AIS technology, which has been under development worldwide since the early 1990s to improve navigation safety, helps prevent collisions by enabling ships to electronically "see" and track the movements of similarly equipped ships and to receive pertinent navigational information from shore. Like other wireless technologies, AIS uses a portion of the radio frequency spectrum to carry information. In the United States, specific frequencies within the radio spectrum are allocated primarily by two agencies: FCC--an independent agency that regulates spectrum use for nonfederal users, including commercial, private, and state and local government users--and the National Telecommunications and Information Administration (NTIA), an agency within the Department of Commerce that regulates spectrum for federal government users. These agencies (1) decide how various frequencies are used and (2) assign the frequencies to specific users. FCC makes these assignments by issuing licenses to nongovernmental parties; NTIA does so by assigning specific frequencies to federal agencies that have radio communication needs. AIS is designed to improve upon information available through vessel- monitoring systems already in use. Existing VTS systems apply radar, closed-circuit television, radios, and other devices to monitor and manage vessel traffic from a central onshore location, much as an air traffic control tower does (see fig. 1). An AIS unit consists of a global navigation satellite system; computer hardware and software; three radio receivers; and one radio transmitter-receiver, or transceiver. The unit gathers vessel information--including the vessel's name, identification number, dimensions, position, course and speed, destination, and cargo--from shipboard instruments or from manual input and transmits it to receiving AIS stations installed on other ships or on shore. Radio frequencies, or channels, carry the information. AIS also requires considerable infrastructure on shore--including antennas and base stations equipped with electric power, transceivers, computers, and displays--to monitor vessel activity and transmit information or instructions back to vessels. In the United States, such infrastructure now exists only in areas where VTS systems operate. MTSA and Coast Guard regulations require that certain vessels on U.S. navigable waterways install AIS equipment between January 1, 2003, and December 31, 2004. Coast Guard regulations implementing the law provide that vessels include (1) commercial vessels 65 feet long or more on international voyages, including all tankers regardless of tonnage; (2) passenger vessels of 150 tons or more; and (3) commercial vessels on strictly domestic U.S. voyages in the 10 VTS areas, which encompass approximately 10 percent of the U.S. ports recognized by the Department of Transportation's Maritime Administration (see fig. 2). Currently excluded from Coast Guard regulations are fishing vessels and passenger vessels certified to carry 150 or fewer passengers. Regardless of itinerary, any private vessels not in commercial service, such as a pleasure craft, less than 300 gross tons are not required by Coast Guard regulations to carry AIS equipment. Conflict over the frequencies used for transmitting AIS signals in the United States has been developing for several years. In 1998, to promote flexibility in the use of maritime radio frequencies and to encourage development of competitive new services, FCC created and auctioned licenses to the remaining unassigned U.S. radio frequencies in the very high frequency (VHF) band reserved for maritime public correspondence communications. For approximately $7 million, MariTEL won the bid for these licenses. The announcements for the auction stated that potential bidders should be aware of international agreements and other issues that might affect the ability to use the licenses on the two specific internationally designated AIS frequencies, known as channels 87B and 88B. Issues that could affect the licenses were not explicitly laid out in the announcements, but potential bidders were directed to a prior FCC document and specific federal regulations for assistance in evaluating the degree to which such issues may affect spectrum availability. Different interpretations of issues such as these may have contributed to the conflict that continues to exist between MariTEL and the Coast Guard. This conflict extends to the use of both frequencies. FCC regulations required the winning bidder to negotiate with the Coast Guard for the use of frequencies for AIS but did not specify any particular frequency. In March 2001, in response to FCC's auction requirements, MariTEL and the Coast Guard signed a memorandum of agreement (MOA) that allowed the use of channel 87B for AIS in U.S. waters. MariTEL terminated the MOA in May 2003, however, after disagreements arose over interpretations of the MOA's provisions, including technical properties of the frequencies that the Coast Guard could use for AIS. After termination of the MOA, MariTEL asserted that the Coast Guard had no authority to use channel 87B for AIS, but the Coast Guard maintains that an FCC announcement still gives it that authority. With respect to channel 88B, MariTEL asserts, in general, that it obtained through the FCC auction the exclusive rights to channel 88B in certain areas within approximately 75 miles of the U.S.-Canadian border, and it has petitioned FCC for a declaratory ruling to that effect. The Coast Guard, NTIA, and the Department of Transportation disagree and assert, in general, that channel 88B has already been allocated on a primary basis to the federal government. The total cost and time frame for the development of a nationwide AIS remain uncertain. As of June 2004, the Coast Guard's efforts to install AIS equipment nationwide had followed two tracks: first, installing AIS quickly in the 10 VTS areas and, second, launching a widespread planning effort for the rest of the nation's navigable waters. Having taken advantage of existing facilities, electronic systems, and plans for AIS development to enhance safety in the 10 VTS areas, the Coast Guard plans to complete AIS implementation in those areas by December 2004. At the same time, the Coast Guard has begun to plan for U.S. waters outside the VTS areas, defining the goals, technical requirements, and waterways and vessels to be covered under a nationwide AIS. The Coast Guard expects planning for the technical requirements to be completed between December 2004 and February 2005. The Coast Guard also estimates that the nationwide system could cost between $62 million and $165 million. According to the Coast Guard, the cost estimate is preliminary, because geographic and other factors are expected to significantly affect the cost of installation at different locations, and the impacts are yet to be determined. The first effort in the Coast Guard's two-track AIS development has involved installing, testing, and operating AIS equipment in the 10 VTS areas. To enable monitoring of vessels carrying AIS, the Coast Guard accelerated onshore AIS installation under way in its navigation safety program. A combination of existing facilities, equipment, plans, and funding has allowed rapid establishment of AIS in the VTS areas. Since much of the AIS infrastructure for conventional safety monitoring (e.g., to avert collisions) is the same for security monitoring (e.g., to avert acts of terrorism), bringing AIS into service involved primarily adapting and modifying existing systems to accommodate their additional security purpose. AIS facilities are completely operational at Berwick Bay, Louisiana; Los Angeles-Long Beach, California; Prince William Sound, Alaska; and St. Marys River, Michigan. AIS is being tested along the lower Mississippi River in Louisiana, and it is partially operational at Houston- Galveston, Texas, and New York, New York. The facilities at Port Arthur, Texas; Puget Sound, Washington; and San Francisco, California, are under construction. The Coast Guard expects AIS installations at the VTS areas to be completed by December 2004. To enhance safety and efficiency at the ports of Los Angeles and Long Beach, the Marine Exchange of Southern California, a nonprofit corporation formed to provide vessel arrival and departure information to the local maritime industry, took the initiative to install and pay for AIS on its own. The total cost to the Coast Guard for the installation of AIS equipment at the other 9 VTS areas comes to approximately $20.5 million. Bringing AIS into service in the 10 VTS areas should improve vessel- monitoring capability at these locations. Before AIS, VTS facilities relied on such means as radar, closed-circuit television, ship-to-shore voice communications via radio, and people with binoculars. Signals and other information from the monitoring equipment went to a central vessel traffic center (VTC), where the information was collated and where staff tracked ships' movements. With AIS, for a vessel equipped with a properly operating AIS transceiver, VTC staff have access to so-called static information, which rarely changes, such as dimensions, vessel name, and identification number; dynamic information, which changes continuously, such as course and speed; and voyage-specific information such as cargo type, destination, and estimated time of arrival (see fig. 3). This detail allows VTC staff to immediately identify any transmitting ship, particularly if it is on a collision course with another ship or if it is headed toward a hazardous or restricted area. In some VTS areas, AIS also extends monitoring coverage over a wider radius than originally covered by VTS. On the lower Mississippi River, for example, AIS will cover more than 240 miles along the river--from its mouth to Baton Rouge, Louisiana--rather than the 8 miles around New Orleans covered by the original VTS system. In New York, AIS equipment will allow vessels to be monitored farther out to sea than possible with radar monitoring. From installing AIS shore facilities in the VTS areas, the Coast Guard has learned that the two primary drivers of installation cost are port geography and vessel traffic. Specifically, because AIS radio signals transmit in straight lines, installation can be complicated by the amount of water to be covered, as well as by terrain features such as islands, bays, and peninsulas. In addition, secondary features at a site have an impact, including availability of electrical power, previous presence or absence of communications links, availability of antenna towers, and costs to lease or buy land for antenna towers. For example, after completing site surveys of the area, the Coast Guard estimated that installing AIS in Puget Sound-- an arm of the Pacific Ocean extending into Washington State that features many bays and islands and is surrounded by mountains--would likely cost $6.6 million. In contrast, the AIS installation at Berwick Bay, Louisiana, one of the first AIS installations completed by the Coast Guard, generally monitors a roughly 5-mile radius around a short stretch of the Atchafalaya River and surrounding waterways; this installation cost approximately $1 million. On the basis of its experience installing AIS in the VTS areas, the Coast Guard estimates that installing AIS equipment nationwide could cost between $62 million and $165 million--a preliminary estimate that one Coast Guard official responsible for reviewing such programs characterizes as "ballpark." At the same time the Coast Guard is completing installation of AIS equipment in the 10 VTS areas, it is also planning for nationwide AIS installation, in waters where most of the needed infrastructure is not now available. This planning consists of two primary components: The Coast Guard will soon be defining the technical requirements of the system needed to meet both the safety and security missions of AIS, including how elaborate it will be. For example, will the system need to involve satellites to receive AIS signals beyond the range of stations on land, or will an installation that can receive signals only along the shore be adequate? The Coast Guard will also investigate whether AIS can share shore infrastructure, such as antenna towers, with systems in place or under development, such as its search-and-rescue communications system called Rescue 21. As of June 2004, the Coast Guard estimated it will be able to complete this planning sometime between December 2004 and February 2005. The Coast Guard is also determining the extent of AIS coverage needed in its overall AIS strategy, including a reexamination of which vessels should carry AIS in U.S. waters outside of VTS areas. This process includes selecting which waterways will be covered (e.g., deciding whether relatively small rivers and lakes will be covered); setting priorities for which waterways will be covered first (e.g., deciding whether large ports will receive coverage before open coastline); and identifying which additional vessels will be required to carry and operate AIS equipment (e.g., whether noncommercial, pleasure craft will still be outside AIS requirements). The Coast Guard has held public meetings and requested public comment on these issues and expects to complete its review of these comments by July 2004. Even after these planning efforts are completed, the Coast Guard will not be able to install AIS equipment outside VTS areas immediately. The factors that shape the cost of an AIS installation also shape the equipment requirements. For example, the more obstructions, such as mountains or tall buildings, that could block AIS signals, the more antennas will be required. At every location where the Coast Guard decides to install AIS equipment, it will have to evaluate the presence or absence of such design factors. Site surveys that detail local terrain and the volume and variety of vessel traffic will have to be carried out before the Coast Guard can determine a location's precise equipment needs. As of June 2004, the continuing dispute between MariTEL and the Coast Guard over various frequency issues was in the hands of FCC, which expected to respond in summer 2004. At issue are competing views over the use of the internationally designated AIS frequencies. The commission's response could involve any number of actions or conditions regarding the internationally designated AIS frequencies, especially on access to frequencies needed to carry AIS information. FCC's specific findings could lead to varied technical, cost, and legal implications for AIS installation and operation, including potential delay. Depending on how FCC responds, and any subsequent actions by the interested parties, one factor that offers an opportunity to lower the federal government's costs is the demonstrated or expressed willingness of certain local port entities to shoulder the expense and responsibility for AIS installation if they, along with the Coast Guard, can use AIS data for their own purposes. Since 2003, there have been a number of petitions, proposals, and other actions put before FCC on who may and should use channels 87B and 88B and for what purposes. In October 2003, for example, MariTEL petitioned FCC seeking a ruling that would prohibit transmission on channels 87B and 88B by entities other than those authorized by MariTEL. In this petition MariTEL asserts, among other things, that the termination of the memorandum of agreement ended the Coast Guard's right to use channels for which MariTEL holds licensing rights. The company further contends that transmissions by entities other than those authorized by MariTEL would interfere with its other maritime frequency licenses and prevent its benefiting from the investment it made at the auction. On behalf of the Coast Guard and the Department of Transportation, NTIA also petitioned FCC in October 2003, opposing MariTEL's petition and proposing instead that FCC allocate channels 87B and 88B exclusively to AIS for government and nongovernment use. The government's position was that navigation safety and homeland security would be compromised if the United States and the maritime industry did not have unrestricted access to the frequencies designated by the International Telecommunication Union for AIS use worldwide. Then in February 2004, citing a desire to protect its licensed rights and to reach a quick "resolution to the AIS frequency controversy," MariTEL submitted a proposal to FCC, "to share its licensed rights to channels 87B and 88B for use by ship stations and by the USCG at no cost." In this proposal, MariTEL generally agreed with NTIA's proposal to use channels 87B and 88B only for AIS, but unlike NTIA, it sought to limit access to the signals to ships, MariTEL, the Coast Guard, and the St. Lawrence Seaway Development Corporation. In other words, under this proposal, unless authorized by MariTEL, the Coast Guard and the St. Lawrence Seaway Development Corporation would be the only entities allowed to use AIS information received by a shore station. In effect, under this proposal, the transmission and receipt of AIS signals by other entities, such as marine exchanges, port authorities, or state and local government agencies, would require MariTEL's consent. FCC has been gathering public comment from groups representing vessel pilots, port authorities, ship and barge operators, and others on these competing proposals, and a response is expected in summer 2004. The implications of this response for nationwide AIS development will depend on just how the commission resolves the competing proposals. If FCC allocates the internationally designated frequencies exclusively to AIS use but limits access to ships, MariTEL, the Coast Guard, and the St. Lawrence Seaway Development Corporation, other organizations will no longer be able to use the signals and would therefore have no incentive to pay for installing AIS infrastructure. Such loss of incentive would likely mean the loss of federal cost-sharing opportunities, potentially closing off a possible long-term cost-reduction strategy in the development of AIS nationwide. For example, an official of the Merchants Exchange of Portland told us that the exchange would not be willing to pay for AIS facilities unless access to AIS data is unrestricted. In addition, according to an AIS consultant, enforcing a ban on parties other than MariTEL and the federal government to receive AIS signals at shore stations, as MariTEL has requested, could prove impossible, because an AIS receiver that is only receiving signals cannot be detected by an enforcement authority. For its part, MariTEL maintains that it should be able to protect its investors and to profit from the licenses it won and that AIS can be operated as required by FCC's preauction rules. The company also maintains that even if FCC grants MariTEL's proposal for shared access to the internationally designated AIS frequencies, technical issues could still harm the company's ability to use other frequencies for which it holds licenses. In its February 2004 proposal, MariTEL contends that FCC rules now permit an AIS transmission technology that causes interference with maritime communications on channels adjacent to 87B and 88B. The company's proposal asserts that such interference impairs non-AIS shore- to-ship communications, with significant impact to MariTEL's ability to use its licensed spectrum, including its construction of a wide-area radio system for maritime services. The Coast Guard argues that transmitting AIS signals on frequencies other than those internationally designated could compromise navigation safety and homeland security and complicate nationwide AIS development already under way using channels 87B and 88B. The Coast Guard cites examples such as the following: A ship traveling near or in U.S. waters may have to decide between broadcasting and receiving signals on the international frequencies--to "see" foreign vessels operating under international frequency requirements--and United States-specific frequencies--to "see" domestic vessels operating under U.S. frequency requirements. The inability of vessels to broadcast and monitor the U.S frequencies and the internationally designated AIS frequencies simultaneously heightens the risk of collisions. Until a fully automated frequency management system has been established nationwide, the use of frequencies other than channels 87B and 88B would require transmitting foreign ships to manually change frequencies when approaching U.S. shores. According to the Coast Guard, such so-called manual channel switching is cumbersome and vulnerable to human errors and, if a ship's crew fails to change to the U.S. channel when necessary, could leave the ship "invisible" to ships in the same waters broadcasting on the U.S. frequency. Any U.S. channel management plans that become necessary would, the Coast Guard believes, impair existing operations in the border regions with Canada and Mexico, as well as AIS communications with international vessels operating within or near U.S. waters. For example, the St. Lawrence Seaway AIS system, jointly operated by the United States and Canada, is viewed by the Coast Guard as a complement to its nationwide AIS. The Seaway system, however, operates on channels 87B and 88B, and any U.S.-specific frequencies would reduce the efficiency of this international shipping thoroughfare. Transmissions on channels 87B and 88B from vessels operating outside U.S. jurisdiction would interfere with the effective use of channels 87B and 88B within the United States. According to the Coast Guard, such interference would encumber four frequencies in U.S. coastal areas instead of just the two internationally designated frequencies. Finally, any additional actions by the interested parties stemming from specifics of FCC's response could slow or otherwise affect nationwide AIS development. An opportunity that may help the Coast Guard speed AIS installation at lower cost to the federal government is potential partnerships between the Coast Guard and local port entities. For projects like AIS whose costs and benefits extend 3 or more years, the Office of Management and Budget instructs federal agencies, including the Coast Guard, to consider alternative means of achieving program objectives, such as different methods of providing services and different degrees of federal involvement. Similarly, in 1996 a congressional conference committee report directed the Coast Guard to review user fee options and public- private partnerships for its VTS program. In carrying out these directives, the Coast Guard learned of potential partnership opportunities. The initiative for the actual partnerships has come mainly from the local port entities following their interactions with the Coast Guard on navigation safety issues. As a part of the VTS program, the Coast Guard has been performing a series of safety assessments at U.S. ports to help determine if additional VTS areas are warranted. In a number of cases, when the Coast Guard determined that a federal VTS was not warranted, local entities approached the Coast Guard for assistance in setting up their own vessel-monitoring system. Coast Guard assistance has ranged from full partnerships on vessel traffic management systems, to memorandums of understanding regarding uses of local vessel-monitoring systems, to advice and counsel on possible local efforts. The offers from port entities have come at a number of locations and reflect a realization that vessel monitoring can provide a range of benefits. Entities have explored partnership with the Coast Guard at ports including Baltimore, Maryland; Charleston, South Carolina; Corpus Christi, Texas; Delaware Bay, Delaware, Pennsylvania, and New Jersey; Hampton Roads, Virginia; Los Angeles-Long Beach, California; Portland, Oregon; San Diego, California; and Tampa, Florida. Given the level of interest, these partnerships offer an alternative to exclusive federal involvement in nationwide AIS development. Entities at some of the listed locations have used, or want to use, AIS data about incoming vessels to improve port efficiency, for example, by helping schedule tugs or dock workers; to improve safety by mitigating risks uncovered during the Coast Guard's safety assessments; and to increase their own security by monitoring vessels as they approach the port. Some of these entities have installed AIS or similar systems and have offered to share their information with the Coast Guard. Such work relieves the Coast Guard from having to carry out its own installation of AIS shore stations in certain locations, thus accelerating and facilitating nationwide AIS implementation. As of June 2004, some of the port entities that either used AIS or planned to do so included the following: The Marine Exchange of Southern California, which provides vessel information at the ports of Los Angeles and Long Beach, California, to support port safety and the efficient movement of commerce. As a part of that support, the marine exchange financed, with port pilots, and built the VTS system at Los Angeles-Long Beach and purchased and installed AIS equipment to that system. The Marine Exchange and the Coast Guard share information received on the AIS equipment. The Coast Guard estimated that the cost of installation at Los Angeles-Long Beach was comparable to the Coast Guard's installation at San Francisco, which the Coast Guard estimates at $2.2 million. The Tampa (Florida) Port Authority, which currently operates a vessel traffic advisory service. In 1997 the authority installed an earlier version of AIS that did not meet current international or Coast Guard standards but was designed to help the harbor pilots and vessel masters as they navigated in the Tampa Bay channels. The port authority recently requested a grant from the state of Florida to upgrade its AIS equipment to international and Coast Guard standards so as to improve security at the port of Tampa. The port authority has expressed willingness to share AIS information with the Coast Guard when its system becomes operational. Merchants Exchange of Portland, Oregon, which has expressed a desire to build an AIS system around Portland and the Columbia River as a means of supplying information on vessel movements to interested port entities. The goal is again to improve the efficiency of port operations. According to an exchange official, Merchant Exchange would be willing to share AIS information with the Coast Guard but would not build the facility until the conflict over AIS transmission frequencies is settled. In all three cases, the local port entity has already paid, or is willing to pay, for AIS installation, but the port entities' ability to use AIS information depends on the coming FCC response. Although the local entities are building systems for their own purposes, all are sharing, or are planning to share, AIS information with the Coast Guard when the systems are complete. For example, the initiative taken by the Marine Exchange of Southern California alone likely saved the federal government $2.2 million for AIS installation. The more local port organizations that are willing to pay for the purchase and installation of AIS facilities, the more the Coast Guard can save on nationwide AIS installation. If the FCC response does not allow these entities to make unrestricted use of AIS information, they are likely to be less willing to invest in such facilities. The development of AIS nationwide is an important step in the overall effort to increase port safety and security. The Coast Guard has made an expeditious start with its installations at VTS areas and its continued planning for additional coverage, but before the system can be fully implemented, the Coast Guard faces a number of challenges. It must make some key decisions to determine AIS's technical requirements, waterway coverage, and vessels to be equipped with AIS. The dispute with MariTEL must be resolved, and the Coast Guard must obtain financing for installation nationwide. Pending the outcome of FCC's response, financing is one area where the Coast Guard may find help in meeting its challenges. Although the Coast Guard did not actively pursue cost-sharing options under the VTS program, by actively doing so now, it could potentially accomplish its nationwide AIS installation goals more quickly and reduce installation costs to the federal government. To help reduce federal costs and speed development of AIS nationwide, we recommend that, depending on the outcome of the expected FCC response, the Secretary of Homeland Security direct the Commandant of the Coast Guard to seek and take advantage of opportunities to partner with organizations willing to develop AIS systems at their own expense. We provided a draft of this report to the Department of Homeland Security, the Coast Guard, and FCC for their review and comment. The Coast Guard and FCC generally agreed with the facts presented in the report and offered technical comments that were incorporated into the report where applicable. While agreeing with our recommendation, the Coast Guard also said that developing partnerships would face challenges such as ensuring that locally built systems meet all Coast Guard requirements, dealing with reluctant partners, or developing partnerships that maximize savings to the federal government. Given our assumption that the Coast Guard would not sacrifice AIS capability or standards in developing partnerships, we agree that developing partnerships will not necessarily be easy. We continue to believe, however, that doing so with willing local entities is in the public interest, and we continue to be encouraged in this regard by the level of interest in partnering with the Coast Guard that we found in the VTS program. As arranged with your office, unless you publicly announce its contents earlier, we plan no further distribution of this report until 15 days after its issue date. At that time, we will send copies of this report to the Department of Homeland Security and the Federal Communications Commission. We will also make copies available to others upon request. In addition, this report will also be available at no charge at GAO's Web site at http://www.gao.gov. If you or your staffs have any questions about this report, please contact me at (415) 904-2200 or at wrightsonm@gao.gov or Steve Calvo, Assistant Director, (206) 287-4800 or at calvos@gao.gov. Key contributors to this report are listed in appendix I. In addition to those named above, Jonathan Bachman, Chuck Bausell, Ellen W. Chu, Mathew Coco, Geoffrey Hamilton, Anne Laffoon, and Jeffrey Larson made key contributions to this report.

Summary:
As part of international efforts to ensure maritime safety and security--and to carry out its mandates under the Maritime Transportation Security Act of 2002--the U.S. Coast Guard is developing an automatic identification system (AIS) that should enable it to monitor ships traveling to and through U.S. waters. For AIS to operate nationwide, ships need equipment to transmit and receive AIS signals, and the Coast Guard needs shore stations and designated radio frequencies to keep track of the ships' identities and movements. Yet unresolved frequency issues between the Coast Guard and a private company, MariTEL, have come before the Federal Communications Commission (FCC). GAO reviewed federal agencies' progress in developing AIS nationwide and identified certain challenges and opportunities in completing the work. Because the Coast Guard is in the early stages of progress toward nationwide AIS development, the total cost and completion time are uncertain. The Coast Guard has taken advantage of opportunities to bring AIS into service quickly in 10 areas where vessel-monitoring technology already exists, and it is simultaneously defining and planning for full nationwide coverage. The Coast Guard has only preliminary cost estimates for a nationwide system, because geographic and other factors will affect installation at different locations. The Coast Guard estimates that planning and testing will be completed, and a request for proposals from potential contractors issued, between December 2004 and February 2005. The Coast Guard faces both challenges and potential opportunities in its development of a nationwide AIS. Nationwide development depends in part on how FCC resolves a continuing dispute between federal agencies and MariTEL over issues including who should have access to the internationally designated AIS frequencies and for what uses. To help protect its licensed rights to certain frequencies, MariTEL generally seeks either sole control over the international standard AIS frequencies or shared control with ships and the federal government. The federal government seeks a resolution that will reserve the internationally designated frequencies for AIS use by government and nongovernment entities. FCC expects to respond in summer 2004. This response--and whether it leads to any additional actions on the part of the interested parties--could affect the overall cost and pace of nationwide AIS development. Depending on FCC's response, one factor that offers an opportunity to reduce federal costs is that some local port entities are willing to assume the expense and responsibility for AIS construction if they can use AIS data, along with the Coast Guard, for their own purposes.