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Author Topic:   FCC Regulations for Portable VHF Marine Radios
jimh posted 04-28-2015 06:31 AM ET (US)   Profile for jimh   Send Email to jimh  
According to the FCC regulations, beginning on March 25, 2015--about one month ago--there is a prohibition against the manufacture, importation, and sale of portable digital selective calling (DSC)-equipped radios that do not meet the requirements of ITU–R Recommendation M.493–11 or higher and IEC 62238. Those requirements are generally known as the DSC CLASS-D rating.

The most important aspect of these regulations is to be cognizant that the sale of non-compliant portable radios is prohibited. I recommend careful checking of any portable radio you might consider buying to be sure it is compliant.

There appears to be no prohibition against the use of existing portable DSC radios that do not comply with the newer technical standards. My inference: if you presently own a DSC portable radio that is not compliant with the new standards, you can continue to use it.

More information is contained in a Coast Guard notice. See

http://www.navcen.uscg.gov/pdf/gmdss/DSC_Notice.pdf

The Coast Guard explains the reason behind the regulations to require DSC radios to conform to the newer CLASS-D rating:

quote:
Compliance with these new international technical standards ensure DSC-equipped radios will incorporate many new safety features and functions, including eliminating dangers associated with automatic channel switching addressed in Coast Guard Safety Alert 02-10 of April 13, 2010. New features also include provisions for making test calls, dual receiver functionality to improve operation, and Global Positioning System (GPS) interconnection alarms designed to ensure that distress alerts include a valid and accurate position. The new requirements ensure improved detection of distress alerts, a reduction in the rate of false alarms, and reduced incessant alarming caused by DSC-equipped radios meeting the older standard.

(A similar prohibition was imposed on fixed-mount VHF Marine Band radios, with the statutory date of March 25, 2011 marking the beginning of the new regulations. The Coast Guard clarified that "...previously-installed radios meeting the older standard may continue to be used.")

These new regulations requiring compliance with CLASS-D standards brings boaters to a rather difficult situation. A radio rated to CLASS-D digital selective calling (DSC) standards should not provide any DSC functions until the radio has been given a maritime mobile service identity (MMSI). A boater must then determine what MMSI should be entered into his portable DSC radio.

The topic of maritime mobile service identities (MMSI's) was discussed recently in a separate thread:

MMSI: Where and How to Get One
http://continuouswave.com/ubb/Forum6/HTML/003679.html

Let me repeat some of that discussion here, with an emphasis on the assignment of an MMSI to a portable radio.

The proper MMSI to be used with a handheld VHF Marine Band radio with DSC features is discussed at the U.S. Coast Guard website NavCenter. See:

http://www.navcen.uscg.gov/?pageName=mtMmsi

There you will find the following interesting information:

quote:
Obtaining MMSIs for DSC-equipped VHF Handhelds

A handheld VHF transceiver with DSC and an integral global navigation satellite system (e.g. GPS) not intended for dedicated use on a particular ship (e.g. a diver’s radio) should be assigned a unique 9-digit number in the format 81M2I3D4X5X6X7X8X9. While currently means do not exist within the U.S. to assign such identities, the Coast Guard has been in discussions with the Federal communications Commission and others on implementing them.

In the interim, VHF handhelds used in the United States should use the MMSI assigned to the ship to which the handheld is primarily associated, even if another radio on that ship uses the same MMSI. Non-commercial users of VHF handhelds not primarily associated with any single ship may use an MMSI provided by an organization such as BOAT US, SEA TOW and U.S. Power Squadron (see above). VHF handhelds should not be used ashore absent FCC or NTIA authorization allowing such use.


To summarize what has been said above: there are regulations in existence for a handheld radio not intended to be dedicated to a particular vessel to have its own MMSI, but there are no means to implement this in the USA. If you use a handheld with more than one boat, get the handheld its own MMSI from BoatUS or other private issuing agencies.

This seems to me to be a classic case of the government enacting regulations imposing a burden on its citizens, and then failing to provide the necessary facilities of government for the citizens to comply with the regulations. The FCC is telling us, if we get a new portable radio with digital selective calling, we must get a radio that won't work as a DSC radio at all until we give it an MMSI, but the FCC is not able to supply the proper MMSI. Instead, boaters should get a MMSI that does not comply with the international guidelines, and use that MMSi.

The problem with this approach is made even more ridiculous when you consider that one of the requirements of the new DSC regulations is that the MMSI cannot be changed by the user once a radio has been given an MMSI. This means that, if some day the FCC gets itself organized to provide the proper MMSI for portable radios not associated with an individual boat, and a boater obtains an MMSI for the portable radio, the new MMSI cannot be entered into the portable radio. The boater will have to send the radio back to the manufacturer to be reset. For those of you familiar with Joseph Heller's fiction, this makes me feel like Yossarian in CATCH-22.

kmev posted 05-29-2015 08:54 PM ET (US)     Profile for kmev  Send Email to kmev     
I ran into this problem a year ago. I gave the portable radio the same MMSI as my personally-owned boat. I use this radio aboard my personal boat less than ten percent of the radio's actual time offshore. Its probably not legal, but I am hopeful that someone responds to my potential DSC distress call regardless of whether or not I am aboard the proper boat.
jimh posted 05-29-2015 09:33 PM ET (US)     Profile for jimh  Send Email to jimh     
When a radio with digital selective calling (DSC) sends a DISTRESS ALERT message, that message will be received by two distinct types of receiving stations:

--stations on other boats; and

--stations on shore that are part of the official maritime agency; in the USA that would be the Coast Guard.

Another boat (or ship) that receives a distress alert, whether the distress alert is a voice transmission announcing MAYDAY or a DSC transmission making a DISTRESS ALERT call, is bound in the USA by federal regulations which require that the "vessel shall render assistance to any individual found at sea in danger of being lost, so far as the master or individual in charge can do so without serious danger to the master’s or individual’s vessel or individuals on board."

Cf.: https://www.law.cornell.edu/uscode/text/46/2304

A ship station receiving a DISTRESS ALERT does not have a method to look up the identity of the registrant of the maritime mobile service identity (MMSI) that is associated with the distress alert message. In the case described by KMEV, another ship receiving his hand-held radio's distress alert transmission should treat it in a consistent manner, no matter if the MMSI is not associated with the vessel that KMEV happens to be transmitting from because they have no way of knowing anything about the registrant or the vessel associated with the MMSI. They can't get to that data.

A shore station of a maritime authority, such as the Coast Guard in the USA, will have the ability to look up the registrant associated with the MMSI. In KMEV's case, they should find his name and some contact information. The contact information will permit the maritime authority to reach KMEV via telephone, which they very likely will attempt to do. If they make a telephone call to the contact number or contact person listed in the MMSI data on file for KMEV, they might reach someone who will know that KMEV is out on a boat, perhaps not his own boat, and in this way the legitimacy of the distress alert will be verified. If they cannot reach anyone, I don't know what policy will be followed, but, in general, I think the Coast Guard will act in a manner that assumes the DSC distress alert was legitimate, rather than to ignore it.

The only discrepancy that may occur as a result of KMEV using a hand-held radio whose MMSI is the same as his own boat when he is actually on someone else's boat, is there may be some descriptive information in the registry for the radio's MMSI that describes KMEV's boat which is not likely to match the boat he happens to be on at that moment.

Another boat that gets the distress alert will know nothing about a vessel description. They won't know anything about contact information. Another boat should render assistance, if they can, according to the federal regulations, the tradition of the mariner, and moral obligation.

Another consideration about a DSC distress alert from a hand-held radio: the range of reception is going to be limited. The transmission may be received at a distant shore station, as long as the transmission originated within about 20-miles of shore. If farther offshore, there is a reasonable chance the hand-held radio will be out of range of shore stations. This suggests that another boat will be the most likely recipient of the distress alert transmission. If KMEV is out fishing, perhaps another boat similarly engaged in recreational fishing might receive the distress alert.

If the hand-held radio is a modern radio, it should have its own GNSS receiver, and, accordingly, it should be able to transmit the location at which the distress alert has been sent. This information is not dependent on being on the correct boat; the radio will send its present position. The MMSI registration has no effect on this data. The position of the distress alert is probably the most important data in the process of getting out information about your distress situation.

jimh posted 05-29-2015 09:44 PM ET (US)     Profile for jimh  Send Email to jimh     
As corollary topic, in the USA the obligation to render assistance to a vessel or person in distress at sea was analyzed by a scholarly paper in 1971, which concluded:

quote:
The master or person in charge of a vessel has an excellent chance never to be held accountable by an American court for failure to render assistance. The relative mildness of the penalties and the fact there are no prosecutions recorded to date imply the duty can be discreetly overlooked when upon the high seas or in territorial waters.

From:
THE DUTY TO RENDER ASSISTANCE AT SEA:
IS IT EFFECTIVE OR ADRIFT?

http://scholarlycommons.law.cwsl.edu/cgi/viewcontent.cgi?article=1019& context=cwilj

Hoosier posted 05-30-2015 09:52 AM ET (US)     Profile for Hoosier  Send Email to Hoosier     
The key phrase is:

"so far as the master or individual in charge can do so without serious danger to the master’s or individual’s vessel or individuals on board."

That's pretty subjective and almost unenforceable. Some people will risk life and limb to render assistance and others will back off and video with their cell phones.

jimh posted 05-30-2015 10:28 AM ET (US)     Profile for jimh  Send Email to jimh     
KMEV wrote:

quote:
I gave the portable radio the same MMSI as my personally-owned boat...[It is] probably not legal...

I don't see any conflict in what KMEV has done. It seems to be compliant with the recommendation:

quote:
In the interim, VHF handhelds used in the United States should use the MMSI assigned to the ship to which the handheld is primarily associated, even if another radio on that ship uses the same MMSI.

The notion that a hand-held radio could use a different MMSI is only a suggestion:

quote:
Non-commercial users of VHF handhelds not primarily associated with any single ship may use an MMSI provided by an organization such as BOAT US, SEA TOW and U.S. Power Squadron....

On that basis, I believe there is nothing about what KMEV has done that could be considered illegal.

Hoosier posted 05-30-2015 11:43 AM ET (US)     Profile for Hoosier  Send Email to Hoosier     
The sensible solution would be for portable units to be allowed to load multiple MMSIs so the user could select the one to match the boat he/she was on.
jimh posted 05-31-2015 08:58 AM ET (US)     Profile for jimh  Send Email to jimh     
The suggestion by HOOSIER (David) that users of digital selective calling (DSC) radios ought to be permitted to modify the maritime mobile service identity (MMSI) as they like conflicts with the basic requirements for DSC radios as recommended in ITU-R Recommendation M/493-13. Here is an excerpt:

quote:
12.4 MMSI

DSC equipment should not transmit any DSC call until own ship’s MMSI allocated to the ship by the relevant administration has been configured and stored in the DSC equipment. Once stored, it should not be possible for the user to change the MMSI without advice from the manufacturer.


kmev posted 05-31-2015 10:03 AM ET (US)     Profile for kmev  Send Email to kmev     
I use a Nautilus Lifeline radio, which has a built in GPS. I carry it in case of a fall overboard in which I cannot get back aboard the boat. I am usually solo in cold water, and wanted a waterproof radio with GPS and DSC for obvious reasons.

If I remain in the boat I have multiple methods of communication, including cell phone and both console mounted and handheld radios. I also considered a Personal Locator Beacon, but decided on the DSC radio for the ability to communicate via VHF.

It is my understanding that a DSC distress call can be made without an MMSI having been entered in a radio. This obviously will not transmit any identifying information, but will transmit location if connected to a GPS. Of course, if there is no MMSI attached to a distress call, the Coast Guard is more like to transmit a VHF call informing mariners to be on the lookout rather than responding to it themselves.

Hoosier posted 05-31-2015 10:59 AM ET (US)     Profile for Hoosier  Send Email to Hoosier     
My comment was in relation to PORTABLE DSC radios. I don't think they existed when the reg. was written. Has anyone tried to get this?

" Once stored, it should not be possible for the user to change the MMSI without advice from the manufacturer."

jimh posted 05-31-2015 01:36 PM ET (US)     Profile for jimh  Send Email to jimh     
The recommendations of the ITU include numerous mentions of hand-held devices, so I disagree with the representation that the ITU was not cognizant of them when the recommendations were drafted. The recommendations have been through 13 revisions, so even if hand-held devices were not initially considered, they certainly seem to have been considered in revision-13.
jimh posted 05-31-2015 01:39 PM ET (US)     Profile for jimh  Send Email to jimh     
KMEV reveals his understanding:

quote:
It is my understanding that a DSC distress call can be made without an MMSI having been entered in a radio.

There may be some DSC radios that have been made, imported, sold, or in use in the USA for which your understanding is correct, but, as I mentioned earlier and referenced with an excerpt from the present recommendations, your understanding is NOT supported in the current recommendation of the ITU for the behavior of a DSC device. Because the FCC has now prohibited the manufacture, importation, and sale of portable DSC radios that do not comply with the recommendation, the ability to find a radio that can transmit a DSC DISTRESS ALERT message without having first been configured with an MMSI will be limited to older models.

jimh posted 05-31-2015 01:48 PM ET (US)     Profile for jimh  Send Email to jimh     
The basis for the recommendation that a DSC radio should not transmit any DSC messages unless configured with an MMSI may have been a reaction to or a development from or can be understood better by considering the report a few years ago (2011) in a letter to NMEA from a Coast Guard Admiral in which an astonishingly high percentage (six out of ten) of DSC DISTRESS ALERT messages received were said to lack a registered MMSI. This behavior rendered an important feature of the DSC radio technology useless, as a fundamental aspect of a DSC radio is to have its own identity. You cannot make a selective call to a radio unless that radio has an identity. The notion of selective calling is fundamental to DSC technology. The behavior of DSC radios now is to not provide any DSC features unless an identity has been entered into the radio.
Hoosier posted 05-31-2015 07:46 PM ET (US)     Profile for Hoosier  Send Email to Hoosier     
This raises an interesting question, if I can make a 911 call at anytime with my cell phone, whether I'm a current subscriber to a service or not, how come I can't make the maritime equivalent of a 911 call without going through a bunch of hurdles designed to impede my making that emergency call?
jimh posted 06-04-2015 01:30 PM ET (US)     Profile for jimh  Send Email to jimh     
You can always make a voice call on Channel 16 to announce a distress situation. It is not mandatory to equip your boat with any sort of radio, nor is it necessary to choose a digital selective calling radio. If you do choose to voluntarily equip your boat with a radio, and if you choose a digital selective calling radio, then, with the present-day regulations, you will need to get a qualified DSC radio. That radio should not operate with DSC features unless it has an MMSI.
jimh posted 06-04-2015 02:40 PM ET (US)     Profile for jimh  Send Email to jimh     
The comparison of the global maritime safety of life at sea (SOLAS) radio communication system with common-carrier cellular telephone systems needs to examined more closely.

In common-carrier cellular telephone systems, the system operator is under a great deal of restraint and must meet many technical regulations in order to be permitted to operate the radios using the radio spectrum.

In recreational boats voluntarily equipped with a DSC radio, that radio must interoperate with all the other DSC radios on the globe, and it does not seem unreasonable to require that boater get a radio radio that conform to certain specifications. As the FCC noted (cited in my earlier posting), compliance with these specifications is justified as follows:

quote:
Compliance with these new international technical standards ensure DSC-equipped radios will incorporate many new safety features and functions, including eliminating dangers associated with automatic channel switching addressed in Coast Guard Safety Alert 02-10 of April 13, 2010. New features also include provisions for making test calls, dual receiver functionality to improve operation, and Global Positioning System (GPS) interconnection alarms designed to ensure that distress alerts include a valid and accurate position. The new requirements ensure improved detection of distress alerts, a reduction in the rate of false alarms, and reduced incessant alarming caused by DSC-equipped radios meeting the older standard.

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