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Author Topic:   FCC: MMSI Request For Comments
jimh posted 10-19-2007 09:26 PM ET (US)   Profile for jimh   Send Email to jimh  
The current contents of the BoatUS PUBLIC AFFAIRS web page at

http://www.boatus.com/gov/

alerts recreational boaters (and particularly those who have registered for a marine mobile service identity or MMSI) to a public notice from the FCC seeking comments from vessel operators regarding the inconvenience and cost of embedding new MMSI numbers in DSC VHF marine radios.

The problem at hand for boaters in the United States who have obtained an MMSI from a private register (such as BoatUS) is that their MMSI's will not be useful outside the United States. If a United States boater wants to cruise abroad, they'll have to obtain a new MMSI from the FCC. And abroad means Canada.

The irony of this situation is that private registries, like BoatUS, originally obtained the blocks of numbers they give out to boaters FROM the FCC. But due to some administrative or technical problem, the FCC cannot re-enter the data back into their database.

Here is the FCC official notice:

http://fjallfoss.fcc.gov/edocs_public/attachmatch/DA-07-4212A1.doc

ASIDE: I cannot believe that the FCC expects you to purchase Microsoft WORD in order to read their public document. It should be in PDF format.

This situation is really a burden on boaters, because most modern DSC radios cannot have their MMSI entry altered by except by sending the radio back to the manufacturer.

My personal opinion is that in this day and age it is ridiculous to expect boaters to undertake the cost and trouble of shipping their radios back to the manufacturers just because the FCC cannot figure out how to merge information into their database!

Comments are due by November 13, 2007.

To comment on-line, visit

http://fjallfoss.fcc.gov/prod/ecfs/upload_v2.cgi

The proceeding number is 07-230.

Here is the FCC's public notice converted from WORD format;

---------


DA 07-4212
Released: October 11, 2007
WIRELESS TELECOMMUNICATIONS BUREAU SEEKS COMMENT ON REQUEST OF NATIONAL GMDSS IMPLEMENTATION TASK FORCE REGARDING MARITIME MOBILE SERVICE IDENTITIES

WT Docket No. 07-230

Comment Date: November 13, 2007
Reply Date: November 28, 2007

A maritime mobile service identity (MMSI) is a unique nine-digit number assigned to commercial and recreational U.S. vessels participating in the Global Maritime Distress and Safety System (GMDSS). The Commission assigns MMSIs to licensed vessels as part of the ship station licensing process. Operators of vessels that are not required to obtain an individual ship station license (“exempt” vessels) can obtain MMSIs from designated private entities. Exempt vessels with privately-issued MMSIs that later obtain individual ship station licenses receive new MMSIs in the licensing process.

On May 29, 2007, the National GMDSS Implementation Task Force (GMDSS Task Force) filed a petition requesting that the Commission alter the Universal Licensing System (ULS) so as to permit operators of exempt vessels that later obtain individual ship station licenses to retain the privately-issued MMSI. Conversely, the GMDSS Task Force also recommends that the designated private entities be permitted to manage MMSIs originally issued by the Commission when the operator of a licensed vessel decides not to renew the station license. The GMDSS Task Force argues that such modifications of the licensing process would alleviate a burden on operators by eliminating the need to have the new MMSI programmed into their shipboard equipment. Another suggested benefit is that it would prevent the same vessel from being assigned two MMSIs concurrently, which wastes numbers. We seek comment on these proposals. Commenters should particularly address the extent to which the current process burdens vessel operators, both with respect to the number of affected vessels and the degree of burden on each affected operator.

Relatedly, the GMDSS Task Force notes that the Commission has expanded the vessel descriptive data required on applications for new ship station licenses in order to enhance search and rescue operations. The GMDSS Task Force recommends that the Commission require incumbent licensees to provide the expanded data when they apply for license renewal. It also suggests that the Commission periodically contact licensees and other MMSI registrants to verify that the data on file remains correct, and that the MMSI is still active. It states that this will facilitate the recycling of numbers. We seek comment on these proposals. Commenters should particularly address the degree to which the lack of updated data has impeded search and rescue efforts.

Procedural Matters

Comments on the Request are due no later than November 13, 2007. Reply comments are due no later than November 28, 2007. All filings should reference the docket number of this proceeding, WT 07-230.

This proceeding has been designated as a “permit-but-disclose” proceeding in accordance with the Commission's ex parte rules. Parties making oral ex parte presentations in this proceeding are reminded that memoranda summarizing the presentation must contain the presentation’s substance and not merely list the subjects discussed. More than a one- or two-sentence description of the views and arguments presented is generally required.

The Request is available for public inspection and copying in the Commission's Reference Center, Room CY-A257, 445 12th Street, S.W., Washington, D.C. 20554. Copies of the Request also may be obtained via the Commission's Electronic Comment Filing System (ECFS) by entering the docket number, WT 07-230. Copies of the Request are also available from Best Copy and Printing, Inc., telephone (800) 378-3160, facsimile (301) 816-0169, e-mail FCC@BCPIWEB.com.

Comments may be filed using the Commission's Electronic Comment Filing System (ECFS) or by filing paper copies. See Electronic Filing of Documents in Rulemaking Proceedings, 63 Fed. Reg. 24121 (1998). Comments filed through the ECFS can be sent as an electronic file via the Internet to http:// www.fcc.gov/cgb/ecfs/. Generally, only one copy of an electronic submission must be filed. If multiple docket or rulemaking numbers appear in the caption of this proceeding, however, commenters must transmit one electronic copy of the comments to each docket or rulemaking number referenced in the caption. In completing the transmittal screen, commenters should include their full name, U.S. Postal Service mailing address, and the applicable docket or rulemaking number. Parties may also submit an electronic comment by Internet e-mail. To get filing instructions for e-mail comments, commenters should send an e-mail to ecfs@fcc.gov, and should include the following words in the body of the message, “get form.” A sample form and directions will be sent in reply.

Parties who choose to file by paper must file an original and four copies of each filing. If more than one docket or rulemaking number appears in the caption of this proceeding, commenters must submit two additional copies for each additional docket or rulemaking number.

Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-class or overnight U.S. Postal Service mail (although we continue to experience delays in receiving U.S. Postal Service mail). The Commission's contractor will receive hand-delivered or messenger-delivered paper filings for the Commission's Secretary at 236 Massachusetts Avenue, N.E., Suite 110, Washington, D.C. 20002.

-The filing hours at this location are 8:00 a.m. to 7:00 p.m.
-All hand deliveries must be held together with rubber bands or fasteners.
-Any envelopes must be disposed of before entering the building.
-Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
-U.S. Postal Service first-class mail, Express Mail, and Priority Mail should be addressed to 445 12th Street, S.W., Washington, D.C. 20554.
-All filings must be addressed to the Commission's Secretary, Office of the Secretary, Federal Communications Commission.

Parties shall send one copy of their comments and reply comments to Best Copy and Printing, Inc., Portals II, 445 12th Street, S.W., Room CY-B402, Washington, D.C. 20554, (800) 378-3160, e-mail FCC@BCPIWEB.com.

Comments filed in response to this Public Notice will be available for public inspection and copying during business hours in the FCC Reference Information Center, Portals II, 445 12th Street S.W., Room CY-A257, Washington, D.C. 20554, and via the Commission's Electronic Comment Filing System (ECFS) by entering the docket number, WT 07-230. The comments may also be purchased from Best Copy and Printing, Inc., telephone (800) 378-3160, facsimile (301) 816-0169, e-mail FCC@BCPIWEB.com.

Alternate formats of this Public Notice (computer diskette, large print, audio recording, and Braille) are available to persons with disabilities by contacting Brian Millin at (202) 418-7426 (voice), (202) 418-7365 (TTY), or send an e-mail to access@fcc.gov.

For further information, contact Mr. Ghassan Khalek of the Wireless Telecommunications Bureau, Mobility Division, at (202) 418-1327, ghassan.khalek@fcc.gov.

Action by the Deputy Chief, Mobility Division, Wireless Telecommunications Bureau.

- FCC -

A vessel is not required to be individually licensed if it is not subject to any radio equipment carriage requirement under any statute, treaty, or agreement to which the United States is a party; does not travel to foreign ports or make international communications; and does not carry equipment other than VHF (156-162 MHz) radios, emergency position-indicating radio beacons, and radar installations. See 47 C.F.R. § 80.13(c).

See Commission Announces Agreements with Shine Micro, Inc., and United States Power Squadrons, Inc., and Termination of Agreement with Maritel, Inc., Regarding Assignment of Maritime Mobile Service Identities (MMSIs), Public Notice, 22 FCC Rcd 7329 (WTB MD 2007) (listing entities from which operators of exempt vessels can obtain MMSIs).

The GMDSS Task Force was chartered by the U.S. Coast Guard to supplement government functions in expediting the implementation of the GMDSS. The membership includes over 1,500 representatives of government agencies, commercial vessel owners and operators, recreational vessel interests, training institutions, service agents, manufacturers, trade associations and maritime labor organizations.

Petition to Request the FCC Adopt New Policies and Procedures Regarding MMSI Assignments (filed May 29, 2007) (Request).

See 47 C.F.R. §§ 1.1200(a), 1.1206.

See Commission Emphasizes the Public’s Responsibilities in Permit-But-Disclose Proceedings, Public Notice, 15 FCC Rcd 19945 (2000).

See 47 C.F.R. § 1.1206(b)(2). Other rules pertaining to oral and written presentations are also set forth in Section 1.1206(b). See 47 C.F.R. § 1.1206(b).

PUBLIC NOTICE

Federal Communications Commission
445 12th St., S.W.
Washington, D.C. 20554

News Media Information 202 / 418-0500
Fax-On-Demand 202 / 418-2830
TTY 202 / 418-2555
Internet: http://www.fcc.gov
ftp.fcc.gov


Chuck Tribolet posted 10-20-2007 06:58 AM ET (US)     Profile for Chuck Tribolet  Send Email to Chuck Tribolet     
One more problem: If you have to change your MMSI, it's
like a telephone number change -- your correspondents have
to change their address books. (Yes, Jim, we do use DSC
for boat-to-boat calls here on the left coast).


Chuck

bluewaterpirate posted 10-20-2007 09:34 AM ET (US)     Profile for bluewaterpirate  Send Email to bluewaterpirate     
DSC vhf radios are programed to permit the users to enter the MMSI # twice. If you've only used one of these attempts then your fine you can go back enter your new MMSI #. As JimH pointed out if you've used both attempts then it's back to the factor. This not only affects DSC vhf radios but also EPIRBS.
jimh posted 10-20-2007 10:23 AM ET (US)     Profile for jimh  Send Email to jimh     
The older DSC radios seem to allow the MMSI to be entered twice, however on my current radio, a newer Class-D radio from Standard Horizon, the MMSI can only be entered ONCE. If the MMSI is to be changed after that, the radio has to be sent back to the manufacturer for programming.
bluewaterpirate posted 10-20-2007 11:47 AM ET (US)     Profile for bluewaterpirate  Send Email to bluewaterpirate     
Then shame on Standard Horizon for that idiotic change to MMSI protocol. Stupid piece of engineering.
Moe posted 10-20-2007 12:38 PM ET (US)     Profile for Moe  Send Email to Moe     
The FCC document can be read with Microsoft WordPad or OS-X TextEdit, both of which come with their respective OS. It can also be read with at least most formatting by the free multi-platform AbiWord and OpenOffice.Org, the free OS-X-specific NeoOffice port of OpenOffice.Org, Apple's commercial Pages 2.02 and 3.01, as well as Corel's commercial WordPerfect product for Windows.

It would've been nice to have been able to use our BoatUS-issued MMSI with LUFF SHACK's ship station license (approximately $160 for ten years, if I recall correctly). Instead we got a new FCC-issued MMSI and I went to BoatUS and cancelled the one we had there. Our Icom allowed two programmings, so that wouldn't have been a problem had we not sold it with the Whaler. The BoatUS-issued MMSI wasn't, but the FCC-issued one is in the ITU maritime database here:

http://www.itu.int/cgi-bin/htsh/mars/ship_search.sh

Should we decide not to renew the ship station license, it will be nice if this proposal is implemented and we can keep our current FCC-issued MMSI, maintained subsequently by BoatUS, etc.

As far as Class D VHF radios go, the Standard Horizon PS2000, GX3000S Matrix, and CPV350 VHF/GPS allow programming the MMSI twice, as does the Icom M504 and M604, and the Uniden UM525om. The SH GX5000S/GX5500S do not.

--
Moe

jimh posted 10-20-2007 03:52 PM ET (US)     Profile for jimh  Send Email to jimh     
Regarding the behavior of Standard Horizon radios when programming them with an MMSI:

I have a Standard Horizon GX1500S "Quest-X" radio that I purchased in the spring of 2007. If you read the printed manual which accompanies the radio, or if you download the PDF file from the Standard Horizon website, and consult the section about programming the radio with an MMSI, you will be informed that this operation can be performed twice by the user. However, included in the packaging that came with my radio was a small printed erratum sheet. The erratum sheet is designated

Quest-X GX1500S
Owner's Manual Erratum Sheet

and contains corrections for Page 33, Section 11.2.2 Programming the MMSI.

The correction is to change the word TWICE to ONCE in regard to the number of times the radio can have the user enter the MMSI number during set up. The manual should contain this warning:

WARNING

User MMSI can be input only ONCE, please be careful not to input the incorrect MMSI number

I cannot say with any authority if there are other errors in other printed or PDF documents related to Standard Horizon radios, but I would recommend carefully checking the packaging when opening a new Standard Horizon radio to check for an erratum sheet. I have corrected the printed version of my manual.

Assertions about the behavior of other Standard Horizon radios should be clarified that they are based on actual possession of the radio and having checked carefully for any erratum for the manual. If one relies on the PDF files as a source, they may be making an mistake.

Moe posted 10-20-2007 04:04 PM ET (US)     Profile for Moe  Send Email to Moe     
That is good advice. It's very easy to make a change to firmware in production.

--
Moe

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