7 August 2003

**U.S. NATIONAL IMPLEMENTATION TASK FORCE GMDSS INFORMATION BULLETIN**

**SAFETY OF FISHING VESSELS IN THE VESSEL MONITORING SYSTEM (VMS)**

**Background**

The National Marine Fisheries Service (NMFS) of the National Oceanic and
Atmospheric Administration (NOAA) has established a Vessel Monitoring
System (VMS) to track vessels, which have been authorized to participate
in selected fisheries. These fisheries are managed by the Regional
Fishery Management Councils that prescribe the equipment and procedures
for complying with VMS requirements. NMFS has been specifying tracking
systems to support law enforcement programs aimed at conserving marine
resources and countering violations by fishing vessels. The tracking
systems have been selected to take advantage of available technology,
automate the process to the extent feasible, ensure privacy, and
minimize cost to participating fishing vessels. While initial VMS
requirements have been limited to vessel tracking, there is obvious
management and safety benefit to specifying that vessels have a two-way
communications capability. Future developments may require vessels to
report fish catch or other data.

**Satellite Based Monitoring Systems**

Since most of the fisheries selected for VMS tracking lie well offshore,
satellite based tracking systems have been selected as offering the
desired capabilities of automation and privacy. The Inmarsat system
utilizing various configurations of the Inmarsat-C service has been
designated as one of the primary options but the Argos and Boatracs
systems are also permitted in selected fisheries and an Orbcomm proposal
has been made. The NMFS has had instances of spoofing by participating
fishing vessels and in some cases has restricted vessel terminals to
those with integral GPS, which do not accept external position input. In
some cases NMFS has also mandated special software modifications for use
in the VMS.

The Argos transponders are carried on polar orbiting environmental
satellites and track emissions from the vessel at prescribed intervals,
deriving positions from GPS receivers. There is a limited capacity for
reporting additional parameters such as catch data. There is a
capability to send ship to shore emergency alerts and the data center is
manned 24x7. The system is not configured for two-way communications but
future developments could add that capability. Argos terminals are not
GMDSS qualified.

The Boatracs system is a maritime version of a land-based vehicle
tracking system using geostationary satellites. Boatracs units are not
GMDSS qualified but have a two-way messaging capability for email type
data communications. There is a 24x7 manned data center and it is
possible to send a shore to ship 'priority' message, which will sound an
alarm on the vessel if the appropriate add-ons have been installed on
the Boatracs transceiver. An optional 'panic button' is available for
the vessel terminal that enables the vessel to quickly originate a ship
to shore emergency message creating an audible alarm at the data center
which will then notify the Coast Guard.

The Inmarsat-C system is a component of the GMDSS when configured
according to rules of the International Maritime Organization (IMO) to
meet Safety of Life at Sea (SOLAS) specifications. Inmarsat-C is a data
only system that supports text messaging and compressed data reports.
Position reports are derived from a connected or integral navigation
receiver. SOLAS configurations include a distress button for emergency
use, priority handling of distress and safety messages, audible alarms
on the vessel, and an Enhanced Group Calling (EGC) feature enabling
reception of the SafetyNET Marine Information Broadcasts. In this
Bulletin, the term "GMDSS qualified" means that all SOLAS specifications
have been met. The following Inmarsat-C terminals have been authorized
or are under consideration for selected fisheries:

a\. TT-3022D-NMFS - GMDSS qualified with integral GPS. Has a distress
button and can handle two way communications if a messaging unit is
provided (not required for VMS operations but required for GMDSS use).
NMFS software modification required.

b\. Trimble Galaxy TNL-7005 with software v5.1 with integral GPS. This
unit is factory preconfigured for NMFS VMS non-GMDSS operations. The
Trimble units are no longer being manufactured but may be available from
some dealers.

c\. Trimble Galaxy TNL-8005 with software v5.1. This unit is similar to
the 7005 except that it has an integral messaging unit and is GMDSS
qualified.

d\. TT-3026-M, a mini-C terminal that is under consideration. It is not
GMDSS qualified and only has two-way communications capability if an
optional messaging unit (laptop or etc) is added.

e\. TT-3026-S, a mini-C terminal similar to the 3026-M except that it
has EGC capability for reception of SafetyNET broadcasts. Two-way
communication is available if a messaging unit is added, (required for
GMDSS qualification).

The Orbcomm system has also been proposed for VMS applications but has
not yet been accepted. The system operates in the VHF band through 30
Low Earth Orbit (LEO) satellites with generally adequate coverage of
most fishing grounds. Orbcomm terminals are not GMDSS qualified but
two-way data communications are available in an email format. The data
centers are manned 24x7and can relay messages to a pre-set notification
list including the regional Rescue Coordination Center (RCC).

**Radio Safety Equipment Prescribed for Fishing Vessels**

Fishing vessels are engaged in a dangerous occupation, often in rough
weather and because of their relatively small size have come to be
regarded as generating proportionally more search and rescue missions
than other segments of the maritime community. Despite this, U.S.
fishing vessels have been minimally regulated for radio safety
equipment, perhaps due to political intervention aimed at minimizing the
expense of compliance. The Coast Guard has expressed concern that NMFS
VMS regulations have accepted non-GMDSS satellite systems with
non-standard or one-way messaging capabilities and versions of
Inmarsat-C in which a messaging unit is optional. The Inmarsat-C
transceiver can provide the position reporting function either
automatically or when polled but without a laptop or other messaging
facility, the unit cannot send or receive messages. NMFS has made it
clear that while they recognize the safety benefit of a two-way
communications capability, their mandate has been limited to Law
Enforcement requirements.

# Incentives for Fishing Vessels to Equip for Two Way Communications

Fishing Vessel crews are interested in sending and receiving personal
messages to family and friends ashore and may voluntarily augment
required communications systems with the necessary equipment to send and
receive email through internet connections. This becomes especially
important now that "marine Operator" commercial services are rarely
available. U.S. vessels can also generally route email messages to the
Coast Guard RCCs via the Internet although this may not be generally
true on a global basis. The NMFS may elect to require a two-way
communication capability in the future to facilitate catch reporting and
other management functions. Similarly, the Coast Guard may require a
two-way communications capability to support a future requirement for
long range tracking of fishing vessels for homeland security purposes.
If federal authorities do not mandate such a capability, insurance
companies and non-regulatory bodies such as the GMDSS Task Force should
provide incentives for voluntary fitting. If cost is a factor, most
fishing vessel owners might at least opt for a system providing email
capability if they understand the safety benefits. Ideally, a safety
conscious vessel owner will specify a GMDSS qualified system.

**The Coast Guard safety concern**

The GMDSS is an integrated system in which all vessels derive a
collective safety enhancement through participating in a common system.
When selected vessels in the fleet lack some of the GMDSS features, not
only is their safety posture reduced, but the safety of other vessels is
also reduced since those without full features cannot readily be alerted
to assist another vessel nearby. The Coast Guard safety concern with the
VMS equipment options which do not include a two way communications
capability is as follows:

a\. A high percentage of distress alerts received from Inmarsat-C
equipped vessels are false. For this reason Coast Guard doctrine
includes sending a message to the vessel to verify the validity of the
alert. A fishing vessel without a messaging terminal will not know that
he has been sent a message but the terminal will acknowledge receipt of
the message as though a messaging terminal was available. In the same
fashion, an EPIRB alert from a fishing vessel may also need to be
validated via a two-way communication system. The IMO Subcommittee on
Communications, Search and Rescue (COMSAR) addressed this problem at its
3^rd^ session and stated "the Subcommittee strongly urges that Inmarsat
no longer allow terminals without a full user interface and with
Distress Facilities to be used for data acquisition." (Now that Inmarsat
is a private Corporation, this recommendation should also be directed to
administrations).

b\. The Coast Guard often finds it necessary to contact other vessels to
assist a vessel in difficulty. Vessels in the vicinity can usually be
alerted through a priority SafetyNET broadcast which sounds an audible
alert on the vessels. Alternatively, a vessel known to be in the
vicinity can be addressed individually. Fishing vessels without a
messaging capability cannot be alerted by either means, however. Vessels
that optionally fit a messaging unit for email etc. can send requests to
the Coast Guard for assistance and can receive email messages sent by
the Coast Guard. These informal messaging channels may not produce an
audible alert on the vessel, however, and several hours can elapse
before the vessel routinely checks its email.

c\. Using non-GMDSS Inmarsat-C terminals would presumably minimize the
false alert problem since those terminals do not have a distress button.
This is a dubious improvement however, since a non-GMDSS terminal
inherently provides fewer safety features than a GMDSS terminal. If such
a terminal has a two way messaging capability, however, it would
contribute to safety since a fishing vessel could request Coast Guard
assistance via an email message and receive email messages from the
Coast Guard.

d\. While the availability of a non-GMDSS messaging system can be of
assistance, it is not as good as a GMDSS compliant communication system
since messages from the ship are passed through non-priority channels
and arrive at the Coast Guard Rescue Coordination Center (RCC) as an
email message. Much longer turn around times are typically associated
with these messaging systems. Similarly, the RCC, if trying to contact a
vessel without a GMDSS system is not able to use the readily available
SafetyNET priority broadcast channel which sounds an alert on the ship
and must resort to researching available data bases to determine whether
the vessel has a two-way messaging capability and, if so, how to address
the message. Note that the concern relative to two-way communications is
heightened if the Coast Guard required MF/HF Radiotelephone has been
waived because the vessel fitted a satellite system.

e\. A further Coast Guard concern regarding non-GMDSS messaging
terminals is the size of the storage buffer for incoming messages. In
the event that the vessel operator does not check for new messages
periodically, the buffer could fill up and some older unread messages
could be lost. There have also been reports that some GMDSS qualified
Inmarsat-C terminals may fail to store incoming messages properly if the
printer has been turned off, this reportedly included failure to store
messages on the floppy disc and delete older messages when the disc is
full.

**FCC Mandated GMDSS Equipment for Fishing Vessels over 300 Tons**

The Federal Communications Commission (FCC) is the regulatory agency
responsible for radio safety regulations for fishing vessels over 300
tons. The FCC Rules do not recognize fishing vessels as a special
category and treat them the same as cargo vessels of the same size. The
FCC Rules require full GMDSS capability for fishing vessels over 300
tons. This includes a SOLAS qualified Inmarsat-C terminal and numerous
other safety radio equipments. An FCC Station License is required for
all vessels mandatorily equipped with radio including those below 300
tons. GMDSS radio operator licenses are also required for those fishing
vessels required to be GMDSS equipped.

**Coast Guard Mandated Radio Safety Equipment**

The Coast Guard regulates safety radio equipment on vessels under 300
tons in accordance with 46CFR28. The complex carriage regulations can be
summarized as requiring the following equipment:

Emergency Position Indicating Radio Beacon (EPIRB) per 46CFR25

VHF Radiotelephone for all fishing vessels in all areas (DSC is not
specified)

MF Radiotelephone if operating over 20 miles from the coast (DSC not
specified)

MF/HF Radiotelephone if operating more than 100 miles from the coast or
in any Alaskan waters

A Satellite system covering the operating area can substitute for MF and
HF (this exception

> implies a two-way communications capability but it is not stated
> specifically)

A cell phone can substitute for MF and HF if the cellular system covers
the operating area

All required communication systems must have emergency power available

# New Regulatory Action to Comply with Homeland Security Requirements

The Coast Guard published new regulations on 1 July 2003 to implement
new homeland security procedures required by the Transportation Security
Act. These include short range tracking of vessels with a VHF Automatic
Identification System (AIS). Fishing vessels are not exempted in the 1
July regulations so those over 65 feet in length are required to fit the
short range AIS system by 31 December 2004. Another homeland security
goal to be implemented later will include a long range tracking system
utilizing Inmarsat-C and perhaps other VMS system techniques. It is not
yet clear what size fishing vessels may be required to participate in
long range tracking but it seems likely that the tracking system would
be accompanied by a requirement for two-way communications capability in
order to effectively manage the program. The GMDSS Task Force urges that
these new Coast Guard requirements be developed in conjunction with the
NMFS requirements to minimize impact on fishing vessels.

**Coast Guard Recommended Supplemental Radio Safety Equipment**

The Coast Guard strongly recommends that all fishing vessels equipping
for participation in a NMFS mandated VMS fishery, procure terminals with
a messaging capability to enable two way communications. If a GMDSS
qualified terminal is one of the options permitted, the Coast Guard
strongly endorses that as a preferred option for vessel safety. The
GMDSS Task Force also endorses these recommendations and has agreed to
help publicize them throughout the fishing community.

**The GMDSS Task Force**

The National GMDSS Implementation Task Force approved this Information
Bulletin on 7 August 2003, the Task Force is a Coast Guard sponsored
group established to resolve implementation problems and disseminate
GMDSS information. The Task Force is soliciting feedback on problems
encountered and invites responses to Captain Jack Fuechsel, Task Force
Executive Director, 1600 North Oak Street, #427, Arlington VA 22209;
phone 703-527-0484; or email gmdss@comcast.net. See also the Coast Guard
GMDSS Internet web site:
[www.navcen.uscg.gov/marcomms](http://www.navcen.uscg.gov/marcomms)
(select GMDSS, then GMDSS Task Force). Duplication and reprinting of
this Bulletin is authorized in order to reach the widest possible
audience.

File: vms-4.doc