial DSC systems and specify GMDSS and Restricted GMDSS Operator licenses as appropriate. 80.201-80.219 Subpart E General technical standards. Appears to need updating; recommend IEC Test Standards be incorporated by reference. Drop reference to Marisat. 80.221 Radiotelephone alarm signal - Consider whether there is a continuing application for this rule noting that the GMDSS makes no provision for continued use of the signal. 80.223 Special requirements for survival craft stations - delete references to 500, 2182, & 8364 khz which are not required or used from survival craft in the GMDSS. 80.251-80.273 Subpart F Equipment authorization for compulsory ships - delete; radiotelegraph transmitters, alarm signal receivers and keying devices, survival craft radio equipment operating on 500 and 8364 khz, radiotelephone distress frequency watch receivers are no longer required under GMDSS. 80.301 Coast Station Watch requirements - Consider deleting reference to 500 khz watch which has not been maintained a shore in the U.S. for years; delete reference to 2182 khz watches 6 months or more after Coast Guard shore network guard is augmented with 2187.5 khz DSC and compulsory craft presently required to have MF telephony have been shifted to MF-DSC. 80.304 Watch requirement during silence periods - Reference to silence periods should be deleted since there are no silence periods in GMDSS. Coordinate with changes to ITU Radio Regulations. 80.305 Watch requirements of the Communications Act and the Safety Convention - delete (a)(1) regarding 500 khz; delete (a)(2) regarding 2182 khz 6 months or more after Coast Guard completes augmentation of MF shore network with DSC and non-GMDSS compulsory MF vessels have been shifted to MF-DSC; edit (a)(3) on channel 16 watch to indicate mandatory watch by GMDSS vessels through 1 February 2005; and after 1 February 2005, delete channel 16 watch requirements 6 months after Coast Guard has completed VHF-DSC network upgrade and non-GMDSS compulsory VHF vessels have been shifted to VHF- DSC. Edit (b)(1),(2), & (3) similarly and incorporate required DSC and Inmarsat watches in all sections adding the requirement to copy NAVTEX and SafetyNET MSI broadcasts as appropriate to areas of operation. 80.305 & 80.307 Watch requirements. Consider deleting Radiotelegraph watch and auto alarm watch requirements which are not provided for in the GMDSS. Coordinate with changes to the ITU Radio Regulations. 80.308 Watch required by Great Lakes Radio Agreement - Transition this watch to VHF-DSC within 6 months of completion of the Coast Guard's upgrade of the shore network to VHF-DSC but require watch on both channel 70 and the bridge-to-bridge channel. (Note: requires amendment of Great Lakes Agreement). 80.310 Watch required by voluntary vessels - Include requirement for GMDSS watches on voluntary vessels made with respect to 80.93 above to enhance mutual safety. 80.311-80.333 Distress, Alarm, Urgency, and Safety Procedures - Not reviewed in detail but many changes needed to delete 500 and 8364 khz, and references to alarm signals, and to incorporate priorities specified in the DSC and Inmarsat systems. Needs to be consistent with ITU Regulations. 80.351-80.374 Subpart H Frequencies - Not reviewed in detail but many changes needed to delete morse radiotelegraphy and update frequency tables in accordance with ITU regulations. 80.375 Radiodetermination frequencies - Modify table and text in (a) to delete 410 and 500 khz. 80.401 Subpart I Station Documents - The following publications are recommended as appropriate for GMDSS ships: Equipment Operating Manuals for all GMDSS equipments FCC Rules, CFR 47, Part 80, latest edition ITU Manual for the Maritime Mobile Service ITU List IV List of Coast Stations ITU List V List of Ship Stations ITU List VI List of Radiodetermination Stations ITU List VIIA Alphabetical List of Call Signs IMO GMDSS Master Plan or U.S. NIMA Pub 117 (Note: The GMDSS Master Plan required by article 80.1085 should be broadened to accept NIMA Pub 117 as an alternative as recommended earlier by the Task Force in it's 29 July 1997 letter to the FCC noting that the IMO has already agreed to accept national publications in lieu of the GMDSS Master Plan.) 80.405 Station license - modify to identify stations which are 'licensed by Rule'. 80.409 Station Logs - The Task Force considered the matter of GMDSS log keeping in some detail and recommends generally that the requirements be minimized in recognition that the watch is being maintained by deck watch officers with other responsibilities. The GMDSS log keeping guidance provided by the IMO STCW B- VIII while consistent with traditional radio practice appears to be discretionary with Administrations rather that mandatory. The revised GMDSS log keeping rules could be given in Subpart W, Section 80.1075 or incorporated in Section 80.409 with appropriate notations. The primary GMDSS operator is the person designated to man the GMDSS watch in emergency and may be the shipboard GMDSS maintainer if one is assigned. The GMDSS watchstander is the mate on watch at the time. The following log keeping entries are suggested as sufficient to meet the minimum needs of safety communications under GMDSS: (a) A summary of Distress communications heard and Urgency communications affecting own ship. (b) A summary of Safety communications on other than VHF channels affecting own ship. (c) An entry shall be made by the primary GMDSS operator that pre-departure equipment checks were satisfactory and that required publications were on hand. He shall also make daily entries of satisfactory tests to ensure the continued proper functioning of GMDSS equipment. (d) An entry shall be made by the primary GMDSS Operator describing any malfunctioning GMDSS equipment and another entry when it is restored to normal operation. (e) A weekly entry shall be made by the primary GMDSS operator that the proper functioning of Digital Selective Calling (DSC) equipment has been verified by actual communications or a test call, the proper functioning of batteries or other reserve power sources, the testing of portable survival craft radio gear and radar transponders, and the inspection of EPIRBs. (f) The GMDSS watchstander shall log the time of any inadvertent transmissions of Distress, Urgency and Safety signals including the time and method of cancellation. (g) The GMDSS watchstander on a ship without integral or directly connected navigation receiver input to all GMDSS equipment capable of automatically transmitting a distress alert which includes position, shall manually update the embedded position in each equipment each watch and make a log entry of the fact. (h) A GMDSS radio log entry shall be made whenever GMDSS equipment is exchanged or replaced (ensuring that ship MMSI identifiers are properly updated in the replacement equipment), when major repairs to GMDSS equipments are accomplished, and when annual GMDSS inspections are conducted. 80.415 ITU publications - See 80.401 recommendation above. 80.801-80.836 Subpart Q - Compulsory radiotelegraph installations for vessels 1600 gross tons - Generally, convert whole sub part to voluntary carriage. If appropriate, retain Radar requirements in 80.825 but correct RTCM address. 80.851-80.877 Subpart R - Compulsory radiotelephone installations for vessels 300 gross tons - Delete whole section on the assumption that vessels over 300 tons must comply with the GMDSS requirements in Sub Part W. Create a new section or a new Subpart on recreational vessels noting that interpretations of the Communications Act of 1934 seem to require GMDSS installations on recreational vessels greater that 600 tons. Include recommendations made for Section 80.93. 80.901-80.935 Subpart S - Compulsory radiotelephone installations for small passenger boats - retain but upgrade requirements for VHF, MF, and HF to VHF-DSC, MF-DSC, and HF-DSC appropriate to the operating area. Allow 6 months or more after completion of the Coast Guard shore network upgrades to VHF-DSC and MF- DSC. HF-DSC is now operational. Correct AMVER address and phone number in both sections of 80.905. Delete requirement for radiotelephone distress frequency watch receiver and radiotelephone alarm signal generator. 80.951-80.971 - Subpart T - Radiotelephone installation required for vessels on the Great Lakes - retain but upgrade requirements to require VHF-DSC within 6 months or more of completion of the Coast Guard's upgrade of the coastal network in the Great Lakes to VHF-DSC. Consider adding a NAVTEX receiver if Coast Guard extends NAVTEX coverage to Great Lakes to augment existing Canadian coverage. (Note: requires amendment of Great Lakes Agreement). 80.1001-1023 - Subpart U - Bridge-to- bridge radiotelephone requirements - No change. 80.1051-80.1061 Subpart V - EPIRBs - Delete Class C EPIRB in 80.1057; update RTCM address and reference to Coast Guard (G-MVI) in 80.1061 80.1065-80.1135 - Subpart W - Global Maritime Distress and Safety System - generally OK but see following sections: 80.1073 Radio operator requirements for ship stations - Insert language to accept a Restricted GMDSS Radio Operator License for vessels operating in Sea Area A1 exclusively. Make reference to the Coast Guard STCW 95 GMDSS Certification that will be required of all deck officers on GMDSS ships effective 1 February 2002. 80.1074 (b) At-sea GMDSS Radio Maintainers. Delete (1), (2), and (3) and substitute GMDSS Maintainer License. [But note that the Coast Guard may require further proof of competence to certify a licensed GMDSS Maintainer for at-sea duty.] 80.1077 Frequencies - Amend table to include Inmarsat B along with whatever further correction is required to the FCC Rules to acknowledge the IMO acceptance of Inmarsat-B for GMDSS. 80.1085 Ship radio equipment - general - In (d) insert alternative to carry NIMA Pub 117 in lieu of the IMO GMDSS Master Plan as recommended by the Task Force in it's 29 July 1997 letter to the FCC noting that the IMO has already agreed to accept national publications in lieu of the GMDSS Master Plan. Add a new section requiring that all GMDSS equipment capable of transmitting an automatic distress alert which includes position must have an integral or connected navigation receiver input if one is installed, in accordance with ITU WRC 97 S32.5B which took effect 1 January 1999. Note that the IMO has a similar requirement which takes effect in 2002 including a requirement that if a navigation receiver is not connected, the position in the GMDSS transmitter must be manually updated with the ship's current position once each watch. 80.1095 Change (c) to require battery checks at intervals of 30 days rather than 12 months. 80.1099 Change f(2) to indicate that battery charge levels should be checked at intervals of 30 days or less with equipment turned ON and the battery charger turned OFF. Portable equipment with primary batteries such as EPIRBs and SARTs should be checked at the same intervals using methods recommended by the manufacturer. The results of battery checks should be recorded in the radio log. 80.1121 Receipt and acknowledgment of distress alerts by ship stations - revise to incorporate latest IMO/ITU guidance to prohibit automatic relay and sharply limit situations which justify a semi-automatic all ships relay of DSC alerts. 80.1123 Watch requirements for ship stations - modify date in (c) to require watch on channel 16 until 1 February 2005. file: fccrules.wpd/txt U.S. GMDSS IMPLEMENTATION TASK FORCE Captain Jack Fuechsel, Exec. Director 7425 Elgar Street Springfield, VA 22151 30 April 1999 Thomas J. Sugrue Chief, Wireless Bureau Federal Communications Commission 445 12th Street S.W. Washington, DC 20554 Dear Mr. Sugrue, 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) now being introduced by the International Maritime Organization. The Task Force membership is broad-based including government authorities, commercial vessel owners and operators, training institutions, service agents, manufacturers and maritime labor organizations. We have previously forwarded several Task Force recommendations to the Coast Guard and FCC on GMDSS issues. The Task Force has been aware that Part 80 of the FCC Rules is long overdue for revision, particularly with respect to Subpart W dealing with the GMDSS. The Task Force has compiled a series of recommendations for revision of the Rules both to accommodate GMDSS and in some cases to suggest other obsolete sections which should be updated. After several months of review in various subgroups, the Task Force approved the final section of these recommendations at its meeting on 30 March 1999. It is realized that a Petition for Rulemaking would be the correct format in which to present the recommendations but the scope of the recommendations are so broad as to require some degree of guidance from the FCC as to how Task Force expertise can best be focused on issues where you desire further input. The Task Force stands ready to assist the FCC with any GMDSS implementation issues on which our input might be desired. Sincerely, JACK FUECHSEL Enclosure: Task Force recommended changes to FCC Rules NATIONAL GMDSS IMPLEMENTATION TASK FORCE GMDSS Task Force recommended Changes to FCC Rules The following tabulation is a list of FCC Rules which appear to require deletion or modification to accommodate GMDSS implementation. The list also includes some articles not directly related to GMDSS which also appear to need updating. In some cases, formal recommendations for change have already been made to the FCC. In most of the following entries, only a brief comment on the need for a change is noted rather than provision of specific new wording. This list has been compiled from the latest published version of Title 47, U.S. Code Part 80, revision of 1 October 1997. 80.5 Definitions. "Categories of vessels" - expand definition which describes every non-passenger vessel as a cargo vessel recognizing special requirements for fishing vessels and recreational vessels. "Digital Selective Calling" - expand to refer to GMDSS usage in Sub Part W. "Distress Signal" - expand to refer to GMDSS distress alerts. "Safety Signal" - expand to describe GMDSS usage. "Urgency Signal" - expand to describe GMDSS usage. 80.15 (e) Class C EPIRBs - Delete (1), not authorized after 1 February 1999. Under (2) delete (ii) which restricts use of Class A & B EPIRBs to areas beyond VHF coastal coverage. 80.19 Standard Forms - In table suggest use of email in addition to Letter/Telegram for certain functions and broader acceptance of such informal communications which contain the needed information but are not on the official FCC form. 80.29 Changes during license term - authorize email along with written notice. 80.51 Ship earth station licensing - remove old verbiage about the Marisat system 80.57 Canada/USA channeling arrangements for VHF maritime public correspondence - This whole section seems overdue for a general updating. Consideration should be given to including DSC on VHF operations in the Great Lakes since both administrations plan VHF-DSC. Any changes would need to be coordinated with the Canadian government. 80.59 Compulsory ship inspections - This whole section needs updating in view of the new privatized inspection program. 80.61-80.83 Station requirements - Needs updating, contains obsolete telegraphy information and omits any mention of DSC. 80.86-80.90 Operating procedures - Needs general updating. 80.91 Order of priority of communications - Include GMDSS alerts in priorities. Needs to be consistent with ITU Regulations. 80.93 Hours of service - Add to (d) a requirement that voluntary ships equipped with DSC systems and/or Inmarsat ship earth stations maintain an automatic watch on the appropriate distress and safety calling frequencies and the appropriate frequencies for the automatic reception of meteorological and navigational warnings and other information to ships in accordance with ITU WRC 97 Article S31 MOD S31.17 Section 8 and MOD S 31.20 Section 9. (See also recommended action for Section 80.310). 80.97-80.100 - Radiotelegraph procedures - Consider whether it is timely to delete radiotelegraph procedures. 80.102 Radiotelephone station identification - Procedures should recognize the inherent identification included in Inmarsat, DSC, and EPIRB transmissions. 80.103 Digital selective calling (DSC) operating procedures - OK for private DSC systems but section should be expanded to reference the DSC operational guidance contained in Sub Part W for GMDSS. 80.116 Radiotelephone operating procedures for ship stations - Section should make reference to DSC procedures and drop reference to silent periods on 2182 khz. 80.141 General provisions for ship stations - Drop section (c), (1) on compulsory radiotelegraph ships. 80.145 Class C EPIRB - Drop, not authorized after 1 February 1999. 80.146 Watch on 500 khz - This watch is not required under GMDSS. 80.147 Watch on 2182 khz - Watch on 2182 khz is not required under GMDSS except upon receipt of a DSC alert on 2187.5 khz. See also Task Force comments on sections 80.305 and 80.901-935. (Note: requires amendment to Great Lakes Agreement). 80.148 Watch on 156.8 Mhz (channel 16) - Modify to recognize VHF-DSC watch requirement and extension of channel 16 watch until 1 February 2005 on GMDSS ships. 80.151 Classification of operator licenses and endorsements - Include GMDSS Radio Operator's License and new Restricted GMDSS Radio Operator's License as recommended by Task Force Petition of 14 January 1998. 80.157 Radio officer defined - Add GMDSS Radio Operator with appropriate text changes and reference to Subpart W. There is no GMDSS requirement for Radio Officers operating radiotelegraph stations. 80.159 Operator requirements of Title III of the Communications Act and the Safety Convention - Update for GMDSS Operator Licenses, consider changing references to radiotelegraph licenses which are not required for GMDSS. (There are a number of needed changes to the Communications Act of 1934 which the FCC should recommend to Congress). 80.161 Operator requirements of the Great Lakes Agreement - If VHF-DSC is adopted for use in the Great Lakes and the inland rivers as part of the Coast Guard's National Distress System, consideration should be given to requiring VHF- DSC in lieu of VHF without DSC for compulsory vessels with an effective date 6 months or more after the Coast Guard completes upgrade of it's coastal network to VHF-DSC. If this is done, the appropriate required license would be for Restricted GMDSS Radio Operator. (Note: requires amendment of Great Lakes Agreement). 80.165 Operator requirements for voluntary stations - Include terrestrial DSC systems and specify GMDSS and Restricted GMDSS Operator licenses as appropriate. 80.201-80.219 Subpart E General technical standards. Appears to need updating; recommend IEC Test Standards be incorporated by reference. Drop reference to Marisat. 80.221 Radiotelephone alarm signal - Consider whether there is a continuing application for this rule noting that the GMDSS makes no provision for continued use of the signal. 80.223 Special requirements for survival craft stations - delete references to 500, 2182, & 8364 khz which are not required or used from survival craft in the GMDSS. 80.251-80.273 Subpart F Equipment authorization for compulsory ships - delete; radiotelegraph transmitters, alarm signal receivers and keying devices, survival craft radio equipment operating on 500 and 8364 khz, radiotelephone distress frequency watch receivers are no longer required under GMDSS. 80.301 Coast Station Watch requirements - Consider deleting reference to 500 khz watch which has not been maintained a shore in the U.S. for years; delete reference to 2182 khz watches 6 months or more after Coast Guard shore network guard is augmented with 2187.5 khz DSC and compulsory craft presently required to have MF telephony have been shifted to MF-DSC. 80.304 Watch requirement during silence periods - Reference to silence periods should be deleted since there are no silence periods in GMDSS. Coordinate with changes to ITU Radio Regulations. 80.305 Watch requirements of the Communications Act and the Safety Convention - delete (a)(1) regarding 500 khz; delete (a)(2) regarding 2182 khz 6 months or more after Coast Guard completes augmentation of MF shore network with DSC and non-GMDSS compulsory MF vessels have been shifted to MF-DSC; edit (a)(3) on channel 16 watch to indicate mandatory watch by GMDSS vessels through 1 February 2005; and after 1 February 2005, delete channel 16 watch requirements 6 months after Coast Guard has completed VHF-DSC network upgrade and non-GMDSS compulsory VHF vessels have been shifted to VHF- DSC. Edit (b)(1),(2), & (3) similarly and incorporate required DSC and Inmarsat watches in all sections adding the requirement to copy NAVTEX and SafetyNET MSI broadcasts as appropriate to areas of operation. 80.305 & 80.307 Watch requirements. Consider deleting Radiotelegraph watch and auto alarm watch requirements which are not provided for in the GMDSS. Coordinate with changes to the ITU Radio Regulations. 80.308 Watch required by Great Lakes Radio Agreement - Transition this watch to VHF-DSC within 6 months of completion of the Coast Guard's upgrade of the shore network to VHF-DSC but require watch on both channel 70 and the bridge-to-bridge channel. (Note: requires amendment of Great Lakes Agreement). 80.310 Watch required by voluntary vessels - Include requirement for GMDSS watches on voluntary vessels made with respect to 80.93 above to enhance mutual safety. 80.311-80.333 Distress, Alarm, Urgency, and Safety Procedures - Not reviewed in detail but many changes needed to delete 500 and 8364 khz, and references to alarm signals, and to incorporate priorities specified in the DSC and Inmarsat systems. Needs to be consistent with ITU Regulations. 80.351-80.374 Subpart H Frequencies - Not reviewed in detail but many changes needed to delete morse radiotelegraphy and update frequency tables in accordance with ITU regulations. 80.375 Radiodetermination frequencies - Modify table and text in (a) to delete 410 and 500 khz. 80.401 Subpart I Station Documents - The following publications are recommended as appropriate for GMDSS ships: Equipment Operating Manuals for all GMDSS equipments FCC Rules, CFR 47, Part 80, latest edition ITU Manual for the Maritime Mobile Service ITU List IV List of Coast Stations ITU List V List of Ship Stations ITU List VI List of Radiodetermination Stations ITU List VIIA Alphabetical List of Call Signs IMO GMDSS Master Plan or U.S. NIMA Pub 117 (Note: The GMDSS Master Plan required by article 80.1085 should be broadened to accept NIMA Pub 117 as an alternative as recommended earlier by the Task Force in it's 29 July 1997 letter to the FCC noting that the IMO has already agreed to accept national publications in lieu of the GMDSS Master Plan.) 80.405 Station license - modify to identify stations which are 'licensed by Rule'. 80.409 Station Logs - The Task Force considered the matter of GMDSS log keeping in some detail and recommends generally that the requirements be minimized in recognition that the watch is being maintained by deck watch officers with other responsibilities. The GMDSS log keeping guidance provided by the IMO STCW B- VIII while consistent with traditional radio practice appears to be discretionary with Administrations rather that mandatory. The revised GMDSS log keeping rules could be given in Subpart W, Section 80.1075 or incorporated in Section 80.409 with appropriate notations. The primary GMDSS operator is the person designated to man the GMDSS watch in emergency and may be the shipboard GMDSS maintainer if one is assigned. The GMDSS watchstander is the mate on watch at the time. The following log keeping entries are suggested as sufficient to meet the minimum needs of safety communications under GMDSS: (a) A summary of Distress communications heard and Urgency communications affecting own ship. (b) A summary of Safety communications on other than VHF channels affecting own ship. (c) An entry shall be made by the primary GMDSS operator that pre-departure equipment checks were satisfactory and that required publications were on hand. He shall also make daily entries of satisfactory tests to ensure the continued proper functioning of GMDSS equipment. (d) An entry shall be made by the primary GMDSS Operator describing any malfunctioning GMDSS equipment and another entry when it is restored to normal operation. (e) A weekly entry shall be made by the primary GMDSS operator that the proper functioning of Digital Selective Calling (DSC) equipment has been verified by actual communications or a test call, the proper functioning of batteries or other reserve power sources, the testing of portable survival craft radio gear and radar transponders, and the inspection of EPIRBs. (f) The GMDSS watchstander shall log the time of any inadvertent transmissions of Distress, Urgency and Safety signals including the time and method of cancellation. (g) The GMDSS watchstander on a ship without integral or directly connected navigation receiver input to all GMDSS equipment capable of automatically transmitting a distress alert which includes position, shall manually update the embedded position in each equipment each watch and make a log entry of the fact. (h) A GMDSS radio log entry shall be made whenever GMDSS equipment is exchanged or replaced (ensuring that ship MMSI identifiers are properly updated in the replacement equipment), when major repairs to GMDSS equipments are accomplished, and when annual GMDSS inspections are conducted. 80.415 ITU publications - See 80.401 recommendation above. 80.801-80.836 Subpart Q - Compulsory radiotelegraph installations for vessels 1600 gross tons - Generally, convert whole sub part to voluntary carriage. If appropriate, retain Radar requirements in 80.825 but correct RTCM address. 80.851-80.877 Subpart R - Compulsory radiotelephone installations for vessels 300 gross tons - Delete whole section on the assumption that vessels over 300 tons must comply with the GMDSS requirements in Sub Part W. Create a new section or a new Subpart on recreational vessels noting that interpretations of the Communications Act of 1934 seem to require GMDSS installations on recreational vessels greater that 600 tons. Include recommendations made for Section 80.93. 80.901-80.935 Subpart S - Compulsory radiotelephone installations for small passenger boats - retain but upgrade requirements for VHF, MF, and HF to VHF-DSC, MF-DSC, and HF-DSC appropriate to the operating area. Allow 6 months or more after completion of the Coast Guard shore network upgrades to VHF-DSC and MF- DSC. HF-DSC is now operational. Correct AMVER address and phone number in both sections of 80.905. Delete requirement for radiotelephone distress frequency watch receiver and radiotelephone alarm signal generator. 80.951-80.971 - Subpart T - Radiotelephone installation required for vessels on the Great Lakes - retain but upgrade requirements to require VHF-DSC within 6 months or more of completion of the Coast Guard's upgrade of the coastal network in the Great Lakes to VHF-DSC. Consider adding a NAVTEX receiver if Coast Guard extends NAVTEX coverage to Great Lakes to augment existing Canadian coverage. (Note: requires amendment of Great Lakes Agreement). 80.1001-1023 - Subpart U - Bridge-to- bridge radiotelephone requirements - No change. 80.1051-80.1061 Subpart V - EPIRBs - Delete Class C EPIRB in 80.1057; update RTCM address and reference to Coast Guard (G-MVI) in 80.1061 80.1065-80.1135 - Subpart W - Global Maritime Distress and Safety System - generally OK but see following sections: 80.1073 Radio operator requirements for ship stations - Insert language to accept a Restricted GMDSS Radio Operator License for vessels operating in Sea Area A1 exclusively. Make reference to the Coast Guard STCW 95 GMDSS Certification that will be required of all deck officers on GMDSS ships effective 1 February 2002. 80.1074 (b) At-sea GMDSS Radio Maintainers. Delete (1), (2), and (3) and substitute GMDSS Maintainer License. [But note that the Coast Guard may require further proof of competence to certify a licensed GMDSS Maintainer for at-sea duty.] 80.1077 Frequencies - Amend table to include Inmarsat B along with whatever further correction is required to the FCC Rules to acknowledge the IMO acceptance of Inmarsat-B for GMDSS. 80.1085 Ship radio equipment - general - In (d) insert alternative to carry NIMA Pub 117 in lieu of the IMO GMDSS Master Plan as recommended by the Task Force in it's 29 July 1997 letter to the FCC noting that the IMO has already agreed to accept national publications in lieu of the GMDSS Master Plan. Add a new section requiring that all GMDSS equipment capable of transmitting an automatic distress alert which includes position must have an integral or connected navigation receiver input if one is installed, in accordance with ITU WRC 97 S32.5B which took effect 1 January 1999. Note that the IMO has a similar requirement which takes effect in 2002 including a requirement that if a navigation receiver is not connected, the position in the GMDSS transmitter must be manually updated with the ship's current position once each watch. 80.1095 Change (c) to require battery checks at intervals of 30 days rather than 12 months. 80.1099 Change f(2) to indicate that battery charge levels should be checked at intervals of 30 days or less with equipment turned ON and the battery charger turned OFF. Portable equipment with primary batteries such as EPIRBs and SARTs should be checked at the same intervals using methods recommended by the manufacturer. The results of battery checks should be recorded in the radio log. 80.1121 Receipt and acknowledgment of distress alerts by ship stations - revise to incorporate latest IMO/ITU guidance to prohibit automatic relay and sharply limit situations which justify a semi-automatic all ships relay of DSC alerts. 80.1123 Watch requirements for ship stations - modify date in (c) to require watch on channel 16 until 1 February 2005. file: fccrules.wpd/txt