Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 32SEPTEMBER 2016 • FOGHORN 27 SAFETYMATTERS Feb 1, 2012 Run a an automatically formatted distress alert to the Coast Guard’s Rescue 21 distress system and to initiate or receive distress, urgent safety, and routine radiotelephone calls to or from any similarly equipped vessel or shore station without requiring either party to be near a radio loudspeaker. More simply, DSC VHF radios have a “red button” that can be pushed to call for help. It is required to have either an integrated GPS or be connected to an existing position-fixing device. Coast Guard and Industry Response Before the FCC requirement for upgrading to DSC VHF radios became effective, PVA and other industry partners engaged the Coast Guard with concerns that Class Aradios are not ap- propriate for small passenger vessels and Class D radios are compatible with the Coast Guard’s Distress 21 distress system. Hundreds of vessels would be required to submit waiver requests to the FCC, which would result in an ad- ministrative burden for all concerned. ClassAradios cost $1700 whereas Class D radios are just $200. The Coast Guard agreed, and issued Policy Letter 15-06 directing marine in- spectors to allow time for compliance beyond the effective date of the regu- lations. In addition, the Coast Guard drafted a petition to the FCC seeking a blanket waiver for all inspected passen- ger-carrying vessels operating within Sea Area A1. The FCC issued a notice soliciting public comments on Coast Guard’s request and 40 supportive comments were received. The FCC Order With the Coast Guard and the industry commenters agreeing that Class A and Class D radios provide an equivalent level of safety, the FCC concluded that, “requiring carriage of Class A VHF-DSC equipment to the exclusion of Class D equipment would not serve the rules’ purpose.” The FCC stated, “continuing to require vessels to request individual exemptions to permit use of a Class D VHF-DSC radio in lieu of a Class A radio imposes an undue administrative and financial burden.” The FCC Order permits “the instal- lation and use of Class D VHF-DSC radio equipment in lieu of Class A equipment by passenger ships and small passenger vessels subject to Subparts W and S, respectively, of Part 80 of our rules, provided that a) the vessel does not make internation- al voyages, and b) the radio contains integral GPS capabilities or is connected to an electronic position-fixing device.” That said, the FCC is not sending our exemptions to all vessel operators with a radio. FCC approved technicians will be aware of the Order when conducting station license inspections. Registration and Proper Installation The FCC regulations require DSC- equipped radios “use a Maritime Mobile Installation Identity (MMSI) assigned by the Commission or its designees” (47 CFR 80.103(b)). For inspected vessels, MMSI numbers are issued by the FCC using form 605, SAFETY, CONTINUED ON PAGE 30