**DA 08-1578**

**Released: July 2, 2008**

WIRELESS TELECOMMUNICATIONS BUREAU SEEKS COMMENT ON REQUEST FOR WAIVER
BY EDELWEISS, LLC OF PART 80 RULES TO ALLOW CERTIFICATION OF
PERSONAL/VESSEL RADAR BEACON TRANSPONDERS

WT Docket No. 08-124

## Comment Date: July 17, 2008 Reply Date: July 28, 2008

On March 17, 2008, Edelweiss, LLC (Edelweiss) filed a request for waiver
of Section 80.1101 f the Commission's Rules[^1] to permit equipment
certification for its "Personal Radar Beacon" (PRB) and "Vessel Radar
Beacon" (VRB). These proposed devices will be used to help pinpoint
survivors during search and rescue operations by acting as an "active
reflector" of 9.2-9.5 GHz band radar signals. Edelweiss states that its
PRB and VRB would bring the benefits of radar beacon transponder
technology to small boats and pleasure craft by offering a smaller, more
economical alternative to existing transponders.

The PRB and VRB do not meet the Global Maritime Distress and Safety
System (GMDSS) Search and Rescue Transponder (SART) technical standards
in Section 80.1011. Specifically, the devices' battery life is eight
hours (compared to ninety-six hours for a GMDSS SART), their power is
160 milliwatts (compared to 400 milliwatts), their antenna bandwidth is
±3 dB (compared to ±2 dB), and their range is no more than two nautical
miles (compared to five nautical miles). Edelweiss argues that its PRB
and VRB should not be required to meet the GMDSS SART standards because
the devices are intended to assist in locating individuals and small
boats in coastal and offshore waters, rather than lifeboats on the high
seas. Consequently, Edelweiss requests a waiver of Section 80.1011 to
permit the certification and use of the PRB and VRB. Commenters are
requested to address the merits of the PRB and VRB separately.

**Procedural Matters**

Comments on the request are due **no later than July 17, 2008**. Reply
comments are due **no later than July 28, 2008**. All filings should
reference the docket number of this proceeding, WT 08-124.

This proceeding has been designated as a "permit-but-disclose"
proceeding in accordance with the Commission\'s *ex parte* rules.[^2]
Parties making oral *ex parte* presentations in this proceeding are
reminded that memoranda summarizing the presentation must contain the
presentation's substance and not merely list the subjects discussed.[^3]
More than a one- or two-sentence description of the views and arguments
presented is generally required.[^4]

The request is available for public inspection and copying in the
Commission\'s Reference Center, Room CY-A257, 445 12th Street, S.W.,
Washington, D.C. 20554. Copies of the Request also may be obtained via
the Commission\'s Electronic Comment Filing System (ECFS) by entering
the docket number, WT 08-124. Copies of the request are also available
from Best Copy and Printing, Inc., telephone (800) 378-3160, facsimile
(301) 816-0169, e-mail FCC@BCPIWEB.com.

Comments may be filed using the Commission\'s Electronic Comment Filing
System (ECFS) or by filing paper copies. *See* Electronic Filing of
Documents in Rulemaking Proceedings, 63 Fed. Reg. 24121 (1998). Comments
filed through the ECFS can be sent as an electronic file via the
Internet to http:// www.fcc.gov/cgb/ecfs/. Generally, only one copy of
an electronic submission must be filed. If multiple docket or rulemaking
numbers appear in the caption of this proceeding, however, commenters
must transmit one electronic copy of the comments to each docket or
rulemaking number referenced in the caption. In completing the
transmittal screen, commenters should include their full name, U.S.
Postal Service mailing address, and the applicable docket or rulemaking
number. Parties may also submit an electronic comment by Internet
e-mail. To get filing instructions for e-mail comments, commenters
should send an e-mail to ecfs@fcc.gov, and should include the following
words in the body of the message, "get form." A sample form and
directions will be sent in reply.

Parties who choose to file by paper must file an original and four
copies of each filing. If more than one docket or rulemaking number
appears in the caption of this proceeding, commenters must submit two
additional copies for each additional docket or rulemaking number.

Filings can be sent by hand or messenger delivery, by commercial
overnight courier, or by first-class or overnight U.S. Postal Service
mail (although we continue to experience delays in receiving U.S. Postal
Service mail). The Commission\'s contractor will receive hand-delivered
or messenger-delivered paper filings for the Commission\'s Secretary at
236 Massachusetts Avenue, N.E., Suite 110, Washington, D.C. 20002.

-The filing hours at this location are 8:00 a.m. to 7:00 p.m.

-All hand deliveries must be held together with rubber bands or
fasteners.

-Any envelopes must be disposed of before entering the building.

-Commercial overnight mail (other than U.S. Postal Service Express Mail
and Priority Mail) must be sent to 9300 East Hampton Drive, Capitol
Heights, MD 20743.

-U.S. Postal Service first-class mail, Express Mail, and Priority Mail
should be addressed to 445 12th Street, S.W., Washington, D.C. 20554.

-All filings must be addressed to the Commission\'s Secretary, Office of
the Secretary, Federal Communications Commission.

Parties shall send one copy of their comments and reply comments to Best
Copy and Printing, Inc., Portals II, 445 12th Street, S.W., Room
CY-B402, Washington, D.C. 20554, (800) 378-3160, e-mail FCC@BCPIWEB.com.

Comments filed in response to this *Public Notice* will be available for
public inspection and copying during business hours in the FCC Reference
Information Center, Portals II, 445 12th Street S.W., Room CY-A257,
Washington, D.C. 20554, and via the Commission\'s Electronic Comment
Filing System (ECFS) by entering the docket number, WT 08-124. The
comments may also be purchased from Best Copy and Printing, Inc.,
telephone (800) 378-3160, facsimile (301) 816-0169, e-mail
FCC@BCPIWEB.com.

Alternate formats of this *Public Notice* (computer diskette, large
print, audio recording, and Braille) are available to persons with
disabilities by contacting Brian Millin at (202) 418-7426 (voice), (202)
418-7365 (TTY), or send an e-mail to access@fcc.gov.

For further information, contact Mr. Jim Shaffer of the Wireless
Telecommunications Bureau, Mobility Division, at (202) 418-0687,
james.shaffer@fcc.gov.

Action by the Deputy Chief, Mobility Division, Wireless
Telecommunications Bureau.

\- FCC -

[^1]: 47 C.F.R. § 80.1011.

[^2]: *See* 47 C.F.R. §§ 1.1200(a), 1.1206.

[^3]: *See* Commission Emphasizes the Public's Responsibilities in
    Permit-But-Disclose Proceedings, *Public Notice*, 15 FCC Rcd 19945
    (2000).

[^4]: *See* 47 C.F.R. § 1.1206(b)(2). Other rules pertaining to oral and
    written presentations are also set forth in Section 1.1206(b). *See*
    47 C.F.R. § 1.1206(b).