ICOM Comments to FCC Re DSC Class-D Radios

VHF Marine Band radios, protocol, radio communication theory, practical advice; AIS; DSC; MMSI; EPIRB.
jimh
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ICOM Comments to FCC Re DSC Class-D Radios

Postby jimh » Wed Mar 01, 2017 10:07 am

I recently wrote about a compliance problem encountered by ICOM in meeting FCC regulations regarding mandatory features to be included in a VHF Marine Band Class-D Digital Selective calling radio. Perhaps directly related to that action, ICOM filed some Ex-parte comments with the FCC in reply to their Docket RM-11765 ("WIRELESS TELECOMMUNICATIONS BUREAU SEEKS COMMENT ON RADIO TECHNICAL COMMISSION FOR MARITIME SERVICES PETITION FOR RULEMAKING TO UPDATE PART 80 OF THE COMMISSION'S RULES") regarding their opinion of what features were necessary in a Class-D DSC radio, and how the FCC's interpretation of the recommendations might not be particularly beneficial to users or perhaps even correct. The comments are on-file for public inspection at

https://ecfsapi.fcc.gov/file/107291223105915/Icom%20Ex%20Parte%20Comments%20In%20Maritime%20Rule%20Making%207-29-2016.pdf

They make quite interesting reading. For anyone interested in DSC radio operation, I recommend visiting the above link and reading ICOM's remarks. ICOM points out that the FCC has already changed their rules regarding DSC radio features several times without seeking public comments before implementing the change, resulting in the adoption of rules that require mandatory inclusion into DSC Class-D radios of complex and unnecessary features. ICOM further asserts that "few (if any)" DSC radios on the market now provide these features. They also comment that "requiring these parallel procedures, introduced as part of Rev. 13, only serve to needlessly increase the cost of Class D equipment for services not necessary for recreational use." ICOM says, in part:

Icom’s review of the equipment capabilities of other manufacturers of VHF-DSC
equipment is that few (if any) manufacturers comply with the following provisions of
ITU-R M.493-13 Annex 4: 1; 2.19; 2.21; 2.22; 3.1.5; 3.2.5; 3.2.5.1; 3.3.3.1; 3.2.5.2;
3.2.5.3; 3.2.6; 3.2.6.1; 3.2.6.2; 3.2.6.3; 3.3.1; 3.3.2; 3.3.3.2; and 3.3.4. Each of these
provisions are automated procedures that run in parallel with other automated procedures.


Icom respectfully requests that the Commission undertake a complete review of [ITU-R M.493-14]
requirements, and adopt only those alterations which are mandatory, or otherwise found
to be important for United States ships. Further, until the Commission completes its
review of these provisions, Icom urges the Commission to temporarily waive the rule
provisions cited below, pending the outcome of this proceeding.


Regarding the proposed changes recommended by the Radio Technical Commission for Maritime Services (RTCM), their recommendations can be found at

https://ecfsapi.fcc.gov/file/60001459665.pdf

The FCC's request for comments can be found at:

https://ecfsapi.fcc.gov/file/60001569598.pdf

jimh
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Re: ICOM Comments to FCC Re DSC Class-D Radios

Postby jimh » Wed Mar 01, 2017 10:33 am

If you are interested in the RTCM's proposed changes to Part 80, here is the complete filing of those changes:

https://ecfsapi.fcc.gov/file/60001459667.pdf

This document is generally omitted from other mentions of this filing and is listed only as an "attachment" to them.