RTCM Paper 026-2009-SC101-233

Summary of Discussions and Decisions on “Class H” Portable Radio at IMO COMSAR 13

The IMO Subcommittee on Radiocommunications, Search and Rescue met in London the week of 19 January 2009 (COMSAR 13). The Subcommittee considered the “Class H” portable radio, which had been proposed to the ITU by the United States on the basis of work done by RTCM Joint SC101/110. (ITU Working Party 5B had asked IMO COMSAR for a recommendation on this proposal through a Liaison Statement.) COMSAR 13 generally supported the concept, but did not endorse the creation of a new Class H, taking into account the pending simplification of Class D, which IMO COMSAR has already requested from ITU. A number of delegations thought that any differences between a fixed Class D radio and a portable Class D radio could be addressed within revised Class D standards. The decision on class designations will ultimately be left to ITU.

COMSAR 13 prepared a Liaison Statement back to ITU Working Party 5B and CIRM, which is reproduced on the last page of this document.

The discussion on this matter took place in two COMSAR 13 Working Groups. Excerpts from the reports of the Working Groups follow. The papers referred to are:
COMSAR 13/4/1 – ITU Liaison Statement
COMSAR 13/4/4 – United States, supporting the Class H concept
COMSAR 13/4/9 – Canada, supporting the Class H concept
COMSAR 13/4/10 – United Kingdom, noting the similarity of the Class H concept with the request to simplify Class D

Search and Rescue Working Group

3.1 The group considered documents COMSAR 13/4/1, COMSAR 13/4/4, COMSAR 13/4/9 and COMSAR 13/4/10 concerning the proposal for a new “DSC Class H” of DSC portable radio and was of the opinion that there is a clear need for a simplified Mobile DSC/VHF Radio for use on non-regulated vessels like pleasure crafts usually operating within visual range off the coast.

3.2 In this context, the majority of the group agreed that such handheld radios should not be seen as an integral part of the GMDSS, but only as a piece of equipment using functionalities provided within that system. Therefore the term “Class H” could be misleading. Consequently the group preferred to discuss “handheld radios used by pleasure boats”.

3.3 The group also agreed with the concerns raised in plenary and specifically in documents COMSAR 13/4/1 and COMSAR 13/4/9. The group was aware of potential problems, the operational limitations and the potential risk of additional false alerts, as mentioned in documents COMSAR 13/4/1 and COMSAR 13/4/9, which could be caused by such a tool (as in practice it is with cellular telephones, widely spread, carried on board and used for alerting and distress communication). However, weighing pros and cons and in the light of the fact that the industry already distributes handheld VHF with DSC functionality not fully complying with the GMDSS, the group was of the opinion that it would be beneficial to provide the industry with guidelines of minimum performance capabilities required, allowing SAR Services to respond to distress alerts promptly and efficiently.

3.4 The group agreed with the features of a “pleasure boat handheld radio” as described in paragraph 7 of document COMSAR 13/4/4, and was of the opinion that the most important characteristics of such a radio were:

.1 simple operation minimizing accidental misuse;

.2 GNSS position transmission; and

.3 identification/registration of each individual unit (as already carried out, for example, in the United Kingdom and Australia).

Technical Working Group

4.9 The Group considered documents COMSAR 13/4/1, COMSAR 13/4/4, COMSAR 13/4/9 and COMSAR 13/4/10, taking into consideration the advice provided by the SAR Working Group, on the proposal for a new DSC handheld radio (termed Class H) and was of the opinion that there was a clear need for a handheld VHF radio with an appropriate range of DSC facilities for use on non-regulated vessels, usually operating within visibility range of the coast. The intention was to provide a simple cost-effective VHF handheld radio that would be able to:

.1 initiate a distress alert via DSC and a distress call via radiotelephony;

.2 provide the unit’s location by means of a built-in GNSS receiver; and

.3 support voice communications with rescue services in an emergency.

The inclusion of accurate location information obtained from GNSS with distress calls was vital to provide a rapid response to vessels in distress. The DSC alerting capability would also provide a more reliable communication path than voice distress calls on VHF Channel 16.

4.10 These handheld radios would not duplicate the functions provided by VHF/DSC communications equipment required under GMDSS compulsory carriage requirements but would be compatible with GMDSS procedures. They would not be suitable for replacing a fixed VHF/DSC installation but might be considered as a possible future replacement for the VHF portable two-way radiotelephone set specified for use on survival craft. The term “Class H” could, however, be misleading because the type of equipment envisaged was not intended to be an integral part of the GMDSS, rather it uses functionalities provided within the GMDSS.

4.11 The Group noted the concerns also raised in plenary, the SAR Working Group and also referenced in documents COMSAR 13/4/1 and COMSAR 13/4/9, about operational limitations, false alerts and operator competence:

.1 The reduced range of a handheld VHF radio compared to a fixed installation was a concern to many. However, the vast majority of distress incidents involve recreational and small commercial vessels, not vessels required to be fitted with GMDSS radios. For example, near-shore fisheries may employ small craft that do not have adequate energy resources for powering a fixed VHF/DSC installation, or the physical space needed to install fixed VHF/DSC equipment and associated antenna. Moreover, small craft should not sail at distances from the coast in excess of their navigational and motive power capabilities. It was not considered necessary to define a new sea area in order to condition the use of such equipment.

.2 As regards false alerts, these remained a recurrent problem even with professional seafarers and equipment. Moreover, the alternatives of non-regulated vessels relying on cellular mobile phones, or having no radio at all, are strongly discouraged. The equipment specification should therefore include adequate measures to prevent inadvertent activation of the DSC distress function.

.3 The Group noted that operator certification for VHF radios on non-SOLAS vessels was a matter for national decision, but strongly encouraged national administrations to ensure that operators should receive an adequate level of training, for example in order to meet the requirements of the Short Range Certificate as set out in Resolution 343 (WRC 97) of the ITU.

4.12 The Group also had concerns about how to avoid confusion when trying to identify the source of distress alerts from handheld radios. These were likely to move around with personnel to different vessels on a regular basis, rather than always being associated with a specific vessel. Noting information provided by the delegations of Australia and the United Kingdom on how they have approached this problem, the Group would recommend a registration process whereby distinctive MMSI numbers were allocated to handheld radios, which were then linked to named individuals. Ideally, the individuals concerned would have to produce an appropriate certificate of competence as part of the registration process.

4.13 On balance and taking account of the fact that VHF radios with basic DSC facilities, manufactured in accordance with RTCM standard SC101, were already in use, the Group was of the opinion that it would be beneficial to provide industry and standards organizations with clear guidance on the performance capabilities needed to ensure that SAR Services were able to respond to distress alerts promptly and efficiently.

4.14 The Group accepted the case for a handheld VHF radio with certain DSC facilities as described in paragraph 7 of document COMSAR 13/4/4 and was of the opinion that the most important characteristics of such a radio were:

.1 simple operational layout, minimizing accidental misuse;

.2 GNSS position acquisition;

.3 identification/registration of each individual unit to a named individual (as already carried out for example by Australia and the United Kingdom); and

.4 minimum number of options beyond the essential requirements.

4.15 The Group discussed the question of whether two receivers would be needed for watchkeeping purposes or whether the technology was now sufficiently advanced to use a rapid scanning single receiver. The conclusion was that further studies were needed in order to verify whether the performance of single receiver would be adequate. This matter could be kept under review while standards were developed.

4.16 The Group prepared a draft liaison statement to ITU-R WP 5B and CIRM, set out at annex 4, and agreed to invite the Sub-Committee to approve it and to instruct the Secretariat to send it to ITU and CIRM, and to invite the Committee to endorse this action.

LIAISON STATEMENT TO ITU-R WP 5B AND CIRM

PROPOSED NEW .DSC CLASS H. OF DSC PORTABLE RADIO INTENDED PRIMARILY FOR DISTRESS ALERTING AND COMMUNICATION

1 IMO would like to thank the ITU-R for the opportunity to comment on the proposed new DSC Class H device.

2 The Sub-Committee on Radiocommunications and Search and Rescue (COMSAR), at its thirteenth session (19 to 23 January 2009), discussed the proposal and concluded that a handheld DSC device compatible with the GMDSS could be of benefit on vessels not required to be equipped with radios compliant with the GMDSS. The simplified radio would increase the probability of successful communication with Search and Rescue forces in an emergency, and would provide an accurate location when equipped with a Global Navigation Satellite System (GNSS) processor. The Sub-Committee considered that the establishment of a new Class H might not be necessary. The objective is to allow for a handheld VHF radio with DSC facilities.

3 The Sub-Committee considered that the envisioned handheld DSC radio with a GNSS processor should have the following features and capabilities:

.1 simple display and operator interface;

.2 standard operating mode which could be Dual Watch on Channels 16 and 70, with the option of setting a Working Channel as well (Tri-Watch);

.3 send a DSC distress alert with undesignated nature of distress using a “Distress” button under a flip-up cover;

.4 automatically handle the integration of location via GNSS into the DSC message;

.5 send a distress message even if location is not available; however, it will warn the user of this and keep trying to acquire location and send an updated distress message automatically;

.6 safeguards to ensure erroneous and out-of-date locations are not transmitted;

.7 send a test call;

.8 send a routine call to individual stations;

.9 send a group call to stations having common interest; and

.10 receive distress alerts, distress acknowledgements, urgency calls and safety calls, routine calls, group calls.

4 The Sub-Committee noted that since these handheld DSC radios could be moved from vessel to vessel, further consideration should be given to the issuance of MMSIs to indicate that it is a handheld device.

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