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Mobilarm Submariner Beacon Waiver Request Public Notice

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Released: January 13, 2012


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 12-46

Released: January 13, 2012




WT Docket No. 12-6

Comment Date: March 5, 2012

Reply Date: March 26, 2012

On September 19, 2011, Mobilarm Ltd. (Mobilarm) filed a request for waiver of Part 80 of the
Commission's Rules1 with respect to the V200 survival beacon device.2 On January 5, 2012, Mobilarm
submitted a revised waiver request.3 The V200 is a lightweight locator beacon designed for use in
situations of submarine escape and abandonment. Upon reaching the water surface, the V200 transmits a
Mayday voice message on frequency 156.8 MHz, a digital selective calling (DSC) Mayday voice message
and Global Positioning System coordinates on frequency 156.525 MHz, an Automatic Identification
System message on frequency 161.975 MHz, and a direction-finding signal on frequency 121.5 MHz.
The V200 is similar to a Maritime Survivor Locating Device (MSLD),4 except that it does not incorporate a
DSC receiver. Mobilarm requires a waiver of Part 80 because currently there are no provisions in the rules
for such a device.
Mobilarm states that it intends for the V200 to be used only by the United States Navy and by
private contractors working for the Navy in the service, maintenance, and recovery of deep-sea assets such
as submarines. It indicates that it will not market or sell the device to any entity other than the Navy or a
Navy contractor. It therefore seeks a waiver to permit FCC equipment certification of the device. We seek
comment on the waiver request.

1 47 C.F.R. Part 80.
2 Letter dated Aug. 30, 2011 from Lindsay Lyon, Chief Executive Officer, Mobilarm Limited to Stan Lyles, Office
of Engineering and Technology, FCC.
3 Letter dated Jan. 5, 2011 from Lindsay Lyon, Chief Executive Officer, Mobilarm Limited to Tim Maguire, Office
of Engineering and Technology [sic], FCC.
4 The Radio Technical Committee on Maritime Services has developed a standard for MSLDs entitled “RTCM
Recommended Standards for Maritime Survivor Locating Devices (MSLD) Version 1.0,” developed by Radio
Technical Committee on Maritime Services (RTCM) Special Committee number 119.

Procedural Matters

Comments on the request are due no later than March 5, 2012. Reply comments are due no later
than March 26, 2012. All filings should reference the docket number of this proceeding, WT 12-6.
This proceeding has been designated as a “permit-but-disclose” proceeding in accordance with the
Commission's ex parte rules.5 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
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.
The request, and comments and reply comments filed in response to this Public Notice, will be
available for public inspection and copying in the Commission's Reference Center, Room CY-A257, 445
12th Street, S.W., Washington, D.C. 20554, and via the Commission's Electronic Comment Filing System
(ECFS) by entering the docket number, WT 12-6. Copies of the request are also available from Best Copy
and Printing, Inc., telephone (800) 378-3160, facsimile (301) 816-0169, e-mail
Comments may be filed using the 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 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 , 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 one copy 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). All filings must be addressed to the Commission’s Secretary, Office of the Secretary,
Federal Communications Commission, as follows:

5 See 47 C.F.R. §§ 1.1200(a), 1.1206.

-All hand-delivered paper filings for the Commission’s Secretary must be delivered to FCC
Headquarters at 445 12th St., S.W., Room TW-A325, Washington, DC 20554. All hand deliveries must be
held together with rubber bands or fasteners. Envelopes must be disposed of before entering the building.
The filing hours at this location are 8:00 a.m. to 7:00 p.m.


This is the


where hand-delivered or messenger-delivered paper filings for the Commission’s Secretary will be
accepted. The Commission’s former filing location at 236 Massachusetts Ave., N.E., is permanently closed.
-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, DC 20554.
-All filings must be addressed to the Commission's Secretary, Office of the Secretary, Federal
Communications Commission.
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,
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
For further information, contact Mr. Tim Maguire of the Mobility Division, Wireless
Telecommunications Bureau at (202) 418-2155 or via e-mail to
Action by the Deputy Chief, Mobility Division, Wireless Telecommunications Bureau.
- FCC -

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