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Comment Sought on Waiver Request for Sea Marshall AIS MSLD

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Released: April 19, 2013


News Media Information 202 / 418-0500

Federal Communications Commission

Fax-On-Demand 202 / 418-2830
445 12th St., S.W.
TTY 202 / 418-2555

Washington, D.C. 20554

DA 13-796

Released: April 19, 2013





WT Docket No. 13-99

Comment Date: June 3, 2013

Reply Date: June 18, 2013

On March 4, 2013, Marine Rescue Technologies Limited (MRT) filed a request for waiver to
allow the equipment certification and use of its Sea Marshall AU9 Maritime Survivor Locating Device
(MSLD). MSLDs are intended for use by persons at risk of falling into the water such as mariners and
workers on marine installations or docks.1 Because the Commission’s Rules do not currently permit
certification or use of MSLDs, they have been authorized by way of waiver of Section 80.1061 of the
Commission’s Rules, which authorizes Emergency Position Indicating Radio Beacons (EPIRBs).2
MRT’s predecessor-in-interest was granted a waiver for a previous version of the AU9 that transmits
Global Positioning System (GPS) coordinates on frequency 121.5 MHz.3 MRT now seeks a waiver to
permit equipment certification and use of an enhanced AU9 that transmits GPS coordinates and a unique
identity code on Automatic Identification System (AIS)4 frequencies.
MRT was granted equipment authorization pursuant to waiver to allow the AU9 to transmit on
frequency 121.5 MHz at a maximum of 100mW effective radiated power (ERP). The device met the
applicable parts of Radio Technical Commission for Maritime Services (RTCM) Recommended Standard

1 They can be worn on or as part of a garment or life jacket, and are intended to facilitate the rescue of personnel in
the vicinity of their vessel or structure so that immediate assistance can be rendered without a time-consuming and
expensive search and rescue operation.
2 MSLDs differ from EPIRBs in that EPIRBs transmit a digital signal on 406.0-406.1 MHz that is detected by the
search and rescue satellite-aided tracking (SARSAT) system operated by the National Oceanic and Atmospheric
Administration. MSLDs do not meet all the requirements in Section 80.1061 because, in light of their narrower
focus, MSLDs do not operate on a frequency monitored by COSPAS-SARSAT, and do not transmit with as much
power or for as long as EPIRBs.
3 See FCC ID YFGAU9, granted July 20, 2010; see also David Marshall, Letter, 13 FCC Rcd 23688, 23688-89
(WTB PSPWD 1998).
4 AIS is an international maritime navigation safety communications system adopted by the International Maritime
Organization and Safety of Life at Sea Convention intended for collision avoidance, monitoring and tracking.

for MSLDs.5 MRT now seeks a waiver to allow the device to transmit identity and location information
on the international AIS channels (AIS A – 161.975 MHz and AIS B – 162.025 MHz) at 500 mW ERP
using a modulation scheme of Self-Organizing Time Division Multiple Access (SOTDMA) employing
Gaussian minimum shift keying at 9600 bps to access channels as defined in ITU R M.1371-4.6 The
enhanced AU9 is programmed with a unique nine-digit identification code in which the first three digits
(972) identify the device as a MSLD and the last six digits identify the manufacturer and the individual
unit. MRT believes that transmitting this information on AIS channels will enhance the rapid location,
identification, and rescue of survivors because the information will be received by any nearby AIS-
enabled device in addition to the MSLD base unit.

Procedural Matters

Interested parties may file comments and reply comments in response to the waiver request on or
before the dates listed on the first page of this Public Notice. All pleadings must reference WT Docket
No. 13-99. Parties may file comments using (1) the Commission’s Electronic Comment Filing System
(ECFS), (2) the Federal Government’s eRulemaking Portal, or (3) by filing paper copies.7
Electronic Filers: File comments electronically using the Internet by accessing the ECFS: or the Federal eRulemaking Portal:
Filers should follow the instructions provided on the website for submitting comments.
In completing the transmittal screen, filers 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, filers should send an e-mail to, and include the following words in the body of the message, “get form.” A sample
form and directions will be sent in response.
Paper Filers: Parties who choose to file by paper must file an original and two copies of each
Send filings 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). Address filings to the Commission’s Secretary, Office of the Secretary, Federal
Communications Commission.
Deliver hand-delivered or messenger-delivered paper filings to FCC Headquarters at 445
12th St., SW, Room TW-A325, Washington, DC 20554 between 8:00 AM and 7:00 PM.
Use rubber bands or fasteners to hold deliveries together. Dispose of all envelopes before
entering the building.
Send commercial overnight mail (other than U.S. Postal Service Express Mail and
Priority Mail) to 9300 East Hampton Drive, Capitol Heights, MD 20743.

5 RTCM Standard 11901.0 for Maritime Survivor Locating Devices (MSLD), dated Dec. 10, 2004.
6 ITU-R Recommendation M.1371-4, Technical Characteristics for an Automatic Identification System Using
Time Division Multiple Access in the VHF maritime mobile band (2010).
7 See Electronic Filing of Documents in Rulemaking Proceedings, Report and Order, GC Docket No. 97-113, 13
FCC Rcd 11322 (1998).

Send U.S. Postal Service first-class, Express, and Priority mail to 445 12th Street, SW,
Washington DC 20554.
Parties are requested to 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
The request, and comments and reply comments filed in response to this Public Notice are
available for viewing via the Commission's Electronic Comment Filing System (ECFS) by entering the
docket number, WT 13-99. The documents also 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. They may also be purchased from Best Copy and Printing, Inc.,
telephone (800) 378-3160, facsimile (202) 488-5563, TTY (202) 488-5562, e-mail
Alternate formats of this Public Notice (computer diskette, large print, audio recording, and
Braille) are available to persons with disabilities by contacting the Consumer & Governmental Affairs
Bureau at (202) 418-0530 (voice), (202) 418-0432 (TTY), or send an e-mail to
This proceeding has been designated as a “permit-but-disclose” proceeding in accordance with
the Commission's ex parte rules.8 Persons making ex parte presentations must file a copy of any written
presentation or a memorandum summarizing any oral presentation within two business days after the
presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral
ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all
persons attending or otherwise participating in the meeting at which the ex parte presentation was made,
and (2) summarize all data presented and arguments made during the presentation. If the presentation
consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s
written comments, memoranda or other filings in the proceeding, the presenter may provide citations to
such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant
page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them
in the memorandum. Documents shown or given to Commission staff during ex parte meetings are
deemed to be written ex parte presentations and must be filed consistent with rule 1.1206(b). In
proceedings governed by rule 1.49(f) or for which the Commission has made available a method of
electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations,
and all attachments thereto, must be filed through the electronic comment filing system available for that
proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in
this proceeding should familiarize themselves with the Commission’s ex parte rules.
For further information, contact Mr. Jim Shaffer of the Wireless Telecommunications Bureau,
Mobility Division, at (202) 418-0687,
Action by the Deputy Chief, Mobility Division, Wireless Telecommunications Bureau.
- FCC -

8 See 47 C.F.R. §§ 1.1200(a), 1.1206.

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