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Released: February 3, 2010


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 10-223

Released: February 3, 2010




WT Docket No. 10-34

Comment Date: February 24, 2010

Reply Date: March 8, 2010

On November 29, 2009, McMurdo, Ltd. (McMurdo) filed a request for waiver of Section
80.1101(c)(6) of the Commission's Rules1 to permit equipment certification and use of its Smartfind S5
Automatic Identification System Search and Rescue Transmitter (AIS-SART). An AIS-SART is used to
locate a survival craft or distressed vessel by transmitting Global Positioning System (GPS) coordinates to
all AIS-enabled devices within VHF radio range.2
The International Maritime Organization has amended the Global Maritime Distress and Safety
System (GMDSS) regulations to permit AIS-SARTs as an alternative to GMDSS SARTs operating in the
9.2-9.5 GHz (9 GHz) band, effective January 1, 2010.3 Because Section 80.1101(c)(6) of the Commission's
Rules authorizes only SARTs operating in the 9 GHz band, McMurdo seeks a waiver to permit certification
and use of its AIS-SART, which it states meets all international requirements. However, the Smartfind S5
AIS-SART does not meet the technical standards for a GMDSS SART in Section 80.1011.4 McMurdo

1 47 C.F.R. § 80.1101(c)(6).
2 The AIS-SART is programmed from the manufacturer with a unique ID code and receives its position via an internal
GPS antenna. This data is combined and transmitted using the international AIS channels (AIS A – 161.975 MHz and
AIS B – 162.025 MHz) in the maritime VHF band.
3 See IMO Resolution MSC.246(83), “Adoption of Performance Standards for Survival Craft AIS Search and
Rescue Transmitters (AIS-SART) for Use in Search and Rescue Operations.” Additionally, performance and
technical specifications for the AIS-SART were approved by the International Electrical Committee on January 15,
2010. See IEC 61097-14 Ed. 1, “Global maritime distress and safety system (GMDSS) – Part 14: AIS search and
rescue transmitter (AIS-SART) – Operational and performance requirements, methods of testing and required test
4 Specifically, the AIS-SART transmits on frequencies 161.975 MHz and 162.025 MHz using a modulation scheme of
Self-Organizing Time Division Multiple Access (SOTDMA) employing Gaussian minimum shift keying; while the
GMDSS SART transmits on frequencies in the 9 GHz band with a transmission that is pulsed, and the modulation is a
series of twelve sweeps from 9.2 GHz to 9.5 GHz. Also, the AIS-SART’s power is 1 watt compared to 400 milliwatts
for the GMDSS SART.

argues that its device should not be required to meet the GMDSS SART standards, because the device
performs more effectively than other locating transmitters and can be located at greater distances with GPS
precision. McMurdo believes its AIS-SART will enhance marine safety by making search and rescue
operations more efficient and less time-consuming.

Procedural Matters

Comments on the request are due no later than February 24, 2010. Reply comments are due no
later than March 8, 2010. All filings should reference the docket number of this proceeding, WT 10-34.
This proceeding has been designated as a “permit-but-disclose” proceeding in accordance with the
Commission's ex parte rules.5 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.6 More than a one- or two-sentence description of the views and arguments presented
is generally required.7
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:// 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 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). All filings must be addressed to the Commission’s Secretary, Office of the Secretary,
Federal Communications Commission, as follows:
-Effective December 28, 2009, 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


location 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

5 See 47 C.F.R. §§ 1.1200(a), 1.1206.
6 See Commission Emphasizes the Public’s Responsibilities in Permit-But-Disclose Proceedings, Public Notice, 15
FCC Rcd 19945 (2000).
7 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).

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.
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
The request, and comments and reply 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 10-34. They may also be
purchased from Best Copy and Printing, Inc., telephone (800) 378-3160, facsimile (301) 816-0169, e-mail
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
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 -

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