Proposed revisions of Maritime and Personal Radio rules would increase effectiveness of emergency location beacons.

Most people know that the FCC is taking steps to improve the ability of the 911 telephone system to identify a caller’s location automatically. But think about how much more complicated it is to pinpoint the location of a person in distress at sea or in the desert or on a mountain top, where there are no street addresses or buildings to help guide rescuers to the victim.

The FCC has authorized a surprisingly large number of devices to assist search and rescue efforts in finding you in uninhabited areas (assuming that you’re smart enough to carry such a device). And in a recent Notice of Proposed Rulemaking (NPRM), the Commission has proposed a number of changes in Parts 80 (Maritime Services) and 95 (Personal Radio Services) of its Rules, which include provisions covering search-and-rescue devices.

Like Heinz’s 57 products, the devices come in an impressive array, each with its own particular features and its own particular alphabet soup acronym.

For example, EPIRB. That’s the acronym for Emergency Position Indicating Radio Beacon. EPIRBs are carried on ships and transmit an alert signal that can be detected by search and rescue systems. They are compulsory on commercial vessels. EIPRBs operate on 406 MHz, which is monitored by the National Oceanic and Atmospheric Administration’s SARSAT satellite tracking system. (EPIRBs used to operate on 121.5 and 243 MHz, but use of those frequencies was phased out starting in 2002 and absolutely prohibited as of December 31, 2006. However, as a result of an oversight, the Commission’s rules have not included that specific prohibition since 2010. The NPRM proposes to correct that.)

The latest EPIRB enhancement is the addition of a GPS component which directly transmits accurate location information. Previously, EPIRBs provided less precise positioning information based on Doppler Shift analysis detected when the signal is received.

The Coast Guard recommends use of GPS-enhanced EPIRBs, and the National Transportation Safety Board has suggested that the FCC make such use mandatory for all commercial vessels required to carry EPIRBs. Putting the icing on the cake, the Radio Technical Commission for Maritime Service (RTCM) has adopted a new standard which includes the capability to broadcast position data when an EPIRB is activated. With all of that prodding, the FCC is now proposing to incorporate the RTCM standard into its rules. It asks for comments on the appropriate timetable for phasing out non-GPS EPIRBs.

Next we have PLBs, or Personal Locator Beacons. These also transmit a distress signal on 406 MHz, but they may be carried on land by members of the general public. They’re more effective than cellphones, since their signal reaches a satellite from remote areas where there is no cell service. The FCC’s rules for PLBs (in Part 95) incorporate the RTCM’s technical standard, but the FCC’s version hasn’t been updated to track changes adopted by the RTCM in 2012. Again, the FCC proposes to revise its rules to incorporate the updated RTCM standard (which includes new test procedures and operational scenarios for some PLBs).

The RTCM also recommended that language in Section 95.1401, which limits PLB transmissions to “transmission[s] of distress and safety communications,” be revised to refer instead to “transmission[s] of distress and safety of life communications.” The difference there is that mere “safety communications” involve the safety of life or property. The FCC has not proposed to make that change, but does solicit comments about it.

And then we have SENDs, or Satellite Emergency Notification Devices. These are small transmitters that can be carried by individuals in remote areas. They typically operate as subscription services and alert a satellite system, which sends a web-based report to the operator of the service, which in turn dispatches rescue personnel. They rely on a different satellite system than PLBs and, consequently, they don’t operate on 406 MHz. SENDs currently fall under the Mobile Satellite Service (MSS) rules rather than the Part 95 Personal Radio rules.

RTCM has developed technical standards for SENDs devices which it suggests be incorporated in Part 95. While the FCC invites comments on that suggestion, the Commission makes clear that that it believes RTCM’s proposed revision to be unnecessary. In the FCC’s view, manufacturers and MSS providers are free, without FCC compulsion, to adopt the RTCM standards if they wish to.

Next up, MSLDs. Those would be Maritime Survivor Locating Devices, normally worn by persons at risk of falling into the water – mariners, dock workers, divers who surface out of sight of their boat, etc. They may be attached to a life jacket. They’re used when the person with the MSLD is likely to be located in a relatively small area (like near the boat he or she fell off of).

RTCM has proposed adoption of its new MSLD technical standard and licensing “by rule” of these devices under either Part 95 of the Rules, like Citizens Band radio, or Part 80, which governs other marine devices.   (When devices are licensed “by rule,” users are deemed to be licensees for purposes of being subject to FCC jurisdiction, but they don’t have to file applications and don’t receive licenses in their individual names.) The FCC is inclined to include the RTCM standards in its rules, but is looking for input on several other related regulatory questions

We’re not finished yet. 

AIS-SARTs, a/k/a Automatic Identification System Search and Rescue Transmitters, are carried on ships and survival craft. SARTS send out distress alerts by actively reflecting 9.2-9.5 GHz band radar signals. If they detect incoming radar – likely to be in use on a craft which could effect a rescue – they transmit back a signal which shows up on the radar screen of the radar operator (yup, this is one way to “get on someone’s radar screen”). AIS is a VHF maritime navigation safety system that transmits information about the identity, type, position, and navigational status of a ship to shore stations, other ships and aircraft equipped to monitor and track ships. 

When a distress signal comes in from any type of alert system, it can be relayed to AIS-equipped vessels, one or more of which may be near the distress location and able to effect a rescue. Not all AIS-SARTs meet SART technical standards, and the FCC has issued rule waivers to allow them to operate. It now proposes to incorporate standards from the International Maritime Organization and International Electrotechnical Commission into its rules to establish minimum standards for AIS-SARTs.

Let’s wrap up the alphabet soup with VDSMS, or VHF Digital Small Message Services. The basic proposal here is to bring VHF marine radio into the 21st century by allowing a variety of text messaging pursuant to yet another RTCM standard. VDSMS would be permitted only when a channel is not being used for voice and might be barred altogether from channels which are co-channel or adjacent to safety and security frequencies.

On a somewhat tangential front, the FCC asks whether it should allow portable VHF marine radios to be carried by ship personnel while on shore. Apparently, it’s fairly common practice for ship’s crews to keep their marine radios on their belts when going ashore on business (or perhaps for a pint of grog). The FCC doesn’t like the idea, noting that cellphones work just fine on shore. Still, the Commission will entertain comments if anyone can explain why using marine radios on shore would satisfy some unmet need.

Finally, the FCC proposes to make marine radio licenses assignable, like most other kinds of licenses. Under the current rules, if a vessel is sold, the old owner is supposed to cancel its license, and the new owner applies for its own license. There is no mutual exclusivity for these licenses, and applications may be filed at any time, so getting a new license is normally pretty easy. Nevertheless, the existing system has resulted in the need for special temporary authority when a ship sale closes and the buyer’s license has not yet been issued. The FCC previously amended analogous rules governing the assignment of aircraft licenses, and the Commission is inclined to treat those aloft and those afloat the same.

If you can remember all the acronyms and have something to say about the FCC’s proposals, you can file comments by going to this FCC site and uploading your comments in Proceeding Number 14-36. Deadlines for comments and reply have not yet been set. Check back here for updates.