U.S. GMDSS IMPLEMENTATION TASK FORCE

Captain Jack Fuechsel, Exec. Director
7425 Elgar Street
Springfield, VA 22151
 5 November 1998
Dan Phythyon
Chief, Wireless Bureau
Federal Communications Commission
1919 M Street N.W.
Washington, DC 20554

Dear Mr. Phythyon,

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. I am writing at 
the request of the Task Force GMDSS Training Group to 
call your attention to a Training and Licensing 
problem which we believe can be resolved through 
amended administrative procedures.

The FCC now requires that at least two operators on 
board GMDSS ships hold the FCC's GMDSS Operator 
Certificate (GOC). While recommended, training is not 
required for this license provided the candidate can 
pass the FCC COLEM exam, a multiple choice test drawn 
from a question pool. Separately, the U.S. Coast 
Guard, as the administrator for implementation of the 
revised IMO Treaty on the Standards of Training, 
Certification, and Watchkeeping (STCW-95) will 
require that effective 1 February 2002, all masters 
and mates hold the FCC GOC license and qualify for a 
Coast Guard GMDSS endorsement certifying competence 
in the operation of GMDSS communications systems. 
Training is a prerequisite for this Coast Guard 
certification process which is administered by the 
Coast Guard's National Maritime Center (NMC).

The NMC requires a training program of at least 70 
hours duration including both theoretical 
examinations and practical demonstration of ability 
to operate GMDSS equipment. The NMC adopted a Task 
Force developed U.S. Model GMDSS Course based on the 
International GMDSS Model Course approved by the IMO. 
The NMC also approved a Task Force developed 
companion question pool of 500 questions keyed to the 
Model Course for use in administering the theoretical 
examinations. The NMC additionally accepted the offer 
by the Question Pool Subcommittee of the Training 
Task Group, to keep the pool current through a 
continuing review process involving the GMDSS 
teaching institutions, all of which are represented 
on the Training Task Group. Since the FCC COLEM exam 
and the Coast Guard theoretical exam are based on the 
same material, it would be less of a burden on these 
candidates if they did not have to take and pay for, 
a second written exam to obtain the FCC license.

It has become apparent that the separate requirements 
of the FCC and the Coast Guard for GMDSS credentials 
are becoming very confusing to both operators and 
administrators. The FCC will no doubt wish to 
continue its requirement for the GOC since some 
vessels required to comply with GMDSS rules have been 
exempted from the STCW-95 requirements. Since the 
Coast Guard's mandatory 70 hour training coupled with 
the written exam and practical demonstration of 
competency clearly exceeds the minimum FCC 
requirements, the Task Force recommends that the FCC 
issue the GOC without examination to graduates of 
Coast Guard approved GMDSS training courses.

The GMDSS Training Group approved this request at its 
meeting on 1 October 1998 with the concurrence of the 
Coast Guard NMC representative and the Chairman, 
MARAD's training specialist. It is hoped that this 
simple and logical change can be incorporated in FCC 
procedures. If the proposal is agreed in principal, 
detailed administrative procedures can be worked out 
between your staff and the NMC staff. The Task Force 
stands ready to assist as may be desired by either 
party and offers to utilize it's resources to 
promulgate any new policy to interested parties.

Sincerely,


JACK FUECHSEL

Copy to:  Ms Joy Alford, FCC
	   Commanding Officer, USCG National Maritime 
Center

file: trfcc-1.wpd/txt