See website Vvpirb.com for some ideas.

Some very interesting stuff in here, as usual.

Rgds
Glenn





NATIONAL GMDSS IMPLEMENTATION TASK FORCE

Newsletter and Summary Record of 5 August 2010 Meeting

     The Summary Record. This summary record is provided for information and will be posted on the Task Force portion of the Coast Guard web site Note the new address: www.navcen.uscg.gov/?pageName=MaritimeTelecomms (click GMDSS, then GMDSS Task Force). The summary record is also distributed to all Task Force members to serve as a Newsletter summarizing GMDSS developments and other issues in marine telecommunications. The GMDSS Task Force met on 5 August 2010 at the RTCM Headquarters in Arlington, Virginia. The documents listed below were distributed and are available on request:

      BoatUS News Release of June 2009 offering Free DSC-VHF Radio Checks
      BOATUS News Release on Rescue Alerted by Rental EPIRB
    Draft Coast Guard Notice on Technical Standards for Marine DSC Radios
    Coast Guard Recreational Boating Statistics for 2009 Noting Rise in Deaths
    DOS News Release on U.S./European Union Collaboration on GNSS Receivers
   
1.   Summary Record of 20 May 2010 Meeting: The Summary Record of the 20 May 2010 meeting which had been distributed earlier was noted without change.

2.   The Coast Guard Reports:

   a. Welcome RDML Robert Day, Chief of Coast Guard Telecommunications. Admiral Robert Day was introduced to the members and made extensive remarks summarized as follows:

      1.) The admiral noted the newly displayed award presented by the Coast Guard to RTCM during the recent Annual Assembly. RTCM President Bob Markle; in response, presented a plaque commemorating the Coast Guard’s status as a founding member of the RTCM. A similar plaque was presented to Ghassan Khalek of the FCC commemorating the Commission’s status as founding member. Admiral Day was also very complimentary regarding the work of the RTCM and the GMDSS Task Force.

      2.)  Admiral Day commented on the changing nature of Coast Guard missions, in particular the massive response to the Gulf of Mexico oil spill. The Automatic Identification System (AIS) was particularly helpful in tracking the hundreds of vessels engaged in skimming including hastily retrofitted shrimp boats. The enormous number of public and private players resulted in significant communications congestion.

      3.) The admiral also noted the enthusiastic industry response to the Coast Guard’s Industry Day with 350 people attending and another 150 participating remotely, the video can be viewed on the TISCOM website. On the other hand, he noted the new budgetary realities facing the Coast Guard and their likely regressive impact on recapitalization of major assets.

   b. Search and Rescue Issues. Captain Dave McBride introduced his new Deputy, CDR Max Moser and LCDR Mark Turner who recently relieved LCDR Kathy Niles. Dave Edwards reported on the status of the AMVER Program with the following highlights:

      1.) There are about 650 U.S. flag vessels being tracked under the Long Range Identification and Tracking (LRIT) program, and since U.S. vessels are required to participate in AMVER, their data is entered automatically into the AMVER database. There are other countries such as Norway which also require their vessels to participate in AMVER, and it could probably be arranged that their LRIT data also be automatically be forwarded to the AMVER database

      2.) Voluntary participation in AMVER is growing with some 19,000 vessels registered to participate despite the introduction of IMO’s mandatory LRIT program. Although LRIT data is available for Search and Rescue, it is a relatively new development and RCCs tend to go to AMVER as first choice or out of habit.

      3.) RCCs typically release an Urgent Marine Safety Broadcast requesting assistance from vessels in the vicinity of a distress but it has been noted that few vessels volunteer, possibly because they may not know whether other vessels are closer. On the other hand, when requested directly by an RCC which has determined that they are in the best position to assist, vessels invariably accept the request and divert to the position of the distress.

   c. Development E-Navigation and AIS/ECDIS Regulations. Jorge Arroyo reported for the Office of Waterways Management with the following highlights:

      1.) The ITU-R meeting agreed to 4 significant revisions to the AIS technical standard (ITU-R M1371-3 now -4) that address AIS SARTS and facilitate the reception of AIS via satellite by the transmission of a new message #27 designed for long range position reports and use on channels other than AIS1 or 2.

      2.) The 2nd edition of the AIS test standard (IEC 61993-2) is in final clearance and should hopefully be approved by years’ end, This edition corrects many of the deficiencies and nuances encountered with the 1st generation AIS units.

       3.) IMO’s Maritime Safety Committee adopted an amendment to SOLAS Chapter V, Regulation 18 imposing an annual AIS inspection requirement, we anticipate its ratification at the next IMO assembly meeting and to come into effect in 2012.

      4.) There were no new developments in the continuing rulemaking process regarding carriage of Electronic Chart Display Systems (ECDIS) to report at this time. This is primarily due to the fact that the standards for the display feature have not been completed. RTCM has completed work on a ECS standard that defines 3 different classes of ECS, however, does not fully address the portrayal of AIS; additional work on this is anticipated.

      5.) Subsequent to the meeting, the Coast Guard’s Navigation Center issued an alert reminding vessels with AIS to confirm that their unit is operating on the proper channel. The standard default frequency is 161.975 MHz (AIS1 or channel 87B). The alternate frequency is 162.025 MHz (AIS2 or channel 88B). The owners manual should enable verification that your unit is set to the proper channel.

   d. Status of Fishing Vessel Safety Rule Making. Jack Kemerer reported with the following highlights:

      1.) The Coast Guard’s last change to Fishing Vessel Safety Regulations was in 1991. By 2003 various pressures including NTSB recommendations and reviews of casualty data prompted a new round of proposed Rule Making to address various deficiencies identified. Among the target issues selected were vessel stability, immersions suits, life rafts, and crew training. Since 2003 two public hearings have been held and the next draft of the proposed regulations is currently under review by the Department of Homeland Security with review by the Office of Management and Budget (OMB) to follow.

      2.) Although Radio Safety features were not a specific target of the proposed rule making, the GMDSS Task Force filed comments on 11 December 2008 strongly advocating the updating of radio safety provisions for Fishing Vessels and their survival craft. These recommendations were subsequently endorsed by the Coast Guard’s
National Fishing Vessel Safety Advisory Committee. The Task Force recommendations can be viewed on our website.

      3.) The U.S. fishing vessel population includes about 20,000 federally documented vessels and about 50,000 state registered vessels. The International Maritime Organization (IMO) has a proposed Fishing Vessel Convention which was adopted by a Conference in Torremolinos but which has yet to come into force. In the interim, IMO has published a series of recommended Standards for fishing vessels or various classes but these have not been adopted as mandatory for U.S fishing vessels. Should the Torremolinas Convention even come into force, the Coast Guard would need further legislative authority to enforce the provisions.

      4.) The Coast Guard Authorization Bill now in Conference has provisions which would affect fishing vessels such as changes in the Boundary Line, requirements for survival craft rather than floats, additional crew training, and mandatory safety examinations twice in five years. 

      5.) In response to a question as to whether commercial fishing was getting any safer, Mr. Kemerer noted that in a typical year 60 fishing vessels are lost with about 40 fatalities. So far this year 25 vessels have been lost with 15 fatalities. More and more, the regional Fishing Management Councils have opted for a season based on an allowable total tonnage of catch rather than a limited window of opportunity which can be risky for fishing vessels if they are obliged to fish in tight window and bad weather develops.

      6.) In response to an observation that fishing vessels are resisting requirements that they be required to carry both AIS required by the Coast Guard and Vessel Monitoring Systems (VMS) required by the National Marine Fisheries Service (NMFS), it was noted that there are now dual boxes available which can perform both AIS and VMS functions, we will try to provide more information on this dual capability a the next meeting. In the past, the Task Force has opposed the VMS standards as inadequate to meet the Coast Guard’s minimum safety requirements; future standards for VMS need to be worked out jointly by the Coast Guard and the NMFS.

   e. Status Report on Rescue 21 VHF–DSC for Sea Area A1. Gene Lockhart provided an update for the Rescue 21 Program. The following are highlights:

      1.) Rescue 21 is daily making a difference in Search and Rescue response participating in some 19,000 cases. The system availability has been excellent, even in the Gulf of Mexico during the response to the oil spill. One of the best features of the new Rescue 21 upgrade is the highly accurate direction finding capability which is proving to be a big assist in locating distress calls from vessels without DSC and from DSC capable vessels without a connected navigation receiver. The D/F has also enabled prompt resolution of several hoax calls. 

      2.) The east and Gulf coasts are largely completed except for some gaps in the Cape Hatteras which is getting a new 525 foot tower and the Corpus Christi Sector which need to be filled.

      3.). The west coast is also filling in nicely but there are gaps to be filled in on such environmentally sensitive areas as San Clemente Island, Big Sur. And Lake Tahoe where planners are working on their 20th proposed tower location. Hawaii is also proving to be environmentally sensitive as Rescue 21 has to compete with cell phone operators and other government agencies for space on existing towers.

      4.) The Great Lakes timeline is the end of FY2012 and needs 18 new towers for completion. Plans for the Rescue 21 sites in Alaska and the Western Rivers are proceeding but at risk due to budgetary uncertainties and the need for tall towers to get above the tree canopy.

      5.) There is still a feeling that take up of DSC by recreational vessels has been slow, even by users who have a DSC capable radio. We need better publicity of the benefits to activating DSC and continued help from the Coast Guard Auxiliary and the U.S. Power Squadrons in their boating courses and safety inspections.

   f. Status of MF-DSC Coastal Network Upgrade to DSC for Sea Area A2. Joe Hersey reported as follows:

      1.) Joe provided an update on MF Voice planning with an acknowledgement that the study results had validated retention of MF coastal operations. There may be limited funding available to ‘shore up’ a few weak spots but the longer term upgrades will likely be further constrained by new budget realities. Even though the Coast Guard will maintain current MF-DSC capability and the watch on 2182 kHz and enhance both where possible, there are no current plans to declare Sea Area A2 operational. The Coast Guard does not plan to equip small cutters for MF operations but will retain the capability on cruising cutters.

      2.) On a related issue, Joe reminded the group that the FCC Rules provide for a phase out of the special VHF-DSC rules known as the RTCM SC 101 standard. It is a reduced capability radio authorized to facilitate introduction of DSC but is being withdrawn now that prices of the more capable international standard radios have been coming down. The FCC Order issued in August 2006 prohibits manufacturer, import and sale of fixed mount VHF-DSC radios in the U.S. which do not conform to the International Electrotechnical Commission (IEC)  62238 standard after 25 March 2011. Continued use of existing SC 101 fixed mount radios is grandfathered and continued sale of SC 101 portables is permitted until 25 March 2015

      3.) Joe also reminded the group of the Coast Guard’s earlier Safety Alert warning mariners that the receipt of alerts on channel 70 would automatically shift the VHF radio to channel 16 and that that feature should be disabled when in a situation where to watch needs to be maintained on the bridge-to-bridge channel or a VTS sector channel. Use of the more capable Class D radios should minimize this automatic channel switching problem, enable automatic test calls, and provide GNSS interconnection alarms. Use of these higher performing radios should also improve detection of distress alerts, reduce the false alarm rate, and reduce the incessant alarming attributed to the inferior radios. . The GMDSS Task Force has long advocated use of the international Class D standard in preference to the less capable SC 101 standard.
 
   g. Working Group Preparations for IMO Meetings. Russ Levin reported on the upcoming IMO/ITU Panel of Experts meeting planned for September 2010 and the Comsar 15 meeting in London March 2011 as follows:

      1). Documents are due early September for the Joint experts meeting. The agenda includes GMDSS Modernization and a proposed U.S. input paper will present the conclusions of the GMDSS Modernization Workshop at the RTCM Assembly on 20 May 2010. The Workshop Conclusions document is posted on the Task Force website.

      2). The Comsar 15 meeting in London March 7-11 2011 will also treat GMDSS Modernization along with the usual Communications and Search and Rescue agenda items. The U.S. SOLAS Working Group has scheduled 3 preparatory meeting at the RTCM Headquarters on 17 November 2010, 15 December 2010, and 16 February 2011. A separate Working Group has been authorized for the GMDSS Modernization issue at the March 2011 meeting in London.

      3). Bob Markle noted that a new IMO Safety of Navigation standard for watch alarms on SOLAS vessels comes into effect at the end of 2011, The new requirements for Bridge Navigational Watch Alarm Systems (BNWAS) on SOLAS ships comes into effect starting 1 July 2011, with a retrofit schedule that goes through 1 July 2014.

   h. GMDSS Modernization. RADM Gilbert (Ret.) noted the previous comments on GMDSS Modernization and consideration at two upcoming meetings. He reminded the group that the ITU Conference in 2012 sets the agenda for consideration by the ITU Conference in 2016 and its important that E-Navigation and GMDSS Modernization issues be approved for consideration in 2016. He also reported on the recent Conference of the International Maritime Satellite Organization (IMSO) which provides government supervision of maritime satellite systems providing safety services under the GMDSS. The Thuraya satellite system has announced its intent to apply for regional status as a GMDSS provider in areas where they can meet the requirements for 99.9% reliability and service restoration within one hour of an outage.

3.   The FCC Reports: Ghassan Khalek reported for the FCC, the following are highlights of his report:

   a. Further Part 80 Rule Making. Further Part 80 Rule Making.  A new FCC Report and Order was released in June, The rules have not yet been published in the Federal Register, and until they are, no effective date is established.  The rules do the following:

- Prohibit the certification, manufacture, importation, sale, installation, or continued use of INMARSAT-E emergency position indicating radiobeacons (EPIRBs). 

- Conclude that VHF-DSC handheld radiotelephones should include integrated Global Positioning System (GPS) capability, but defer adopting such a requirement until RTCM completes work on GPS performance standards for handheld radios

- Require that any small passenger vessel that does not have a reserve power supply carry at least one VHF handheld marine radio transceiver

- Decline at this time to provide additional spectrum for ship station facsimile communications or to permit the transmission of data on maritime voice channels.  Footnote 46 indicates that the commission will consider RTCM's petition to permit VHF-FM Digital Small Message Services in accordance with RTCM 12301.1 in a separate proceeding .

- Eliminate the limits on the number of frequencies that can be assigned to a private coast station or marine utility station.

- Revise the Part 80 rules to incorporate by reference the latest IEC standards for radar and other equipment. Note that this revision removes the RTCM radar standards from FCC regulations.  (The RTCM radar standards remain for now in U.S. Coast Guard regulations affecting towing vessels.)

- Clarify that vessels subject to Global Maritime Distress and Safety System (GMDSS) requirements are required to test their radiotelephone equipment on a daily basis. 
The meeting was also reminded that the FCC has published rules that phase out SC-101 radios.  (see Para 2.f.2.) above)


   b. Task Force Petition to Authorize Use of Marine Handheld Radios ashore in Maritime Areas. In June 2009, the FCC published the Task Force Petition requesting authority to use VHF handheld radios ashore in maritime areas allowing 30 days for comment. The public comment period ended with no responses either pro or con. This item was not included in the new Part 80 Rulemaking but will be part of a new Rulemaking to include additionally the following two items.

   c. RTCM Petition to Authorize Small Message Data Services on VHF Frequencies. The RTCM petitioned the FCC to accept its recommendations for a small message service on VHF frequencies using data techniques. The Petition was published by the FCC and Public Comment closed 15 October 2009. There were 28 comments, all favorable. This item was also not included in the new Part 80 rulemaking (para 3.a.) but will be part of the new Rulemaking mentioned in b. above.

   d. FCC Response to the NTSB Recommendation that FCC (and USCG) Require GPIRBs on Vessels Currently Required to Carry EPIRBs. The National Transportation Safety Board recently recommended that the FCC require GPS enhanced EPIRBs commonly known as GPIRBs on vessels required by regulation to carry EPIRBs. This recommendation also applies to the Coast Guard for vessels which they regulate. The recommendation was made since early alerting in Distress cases gives survivors a better chance of being rescued and GPIRBs provide a location immediately on reception without waiting for position to be determined by doppler techniques. The FCC plans to include this issue in the next Rulemaking along with items b and c above.
 
   e. Task Force Petition Urging Improved MMSI Management. The FCC denied the Task Force petition earlier but now hopes to implement many of the Task Force recommendations by creating a new database rather than as part of an upgrade of the Universal Licensing System (ULS) as reported earlier. No date was suggested for the new database. The FCC also reported that an additional block of MMSI numbers had been issued to Sea Tow and that new FCC MMSI assignments were not being received by the Coast Guard regularly for incorporation in the MISLE database.

   f. FCC Decision of the Riverside, California Petition to Use Marine VHF Channels for Land Mobile Applications. The FCC has still not announced a decision in this case.

   g. Interpretation of FCC Rule Requiring VHF Radio on Vessels Carrying EPIRBs. It has been noted that the FCC Rules require that vessels carrying EPIRBs also have VHF Radio (Personal Locater Beacons (PLB) are not affected). It was unclear what impact this Rule has on the Hawaiian Law requiring vessels going a mile offshore to carry VHF radio or an EPIRB. Similarly it is not clear whether the rule applies to the BOATUS Rental EPIRB program or to Personal Locater Beacons (PLB), Further information will be sought for the next meeting.

   h. New Issue Regarding Certification of Qualified U.S. GMDSS Inspectors to IMO for Information of Foreign Port State Inspectors. A new issue was raised in that some U.S. vessels undergoing Port State Inspections in a foreign country have encountered difficulty because the U.S. does not furnish the IMO with a list of qualified GMDSS inspectors as required by the IMO. This is complicated by the fact that the FCC does not conduct the U.S. inspections by government inspectors but delegates the function to any or the 2499 holders of the GMDSS Maintainers License. Many of the U.S. flag inspections are done by qualified representatives of the Classification Societies. This issue will be revisited at the next meeting

5.   The RTCM Report: RTCM President Bob Markle reported on the status of Special Committees of interest to the Task Force are as follows:

a. RTCM SC 101/110 on Incorporating GPS in VHF Handhelds. The combined Special Committee continues to work on recommended specifications for a VHF DSC handheld with integral GPS and the continuing work of SC 110 on EPIRB specifications. Their next meetings were held 18-20 August.

b. RTCM SC-119 on Maritime Survivor Locating Devices. This Committee is being reactivated in order to consider man overboard strobe lights and AIS applications.

c. RTCM SC-121 on Automatic Identification Systems (AIS). This Committee continues work on AIS messaging and has a Working Group addressing AIS applications in port areas. The Committee met again on17 August.

d. RTCM SC-123 on Data over VHF Channels. As reported earlier, RTCM has petitioned the FCC to adopt RTCM Standard 12301.1 for transmitting data on VHF channels. The comment period closed with all comments favorable to the proposal. Early approval action by the FCC was expected but is still pending. The Committee is expanding its work to include data messaging on MF and HF channels. The Committee met again on 19 August.

e. RTCM SC-127 on Enhanced Loran.  This Committee continues to meet and work on specifications for a combined Loran/GPS receiver despite the recent termination of Loran service in the U.S. The U.K. organization Trinity House has taken the lead in advocating Enhanced Loran

f. RTCM SC-128 on Satellite Emergency Notification Devices. This Committee was chartered at the request of the Coast Guard to develop performance standards for new systems such as SPOT which are being advertised for emergency or life saving applications with the goal of enhancing reliability and consumer protection. A working group of the National Search and Rescue Committee has been working with this RTCM Special Committee. The Committee met again on 17 August.

g. RTCM Invited to Take Over Work of the “ProTECTS Alliance”. The ProTECTS Alliance (Promotion of Two way Emergency Communications and Tracking Systems) is a group started by the Iridium Satellite Corp. to promote the responsible use of satellite technology for emergency services. The Alliance has recently invited RTCM to take over sponsorship of the Group. The RTCM Board of Directors approved the proposal at its meeting on 19 August.

h. Other RTCM Announcements of Interest. The 2011 RTCM Assembly including a Task Force meeting will be held at the Tradewinds Hotel in St. Pete Beach, Florida May 15-20, 2011.

6.   Reports and Issues: The Recreational Vessel Group Report. David Kennedy of BOATUS reported for Chairman Chuck Husick who was unable to attend. The following are highlights:

   a. BOATUS News Release of June 2009 Offering Free VHF-DSC Radio Checks. BOATUS has established a special MMSI Number, 0-338-04000, which may be used by boaters in the Gulf of Mexico and along the Atlantic Coast from Alabama to New Jersey for complimentary radio checks to assure proper operation of the radio. BOATUS suggests a call by phone to your local BOATUS franchise to determine the channel the local operator uses for radio traffic so that you can place the radio check call on that channel using the universal MMSI Number, 0-338-04000.

   b. Promoting MMSI Registrations and GPS Connections. The Task Force continues to pursue a public awareness campaign seeking ways to encourage MMSI registrations, GPS connections to the DSC radio, and advocating that boats going a mile or more offshore be equipped with VHF radios or EPIRB/PLB. As noted in Para 3.e.5.) above, the Task Force is relying on increased publicity and the boating safety courses and safety inspections conducted by the Coast Guard Auxiliary and U.S. Power Squadrons to assist in educating boaters about the enhanced safety features of VHF-DSC.

    c. BOATUS News Release of July 2010 on Saving of 3 Lives by Rental EPIRB. The release reminded readers of the safety benefits of taking a rental EPIRB on vessels which do not carry one routinely. In this case a 32 foot catamaran was making an offshore passage from Crescent City, California to Alameda, California and mad a last minute decision to take a rental EPIRB. The 3 persons on board owe their lives to this decision as the EPIRB was activated minutes before the boat capsized in heavy seas. The EPIRB alert was the only notification received by the Coast Guard which rescued the 3 person crew by helicopter with the assistance of its rescue swimmer. The BOATUS Foundation’s EPIRB rental program is funded by voluntary contributions of BOATUS members and 65 lives have been saved since 1996. Vessels not normally cruising offshore can rent this valuable lifesaving appliance for $65.00 per week.
 
   d. Coast Guard Office of Boating Safety 2009 Boating Statistics. The Coast Guard reported 736 deaths, 3,358 injuries, and $36 million in property damage for 2009. The fatality rate increased from 5.6 deaths per 100,000 registered boats in 2008 to 5.8 in 2009. 86% of the fatalities occurred on boats where the operator had not taken a boating safety course. Alcohol consumption was a leading factor in 16% of the deaths. Nearly 75% of the 736 deaths were due to drowning and 84% of those were not wearing life jackets. The benefits of wearing life jackets and taking boating safety courses are apparent.

   e. Clarification Sought in Acceptability of Carrying Rules of the Road on Board via Electronic Media. Coast Guard Rules require vessels over 12 meters in length to carry on board a copy of the Rules of the Road. This has traditionally been assumed to mean a paper copy but now that computers and other electronic media are becoming commonplace, the question was raised as to whether the electronic versions satisfied the requirement. This question was posed to Joe Carro of the Office of Boating Safety who acknowledged that some boarding officers were accepting electronic versions, especially in the case of Light Lists and others which are no longer published in paper format. However, there had not yet been official guidance to field inspectors on Rules of the Road and other documents still available in paper format. He offered to follow the issue and provide clarification at a future meeting. 

7.   Reports and Issues: the GMDSS Service Agents & Manufacturers Group. Ralph Sponar’s Group is following several initiatives through an ad hoc group working with NMEA representatives as follows:

   a. Better Definition of “Qualified” Technical Support. The FCC Rules relating to Class B AIS call for installation by a qualified technician and NMEA has formed an ad hoc group to better define ‘qualified’. Recent progress indicates that the NMEA’s CMET certification will likely be accepted by the FCC as qualifying for the AIS installation and perhaps other requirements such as conducting GMDSS inspections and the newly required AIS inspections. The next step is a Petition to the FCC.

   b. Standard Color Coding for GPS/Radio hookups. The NMEA ad hoc group  recommendation for a standard color coding has been approved for inclusion in the NMEA 0183 standard. The NMEA will then recommend this revised standard to manufacturers of both GPS receivers and the various marine equipments to which the navigation receivers should be connected. The revised five page standard will also be posted on the Task Force website along with a two page discussion document on wiring and installation using the NMEA 0183 guidelines.

   c. Recommendation that GMDSS Equipment Accept USB Interface Connections. The NMEA ad hoc group will also examine this proposal but any recommended solution will have to be submitted to IMO which manages the functional requirements for GMDSS equipment. In the past there has been reluctance on the part of IMO to permit use of the computers dedicated to GMDSS equipment for any other purpose.

8.    Reports and Issues: the Commercial Vessel Group. No issues of interest to the Commercial Vessel Group were raised at the meeting but on 20 August, the National Transportation Safety Board (NTSB) announced that they planned to host a Forum on Fishing Vessel Safety on October 13-14 2010. The NTSB concern is based on the fact that in 2009, commercial fishing had the highest fatality rate of all U.S. occupations. The Task Force’s December 2008 recommendations to the Coast Guard on Fishing Vessel Safety, while not likely to prevent accidents, should help to improve the survival rate. These recommendations were passed to the NTSB for use in connection with their Forum.

9.   Reports and Issues: the GMDSS Training Group: An issue was raised that some of the questions on the Test for the GMDSS Maintainer License appeared to be out of date. After the meeting I contacted Andy Anderson who agreed that it needed work. He plans to start this in the fall with the ad hoc group that has updated the pools in the past. Anyone desiring to work with the ad hoc group should contact Andy at owen_anderson@comcast.net .

10.   Other Business and the Next Meeting of the GMDSS Task Force: The next Task Force meeting will be held at 9:30 a.m. on Wednesday morning 29 September 2010 at the Sheraton Hotel in Seattle, Washington during the NMEA Annual Meeting. The follow-on meeting will be held at the RTCM Headquarters in Arlington, Virginia on Thursday morning 6 January 2011.

   Special USA/Canada Meeting in the Seattle area on 28 September. In conjunction with the Seattle Task Force meeting on Wednesday 29 September, the Task Force will sponsor a special meeting the day before at the Farmhouse Restaurant in Mt. Vernon, Washington for the convenience of Canadian visitors. This special meeting will concentrate on issues of interest to local mariners. Task Force members are also invited to attend the special meeting.

AMERC runs the UK GMDSS Course and Centre approvals on behalf of the Maritime and Coastguard Agency (MCA).  AMERC also runs the examination system for GOC, ROC and LRC.  The Newsletter is publised 3-4 times each year and includes, amongst other things, problems that may be common to other administrations.  You can find the newsletter at www.amerc.ac.uk - click on 'Newsletter' ... as the new Editor (for the next 3 years) I welcome any feedback and/or contributions.  I'll send a general message when each new newsletter is published on the website.
Brs
Ian W
www.gmdss4all.net

A short video showing DSC traffic being received off air at a Coast Station:

http://www.youtube.com/watch?v=mqAwZRulbZQ

Ships are still making mistakes with DSC.

We have a coast station DSC system set up here, and I often sit and watch ships making stupid mistakes.

A classic...just a minute ago - a ship sent an all stations test call....so, all coast stations in range automatically responded....

Our station here did, along with Charleville (Australia) and Taupo NZ..... 

Another interesting report of the US GMDSS Task Force


NATIONAL GMDSS IMPLEMENTATION TASK FORCE

Newsletter and Summary Record of 20 May 2010 Meeting

     The Summary Record. This summary record is provided for information and will be posted on the Task Force portion of the Coast Guard web site at www.navcen.uscg.gov/marcomms/ (click GMDSS, then GMDSS Task Force). The summary record is also distributed to all Task Force members to serve as a Newsletter summarizing GMDSS developments and other issues in marine telecommunications. The GMDSS Task Force met on 20 May 2010 in San Diego, California during the RTCM Annual Assembly. The documents listed below were distributed and are available on request:

      BoatUS Foundation News Release on Rental EPIRBs with GPS Locating
      Coast Guard Safety Alert on VHF-DSC Radio Automatic Channel Switching
      Coast Guard Policy Letter re Inspection of Uninspected Towing Vessels
      UK MAIB on Failure of SOLAS Vessels to Respond to MAYDAY RELAYS
      Coast Guard Safety Alert on AIS Text Messaging for Navigation & Emergencies
      Coast Guard News Release on Fog Horn Activation by VHF Radio
   
1.   Summary Record of 7 January 2010 Meeting: The Summary Record of the 7 January 2010 meeting which had been distributed earlier was noted without change.

2.   The Coast Guard Reports:

   a. Search and Rescue Issues Needing Task Force Support. Captain Dave McBride reported for the Office of Search and Rescue on new trends in the use of radio technology in SAR cases. An example is the RTCM work to set minimum standards for devices such as SPOT which advertise emergency alerting services. There was discussion of the pros and cons in the use of AIS Text Messaging for Distress Alerts (see the following sub paragraph) and whether it would be useful to publish the email addresses of RCCs for the convenience of the public.

   b. New Regulatory Initiatives in AIS and ECDIS. Jorge Arroyo reported for the Office of Waterways Management that the U.S. has tracked 35,000 to 40,000 unique AIS vessels to date; just under 7000 per day. There were no new developments in the continuing rulemaking process regarding carriage of Automatic Identification Systems (AIS) and Electronic Chart Display Systems (ECDIS) to report at this time.

   Jorge mentioned a forthcoming Coast Guard Safety Alert entitled “AIS Text Messaging Concerns: Usage During Navigation and Emergencies and Ensuring Accurate Data”. This alert was released 27 May and reminds operators that use of AIS text messaging does not relieve them of other requirements such as Bridge-to-Bridge Radiotelephone Regulations or the requirements to sound whistle signals and display lights in accordance with the International or Inland Navigation Rules. The Safety Alert can be viewed at http://navcen.uscg.gov/enav/ais/0510.pdf. With respect to use of AIS Text Messaging during emergencies, the Safety Alert cautions operators that Text Messages may not be received, recognized, or acted upon by in the same fashion as alerts in the GMDSS system. It is acknowledged, however, that AIS text messaging can be a useful augmentation of GMDSS.

   On May 25th, a Coast Guard San Diego News Release cited the reactivation of the Mission Bay Jetty fog signal which had been destroyed in a storm 10 years ago. The significance of this reactivated fog signal is that it is user activated by calling on VHF channel 79A and pressing the mike button 5 times. This is the second west coast installation of this type of boater activated fog signal but the technology has been used successfully throughout the Great Lakes and represents a more cost effective solution than the earlier cell phone activated fog signal which required a dedicated phone line.

   c. Status Report on Rescue 21 VHF–DSC for Sea Area A1. CDR Steve Osgood provided an update for the Rescue 21 Program. The following are highlights:

      1.) One of the best features of the new Rescue 21 upgrade is the highly accurate direction finding capability which is proving to be a big assist in locating distress calls from vessels without DSC and from DSC capable vessels without a connected navigation receiver. The D/F has also enabled prompt resolution of several hoax calls. 

      2.) The east coast is largely completed except for some gaps in the North Carolina and Corpus Christi Sectors which need to be filled.

      3.). The west coast is also filling in nicely with Sector San Diego declared operational last month. There are gaps to be filled in on San Clemente Island and the Big Sur area south of Carmel. Sector San Francisco is still outstanding as are some organizational changes in the 13th District.

      4.) One of the first rescues involving DSC occurred recently and was quickly resolved with a helicopter dispatched to the scene.

   d. Status of MF-DSC Coastal Network Upgrade to DSC for Sea Area A2. Dave Fowler provided an in depth review of his study of the Coast Guard’s reception of safety and distress calls on 2 MHz frequencies as determined from the Coast Guard database of SAR cases. Surprisingly, the study revealed more use of MF for safety communications than had been expected, especially from fishing vessels. There may be limited funding available to ‘shore up’ a few weak spots but the longer term upgrades will likely be further constrained by new budget realities. Some statistics from his report:

      1.) The study looked at reception by MF/HF Voice and DSC as well as satellite (Inmarsat and other), VHF, EPIRB, and phone. The large number of phone notifications may be partially due to the RCC controller recording manner in which he was notified and not necessarily the radio system the distressed vessel used.

      2.) Initial Notifications during the period 2003-2009 totaled 82K by phone; 61K by VHF; 19K by EPIRB; 2209 by MF/HF; and 1710 by Satellite (after discarding cases from outside U.S. SAR area and cases without lives saved or assisted).

      3.) Fishing Vessels were the predominate type of vessel which accounts for relatively few of the MF/HF cases using DSC as F/V have not yet been required to upgrade to DSC.

   e. Working Group Preparations for COMSAR 14. Russ Levin reported on the results of Comsar 14 which met in London on 8 March 2010 with the following highlights:

      1). The authorized “scoping exercise” for GMDSS Modernization received relatively little attention as it was assigned to a heavily committed working group. The final decision was to refer the issue to a 2 day meeting of IMO and ITU experts scheduled for September 2010 in London.

      2). There was discussion of the problem of retaining the priority for Inmarsat safety and distress messages in the shore to ship direction. The Intergovernmental Maritime Satellite Organization (IMSO) was requested to look into the issue and report to Comsar 15.

      3). The Conference again declined to endorse replacement of the EPIRB 121.5 MHz homer with an AIS transmitter as few of the less developed countries had aircraft capable of homing on AIS. Future plans are to reopen the proposal as an optional alternative similar to the current alternative for Radar SARTs or AIS SARTs.

      4) Comsar 14 approved a new SafetyNET Manual.

   f. Coast Guard Safety Alert on VHF-DSC Automatic Channel Switching. Joe Hersey explained that an incident off New York prompted issuance of the Safety Alert to remind operators that on receipt of a VHF-DSC distress alert, distress acknowledgement, or other DSC call where a VHF channel number has been designated, the DSC radio automatically switches to channel 16 or the other designated channel. This could result in a vessel operator thinking he was still on the Bridge-to-bridge channel 13 making passing arrangements when the radio had shifted off of channel 13. To prevent this from happening, the Coast Guard strongly recommends disabling the automatic channel switching feature when actively engaged in bridge-to-bridge or Vessel Traffic Service (VTS) communications.

   g. GMDSS Modernization. RADM Gilbert (Ret.) noted the presentations relating to modernization of the GMDSS during various sessions of the RTCM Assembly earlier in the week and invited interested parties to attend the GMDSS Modernization Workshop to be held that afternoon. The output from the Workshop will be sent to all Task Force members as a separate distribution soliciting input and comment on the conclusions reached. The resulting consensus will be recommended to governmental authorities as input for appropriate international conferences.
   
3.   The FCC Reports: Ghassan Khalek reported for the FCC, the following are highlights of his report:

   a. Further Part 80 Rule Making. New FCC Rulemaking is expected to be released soon dealing with such matters as the phase out of Inmarsat B and E, the Coast Guard Petition on several aspects of the Automatic Identification System (AIS), and several adjustments to reflect actions taken by the ITU. Hopefully, the following pending Petitions will also be resolved:

   b. Task Force Petition to Authorize Use of Marine Handheld Radios ashore in Maritime Areas. In June 2009, the FCC published the Task Force Petition requesting authority to use VHF handheld radios ashore in maritime areas allowing 30 days for comment. The public comment period has ended with no responses either pro or con.

   c. RTCM Petition to Authorize Small Message Data Services on VHF Frequencies. The RTCM has petitioned the FCC to accept its recommendations for a small message service on VHF frequencies using data techniques. The Petition was published by the FCC and Public Comment closed 15 October 2009. There were 28 comments, all favorable.
 
   d. Task Force Petition Urging Improved MMSI Management. The FCC denied the Task Force petition earlier but now hopes to implement many of the Task Force recommendations when the Universal Licensing System (ULS) is updated in the near future.

   e. Ship Station License Update. The following is a tabulation of active Ship Station Licenses:
   54,920 SA   Voluntary Vessels;   29,908 of these also hold MMSI
   20,533 SB   Compulsory Vessels,   13,977 of these also hold MMSI

4.    Update Report by Satellite Service Provider Inmarsat. Chris Wortham provided an Inmarsat update with the following highlights:

   a. Emergency Calling ‘505’ Implemented for the FleetBroadband Service. This emergency calling system has been implemented for use by all FleetBroadband (FB) terminals. The resemblance of ‘505’ to ‘SOS’ is intentional. Alerts via the ‘505’ system are routed to appropriate RCCs in each satellite ocean region and are free calls. Note that ‘505’ does not provide priority for Distress and Safety messages. Inmarsat will seek approval to qualify for GMDSS certification of the FB 500 (but probably not the FB 150 and FB 250) by 2014.

   b. Marine Safety Information (MSI) Via Fleet Broadband. Fleet Broadband will make all SafetyNET MSI available for ships which want to “pull” the information rather than copying the broadcast. There will be no change to ships for pulling the MSI information.

   c. General Inmarsat Statistics. Inmarsat operates 11 satellites and has over 500,000 terminals in service. Maritime accounts for about 55% of the revenue. Take up of the FleetBroadband service has been rapid with over 5,000 terminals already in service.

   d. Inmarsat plans to introduce a new global handheld satellite phone called ‘IsatPhone Pro’ later this year. There is no likelihood that the handheld will be certified for GMDSS.

   e. Termination of Inmarsat B Service. Inmarsat plans to terminate Inmarsat B service on 31 December 2014 in view of declining use of the service by ships.

5.   Update Report by Satellite Service Provider Thuraya. Fatima Sajwani provided an update on the Thuraya Regional Satellite System with the following highlights:

   a. General Thuraya Statistics. Thuraya is a regional satellite service covering a broad expanse of the Pacific and Indian Oceans and the continents of Europe, Africa, and Asia from 2 geostationary satellites at 44 degrees East and 98.5 degrees East longitude. There are over 250,000 subscribers who utilize Voice, Fax, and Data to 9.6 kbps. Terminals can have integral GPS and maritime coverage includes 80% of the world ports.

   b. Thuraya Plans to Request Certification for GMDSS Service. Thuraya has announced plans to apply to IM O to be certified to provide GMDSS Service. They are already able to provide Long Range Tracking and Identification (LRIT) and Ship Security and Alert Service (SSAS) services to ships within their coverage area since Thuraya meets the specified functional requirements. Their request to IMO for GMDSS certification could come as early as December of this year.

   c. Thuraya Plans to Extend Coverage to the Atlantic Ocean. Thuraya’s third generation expansion plans include establishing near global coverage (excluding polar regions) through new satellite deployments which will also provide redundancy using the existing constellation.

6.   The RTCM Report: RTCM President Bob Markle reported on the status of Special Committees of interest to the Task Force are as follows:

a. RTCM SC 101/110 on Incorporating GPS in VHF Handhelds. The combined Special Committee continues to work on recommended specifications for a VHF DSC handheld with integral GPS.

b. RTCM SC 110 on Emergency Beacons. The Committee is considering the role of new U.S. GPS satellites which carry the Distress Alerting Satellite System (DASS), an ERIPB transponder which could be configured to provide an acknowledgement back to the EPIRB that the alert has been received. While this technology enhancement could be provided, it is not currently included in the design because of lack of a clear requirement. The Galileo Navigation Satellite System will also support EPIRB alerting and is reportedly being designed with response acknowledgement capability. The U.S. needs to make a clear statement of requirement. It appears to the Task Force that the capability would be especially desirable in maintaining morale of the survivors pending rescue.

c. RTCM SC-121 on Automatic Identification Systems (AIS). A Working Group of this Committee has been working on expanded use of AIS in Port areas. The Port of Tampa is now broadcasting 3 digital messages on the AIS communications channel including the NOAA Physical Oceanographic Real Time System (PORTS) information on currents and water levels. The Corps of Engineers is also experimenting with the use of the AIS channel to broadcast similar information in the vicinity of locks.

d. RTCM SC-123 on Data over VHF Channels. As reported earlier, RTCM has petitioned the FCC to adopt RTCM Standard 12301.1 for transmitting data on VHF channels. The comment period closed with all comments favorable to the proposal. Early approval action by the FCC is expected.

e. RTCM SC-127 on Enhanced Loran.  This Committee continues to meet and work on specifications for a combined Loran/GPS receiver despite the recent termination of Loran service in the U.S.

f. RTCM SC-128 on Satellite Emergency Notification Devices. This Committee was chartered at the request of the Coast Guard to develop performance standards for new systems such as SPOT which are being advertised for emergency or life saving applications with the goal of enhancing reliability and consumer protection. A working group of the National Search and Rescue Committee is working with the RTCM Special Committee. Note that BOATUS is now offering SPOT service to its members.

g. Other RTCM Announcements of Interest. The 2011 RTCM Assembly including a Task Force meeting will be held at the Tradewinds Hotel in St. Pete Beach, Florida May 15-20, 2011.

7.   Reports and Issues: the GMDSS Service Agents & Manufacturers Group. Ralph Sponar’s Group is following several initiatives through an ad hoc group working with NMEA representatives as follows:

   a. Better Definition of “Qualified” Technical Support. The FCC Rules relating to Class B AIS call for installation by a qualified technician and NMEA has formed an ad hoc group to better define ‘qualified’. Recent progress indicates that the NMEA’s CMET certification will likely be accepted by the FCC as qualifying for the AIS installation and perhaps other requirements such as conducting GMDSS inspections.

   b. Standard Color Coding for GPS/Radio hookups. The NMEA ad hoc group has plans to recommend adoption of a standard color coding which will then be recommended to manufacturers of both GPS receivers and the various marine equipments to which the receivers should be connected.

   c. Recommendation that GMDSS Equipment Accept USB Interface Connections. The NMEA ad hoc group will also examine this proposal but any recommended solution will have to be submitted to IMO which manages the functional requirements for GMDSS equipment. In the past there has been reluctance on the part of IMO to permit use of the computers dedicated to GMDSS equipment for any other purpose.

8.   Reports and Issues: The Recreational Vessel Group Report. Jack Fuechsel reported for Chairman Chuck Husick who was unable to attend. The following are highlights:

   a. New Marine VHF Handbook from Mercator Publishing. A copy of the new Handbook was circulated to the group. The author, Laszlo Mercz has extensive ITU experience. The handbook comes with a disc enabling the user to set up a Marine VHF Radio Simulator on a computer. The cover shows a U.S. price of $33.95.

   b. Promoting MMSI Registrations and GPS Connections. The Task Force continues to pursue a public awareness campaign seeking ways to encourage MMSI registrations, GPS connections to the DSC radio, and advocating that boats going a mile or more offshore be equipped with VHF radios or EPIRB/PLB.

    c. Sea Tow Proposal for an Automated Radio Check Service. Charlie Zaloom again outlined a proposal that Sea Tow is considering for automated radio checks. If implemented, there would be a designated channel in each port area which a boater could call requesting a radio check. His transmission would then be played back to him on the same channel so that he could also evaluate his transmission for clarity etc. Charlie demonstrated the system at the meeting using two handheld low power units.

   d. San Diego Auxiliarists Exhibit VHF-DSC Demonstrator. Again in 2010 local members of the Coast Guard Auxiliary, Jim Davis and Joe Stevens, exhibited their portable VHF-DSC demonstrator which they take to boat shows and other events. Their assistance in promoting MMSI registration and connection of GPS receivers is greatly appreciated.

9.    Reports and Issues: the Commercial Vessel Group. There were several items of interest to the Commercial Vessel Group as follows:

   a. Failure of SOLAS Vessels to Respond to MAYDAY Messages. An April 2010 Notice from the UK Chief Inspector of Marine Accidents notes that in investigating the death of a seafarer they discovered evidence that some vessels within 10 miles of the incident had failed to respond to MAYDAY messages. In debriefing the ships, several claimed not to have seen the series of distress flares or not to have heard the VHF Alert. A few even claimed not to understand their legal and moral duty to respond. In such circumstances it is the duty of every “master of a ship at sea which is in a position to be able to provide assistance” to at least call the search and rescue service and respond.

   b. Coast Guard Policy Letter re Inspection of Uninspected Towing Vessels. Coast Guard Policy Letter 10-02 of 11 March 2010 was distributed for information. Despite the title, many previously uninspected towing vessels are now subject to inspection and the policy letter provides guidance to marine inspectors and describes a “bridging” program to ease to towing vessel industry into a future inspection regime.

10.   Reports and Issues: the GMDSS Training Group: No issues were raised pertaining to the Training Group.

11.   Other Business and the Next Meeting of the GMDSS Task Force: The next Task Force meeting will be held on Thursday morning 5 August 2010 at the RTCM Headquarters in Arlington, Virginia. The follow-on meeting will be held on Wednesday morning 29 September 2010 in Seattle, Washington during the NMEA Annual Meeting.

Kurt's comments on Ed's paper:

(great comments on HF, BTW...)




KA: I agree that 2 Mhz should be retained for the reasons noted in my other email  – GMDSS (and all) vessels can count on the ground wave radius of 150 NM without worrying about HF propagation.  2182 kHz is also a long used and understood contact frequency for non-GMDSS (recreational boaters etc.) craft.


KA: Excellent idea – more choices in polar coverage and Iridium is now being used for LRIT = synergy amongst systems for once. (alternative satellite providers)


KA: I think the current 4 message priorities of Distress, Urgency, Safety & Routine should be retained.  They are of long standing, are well understood by ship & shore officers and provide a vital distinction.  There is a huge reservoir of regulation and training that would have to be revised by letting the machine speed govern the issue.  Human officers can deal with distinctions.  There’s a vast difference between a Securite call about containers lost over the side and a Mayday call about a fire/explosion.  Mr. Hersey – if I am misunderstanding the single category of “Priority” comment how exactly would that play out?

KA: While it is true the MF-HF general communications world has severely diminished -- there are still many places in the world it retains its effectiveness.  Even in the U.S. WLO Mobile did a great job during hurricane Katrina and they’re giving us HF voice/SITOR ops in the Pacific via KLB. These stations are reachable worldwide with the skills supposed to be taught in all GMDSS STCW classes.  Ships have to test the gear once a day anyway and should be encouraged to keep their hand in by sending a synoptic weather once via SITOR and once via Sat-C.  Again – why do we want to do away with layers of redundancy and of multiple capacities?


KA: at the equipment level LRIT and SSAS device logically should be covered in the GMDSS class.  Academically they bear on the Ship’s Security Officer class, the SAR class and the Emergency procedures class.  I have been working on new curriculum this year for all four classes.  My concern is adding these features to a Competency & Proficiency exam week that is already heavily burdened would raise new difficulties.  How deep are we going to go if there are equipment proficiencies?  Perhaps there could be a half or full day addition to the Security Officer class for lab familiarization and training if adding to GMDSS seems undesirable.

(survival craft equipment)
KA: Long desirable – economizing on S.C.E. equipment is a far-too frequent decision by companies – it frequently is the bare minimum requirements from the least expensive and not very well made equipment providers.


KA: There have been numerous attempts over the years to scrap the HF weather transmissions.  Many vessels do have computer or web based weather delivery systems but not everyone does.  The surface analysis & 500 MB charts form the core of the STCW classes on weather and on heavy weather avoidance.  They are widely used in the industry and should be continued.


(non-SOLAS vessels)

KA: This is one reason why the MF-HF capabilities of GMDSS should be retained.  The U.S, fishing industry has one of the highest industry death rates and it is long past due that they have the same capabilities as similarly sized vessels.  The industry exemption of one year after the USCG declares A1 & A2 in effect should be revisited if it is going to take until 2017 to complete the work in Alaska.  No fishing vessel I know of is ever going to be just an A2 vessel – the fish live out in the Bering and the Gulf and nearly all F/V make an A3 transit to Puget Sound or other West coast ports to resupply and retrofit.  For all practical purposes they are all A3 ships right now.


(false alerts)



KA: The strict policing of inadvertent alerts by Inmarsat is an example that could well be carried over to the MF-HF world.  Recent emails have made mention of computerized DSC stations – are these widely in use?  What do the watch-standers at USCG COMMSTAs do?  Years ago at a conference while inquiring about log-keeping at NOJ, I asked the Lt. what was done with the logs and he said “we just mail them to Pt. Reyes & what they do with them I don’t know.” Many ships keep their logs in electronic format.

If all these DSC alerts are captured in electronic memory it should be relative easy to collate them and “counsel” (or tie up) the most frequent and flagrant offenders. Of course, if there wasn’t the blizzard of DSC Acks & Relays the workload of the Coast station and vessel personnel would be reduced by at least 97% and probably more.  The log-keeping CFR should be revised to only request records of ‘first link in the chain’ DSC Distress Alerts (i.e. those with a single MMSI.) 

Having ships keep logs of Relays and Acks from other vessels and from shore stations is a colossal waste of a ship officer’s time.  First link DSC Distress calls are either real and should be logged & responded to by the receiving vessel or they are inadvertent and should be recorded to identify those still misusing the GMDSS system.   In 5 months of active sea-time with the GMDSS console I personally typed up 4-5,000 DSC Distress calls and none that I can recall were from the original vessel and absolutely none had any follow-on communications – whether cancellations or human distress communications. Nations whose vessels ‘lead the league’ in inadvertent alerts could be asked to review their training or inspections of such flags could be intensified.

Russ Levin's reply:



Kurt:
Thank you for your excellent input.

Problems with equipment and necessary improvements:
   1. We need to consider a requirement that all GMDSS equipment utilize the latest software that has been written to correct previous errors. This may be difficult in some older equipment but worth considering.

   2. Later versions of software need to simplify the operation by eliminating seldom used functions and reduce the number of "layers" to reach a desired function in the menu.

Problems with training:

   1. Diploma mills will always be around and the best way to eliminate these is to have a requirement that a sample lab portion be observed by a third party for quality control.

   2. The training that is done well is lost when the equipment is not used. Use of MF/HF for ship's business is no longer viable due to the loss of commercial shore stations. Use of satellite is required by most companies.

I agree with your comments on SITOR/NBDP but the use of that mode needs to be updated and computer based, better automated, and much simpler to operate if there is to be any hope. Again loss of shore stations has greatly impacted the use of NBDP for ship's business.

v/r

Russ

Another excellent input from Kurt Anderson.



Fm: Kurt Anderson,    GMDSS Instructor 1999-2010
         Radio Officer USMM 1979-1999

Subj: GMDSS Modernization


DSC Controller functions


The problem of DSC Acknowledgements/Relays has been discussed endlessly and for well over a decade and yet they still plague the watch-standing deck officer.  As an instructor I issue paper copies of DSC Acknowledgements & relays received at our school in Seattle.

We don’t even have antennas currently hooked up and yet -- we still have received in the last year multiple calls from NOJ Kodiak and NMC Pt. Reyes.  These calls can persist over hours. In one instance the call originated from 9 degrees south and 76 degrees East -- how many ships it took to daisy-chain that one from the Indian Ocean to the U.S. on 8414.5 MHz can’t be known -- but it must have been multiple vessels.

Everyone should know the problems associated with the DSC false alert problem persist. Training of officers can only partially solve this problem (see below). If the format of the DSC call cannot be readily altered then at least the manufacturer’s software must be changed. This change must be made retroactive to all currently installed DSC units whether through software or hardware upgrades. Officer aggravation would be exponentially reduced and a corresponding confidence in GMDSS greatly enhanced by this one change.

For instance -- the new Furuno MF-HF console has removed the DSC ACK feature and brought the Relay SEL command to a more prominent menu location but the Relay All command is still the first on offer.

The only DSC Relay function that should be available to a ship’s officer is the Relay Select command.  Just as now -- it should appear at the end of any incoming DSC Distress with nature and position call.  This menu should also be the only DSC Relay function apparent at the end of examining a past Distress DSC call in the data directory. 

The Relay select field should enforce the first two digits as double-zero to ensure that only coast stations get the call. The removal of the All-ships ACK/RELay features from the ships would also eliminate the problems caused by the lack of YY/MM/DD values in DSC calls dredged up and re-transmitted days and months later.

SAR communications would not be impaired by this change.  Nearly the entire DSC alarm problem is caused by inattentive and insufficiently trained officers -- in response to situations that are not genuine Distress alerts in the first place.   The removal of ACK/REL all ships commands will eliminate the blizzard of false alarms and will not prevent vessels from being rescued.  If the ACK/REL command was used in response to an inadvertent DSC alert it shouldn’t have happened in the first place.  If the Distress is genuine -- the ACK and Relay commands are unnecessary.  The information pertaining to any authentic distress could always be conveyed ashore to SAR authorities by a wide variety of communications modes -- not by lighting up the whole ocean with DSC calls and alarms.  The good intentions of the system designers are evident but no human can deal well with a Distress system leading to a barrage of alarms/alerts.  (While serving in East Asian waters I have recorded them at 20 per minute on a bad day.)

Part 80 CFR currently reads:

80.1117  Procedure for receipt and acknowledgement of distress alerts.

    (a) Normally, distress calls received using digital selective
calling are only acknowledged using a DSC acknowledgement by a coast
station. Ships should delay any acknowledgement in order to give
sufficient time for a coast station to acknowledge the call. In cases
where no acknowledgement has been heard and no distress traffic has been heard, the ship should transmit a distress alert relay to the coast station. Upon advice from the Rescue Coordination Center, the ship may transmit a DSC acknowledgement call to stop it from being repeated.
 
This language is a vast improvement over prior regulations. However, the third sentence is still problematic.  Given that almost no DSC Distress alert turns out to be from a genuinely distressed vessel -- it requires of a ship (that for propagation reasons didn’t catch a Coast Station’s Ack or Relay) to deluge coast stations with DSC calls concerning alerts that in all likelihood were accidentally transmitted to begin with. Compliance with this by anyone will inevitably will result in a vastly greater workload at the DSC coast stations with consequent distraction to CRS watchstanders.
 
“No distress traffic heard” -- that’s almost assuredly a false alarm.  At minimum -- this language should make explicitly mandatory what it implicitly suggests -- that the Relay Select command be used. If there is an incessant DSC Distress transmission from a vessel then it is either genuine (and likely from an unmanned bridge) or it is not genuine.  In either case the RCC should get various Coast Stations to collaborate to silence it and keep the ship’s officers out of the loop.  On an interim basis the language should be changed to try and keep ships from re-transmitting calls out of the data directory or of sending Ack and Relay responses to the Ack and Relay commands of other stations.

However -- the software should not be altered based upon any nautical mile radius mentality -- ships hundreds and even thousands of miles away might be able to render communications assistance (especially in remote locations such as the poles) -- without being able to render physical assistance.  Also many ships have been known to have defective GPS equipment without being aware of it and to have incorrect manual positions entered -- this would totally bollix any DSC computer trying to make automated software decisions based on accurate positions.

SSB Transceiver:

GMDSS consoles typically use a software database with the Duplex/Simplex Voice and Telex ITU assignments.  It would be useful if all of the consoles gave some indication that the emission selected does not match the frequencies chosen by the officer -- some warning to the watch officer would be nice. 

For instance -- the latest Furuno console does not show a channel field value when the emission and frequencies do not match.   It does the same thing when a manual receive entry outside of the Marine bands is performed.

The manufacturers were given far too much latitude in their transceiver software  -- the DSC software and officer practice refers to “channels”.  This variability is an absolute disgrace and danger.  For instance -- the SEA console requires a “CH450” entry to arrive at 4125.0 kHz but a Furuno vessel requires a “CH400” entry to get there.  Neither of these entries is a valid ITU designation – each manufacturer made it up.  In isolation their logic is apparent but neither agrees with the logic of the other. You hear vessels in the Bering Sea requesting “meet me on “CH450” all the time without any awareness this is not a valid ITU designation or that Furuno vessels don’t have any such database value and therefore cannot switch to a “CH450.”

Instead there should be a simplex/duplex command referencing only the ITU assignment values for worldwide & logical consistency.  This command could easily be engineered with software and/or a simple switch.

Transceiver switching issues:

A USCG email recently made the rounds warning of the automatic switching of VHF units in response to incoming DSC calls taking vessels off of VTS channels etc. Is it known that some units additionally decide to shift from USA mode to International mode upon an incoming Ch-70 alert? This is an especially hot topic here in Seattle where we have a VTS of CH 5A and the International border with Canada to deal with for VHF operations.

The problem also afflicts the MF-HF world. We received a 12 MHz DSC call at the school which controlled our sideband transceiver to the alternate frequency of 12345.6 kHz!!!  The student examined it and instantly started laughing but not all officers are that trained and aware. (The frequency is obviously not a designated Marine frequency.)

This is a very real danger resulting from an automated unit or ignorant officer response to such calls.  This problem was apparent from the first.  That is why it is explicitly referred to by the NMC equipment competencies that all NMC approved U.S. GMDSS schools are supposed to be teaching.   Different manufacturer’s software deal with this issue differently and some manufacturers change their software over time.



Training:

The 20 May 2010 Task Force document makes reference to “poor operator training.”  It is a significant part of why the GMDSS system continues to have problems. Basing a curriculum on the IMO Model course is just the beginning -- the devil is in the details. Having examined course books from both International & U.S. schools I would have to say that far too many fall short – incomplete, unorganized, out of date (and in some cases saying things I find to be factually untrue.) 

Regardless of whether live equipment or simulation is used -- the heart of GMDSS instruction is whether the lab experience actually imparts the necessary skill set.  This level of proficiency needs to build on the academic curriculum to produce officers who understand GMDSS, understand its flaws and can still effectively get themselves, their crew and fellow mariners rescued in a SAR crisis.

Once the NMC issues a course approval what are U.S. schools doing?  Is there any adequate procedure for auditing STCW proficiency assessments or the schools’ graduation rates or of re-examining the courses to see if they truly measure up to the desired mark?   Are schools and instructors fulfilling their obligations? Diploma mills are not an unknown phenomenon in colleges and adult education -- maritime vocational and academies are not immune from the possibility -- scuttlebutt is an old maritime tradition … is anyone interested? Competency assessment requires experience, judgment and fairness. It rests on a willingness to uphold standards on the part of the assessor and the acceptance on the part of the candidate of the validity of those standards. 

Currently in the U.s. nearly all the annual inspections are conducted by shore-based maintainers and occasionally some other designated examiners.  Based on anecdotal evidence and my own experience I would maintain that not all shore-based maintainers have sufficient grasp on the nexus of operational procedures, law and menu variations to be able to comprehensively make assessments of the competencies of a vessel’s officers on the annual inspection or random Port State control inspections. There is also a potential conflict of interest here that should trouble all of us in the industry and government.



What does work in GMDSS?

I am not one who sits around nostalgic for Morse code -- it was always a bit of a pain.  However, GMDSS modernization should not throw out systems such as SITOR, which are tried and true.  Frankly it isn’t that hard to teach and nearly all students take to it in fairly short order.  SITOR transmissions are effective in signal conditions in which voice hasn’t a chance.

Our industry, society and the entire U.S. military is demonstrably over reliant on satellite systems that don’t invariably work and would be endangered in times of war -- exactly when we would need a working Distress system most. New environmental and communications curriculum is being contemplated as summertime transits of the Artic become possible -- what is an A4 ship going to do in the poles with one less tool at their disposal?

Doing away with the capabilities of MF-HF (as some have argued) is extremely shortsighted. A ship that meets the A3 carriage requirements by installing two Sat-C terminals so they can cut costs and avoid DSC alerts can rescue itself but it can’t rescue the rest of us! It has neither the equipment nor the operator familiarity necessary to a SAR situation -- why have aircraft with 4125, 3023 and 5680 kHz if the ships involved have no SSB capable of communications? There is a vast reservoir of MF-HF procedures and experience in the industry, in the SAR forces around the world and still referenced by  the IAMSAR manual.  Why are we talking about reducing proven capabilities in a Distress system?

I flatly reject the position that it is “too hard to teach” so we should just give up. One of the most important pieces of student knowledge is that 2 MHz should ‘paint’ a 150 NM radius of communications around a vessel on Distress (without any further quandary about the mysteries of the ionosphere). In most of Europe and large parts of the NW Pacific & Southeast Asia that could suffice to carry the entire Distress to a successful conclusion.  Australia as a single nation continent made a logical choice to jump to A3 and America could have made a similar choice but we are nearing implementation of A2 after years of waiting -- why quit now?  A3 HF should be retained and improved in the U.S.

Operator Interface:

Manufacturing standards for the machine-human interface should also be examined.  The constant drive to shave costs by reducing dedicated controls, combing separate radios into one box etc. only ends up with a puzzle palace of hierarchal menus that many otherwise competent officers have a hard time recalling or navigating.  The same mentality afflicts ARPA and ECDIS equipment.  Without calling out any manufacturer in particular -- a Distress system based on a 75-cent plastic knob prone to breakage or erratic and idiosyncratic software is not what we should be tolerating.


Sincerely,

Kurt Anderson

My reply:



Hello Owen

Thanks for some very interesting ideas.

In Australia, we run GMDSS revalidation courses – this has helped a lot.

Whilst we all agree that a common design would be a great way forward, this will take time to implement and will be fiercely resisted by shipowners.


Deck Officers are not lacking in intelligence – getting a Master 1 Certificate is not easy, and involves lots of study.  These guys can clearly apply themselves if they want to.

Yes, GMDSS MF/HF radios can be difficult to understand, but I have run a few training courses myself, and MF/HF and DSC CAN be taught – as I’m sure you will agree.

It can be simplified – and the IMO “actions” flow chart is a big help – if in doubt, follow the chart!  We used to mandate that the chart was to be displayed alongside the GMDSS gear.

Deck Officers moan about unnecessary DSC alarms – most of these are caused by other Deck Officers who are not following the flow chart. 

All these false alerts fly about, yet no one wants to do anything about them.

In Australia, GMDSS courses follow the IMO model syllabus, and are 2 weeks long.  This is enough time to teach the basics of HF and DSC.  It can be boiled down to a simple set of do’s and don’ts.

And, as I like to tell my students….if in doubt – wait and listen on the R/T channel.

Rgds
Glenn