The FCC administers an exemption program for various Part 80 carriage requirements for qualifying vessels. Ship exemption applications are filed in ULS for a 4-year exemption. These exemptions may be based on various factors to be exempt from a variety of requirements to including, but not limited to, the utilization of uncertified equipment that may perform functions equivalent to vessel requirements, special vessel class exemptions, or the number of FCC licensed personnel required on the craft. Licensees must provide justification for the exemption and include the information requested below:

The radio station requirements from which the exemption is requested, such as:

  • A particular piece of required equipment;
  • To allow non-GMDSS certified equipment because it is functionally equivalent to the required GMDSS certified equipment;
  • FCC licensed operator requirements; or
  • Other requirements due to the circumstances of the vessel.

Detailed description of the voyages for which the exemption is requested, including:

  • Maximum distance from nearest land in nautical miles;
  • Maximum distance between two consecutive ports in nautical miles;
  • Names of all ports of call and an indication of whether travel will include a foreign port; and
  • List the specific requirement you are asking an exemption from and supporting information as to why it should be considered. 

Reasons for the exemption:

  • Size of vessel;
  • Variety of radio equipment on board;
  • Use of equipment that does not meet the requirements, but serves as a functional equivalent;
  • Limited routes; and/or ·Conditions of voyages.

Documents can be attached to the application to support the exemption request.  At a minimum, supporting information should include a description of the equipment that is currently onboard and a statement that the equipment is installed and operating properly.  Depending on the class of vessel, this could include the following types of equipment:

  • VHF Radio Installation (indicate if GMDSS-approved);
  • Single Side-Band (SSB) Radio (indicate the bands of operation, and indicate if GMDSS-approved);
  • Category 1, 406 MHz EPIRB (indicate if GMDSS-approved);
  • NAVTEX Receiver (indicate if GMDSS-approved);
  • Survival Craft VHF (indicate if GMDSS approved);
  • 9 GHz Radar Transponder (indicate if GMDSS-approved);
  • Search and Rescue Transponders (SARTs) (indicate if AIS- and GMDSS-approved)
  • Ship Earth Station; (include details on the type and model and indicate if GMDSS- approved)
  • 2182 Radiotelephone Auto Alarm
  • Reserve Power Supply (capability); and
  • Any other equipment (i.e. satellite phone make and model.)

Finally, attach a copy of the most recent U.S. Coast Guard Certificate of Inspection and/or FCC-licensed inspector’s report if available.

Tuesday, October 4, 2022