MMSI for Portable VHF in international waters

[CMonster]

Hi
I'm about to purchase a portable VHF with DSC in the USA.
I already have a DSC radio on the sailing boat with an MMSI, registered with Ofcom as I am UK flagged sailing boat.

So, I looked on Ofcom's website.
They don't want me to put the MMSI of the mothership into the portable.
They do want me to apply for an MMSI number for the portable and it will have a different prefix so that the CG will know that I am portable, not a fixed unit .

But I am not in the UK. I will be in Central America for now. No intention to sail to the UK and I can't fly with this unit due to the Li ion battery. There is no chance the UK CG is going to pick up any DSC alert from me.

According to Ofcom and their notes for Ship Radio guidance notes for licensing:
https://www.ofcom.org.uk/__data/assets/pdf_file/0024/16359/of168a.pdf

2.4 VHF/DSC portables are only licensed for use in UK territorial waters
and
3.5 Applicants should note that the use of VHF/DSC Portable maritime radio
equipment under a Ship Portable Radio Licence is only permitted in UK
territorial waters.

So, I can't win.
To me this is an important safety function to alert the mothership if I am in trouble in the dinghy, or in the water, or to alert a passing ship if I am in my liferaft.

Advice appreciated.

I advise the people that write these rules to get out more.

 

[GHA]

Mmsi for handhelds in the UK is a mess, it would be well worth phoning up ofcom to see what they say in person, they're very helpful.

 

[RichardS]

I'm not sure what the problem is.

I have a UK registered boat with a fixed DSC and a portable DSC, both registered with different 235******** UK MMSI numbers. It both cases it was a simple on-line process.

The boat will never sail in UK waters.

Richard

 

[GHA]

I'm not sure what the problem is.

I have a UK registered boat with a fixed DSC and a portable DSC, both registered with different 235******** UK MMSI numbers. It both cases it was a simple on-line process.

The boat will never sail in UK waters.

Richard

Here ..Which may or may not be a problem in the real world.

[FONT=&quot]Do I need a special licence? Will my existing Ship Radio Licence cover it? Must I vary my existing licence?[/FONT]
[FONT=&quot]You must have a separate Ship Portable Radio Licence for each hand held VHF DSC radio. This is because each individual radio is given a separate identity. The apparatus must not be used outwith UK territorial sea. So, it cannot be covered by a normal Ship Radio Licence, as this does not impose any territorial restrictions.
[/FONT]

 

[prv]

As I understand it, the problem is that the international rules don't allow for DSC portables. They weren't thought of when the rules were written, and the authorities that need to agree in order to change them haven't got together and discussed it since.

After a few years stalling in the hope that the ITU would fix the matter properly, Ofcom gave up waiting and made up some rules to register DSC portables in what seemed a sensible way. However, as a U.K. agency they obviously don't have the right to unilaterally define what's legal worldwide, so they consider their self-issued DSC portable licenses to only be valid in U.K. waters and they make sure to tell you this when you apply for one.

In practice, it seems highly unlikely that anybody else will care. Just take out a UK station license for the portable and ignore the "territorial waters only" bit.

Pete

 

[RichardS]

Here ..Which may or may not be a problem in the real world.

[FONT="][URL="https://www.ofcom.org.uk/manage-your-licence/radiocommunication-licences/ships-radio/vhf-faq#"]Do I need a special licence? Will my existing Ship Radio Licence cover it? Must I vary my existing licence?[/URL][/FONT]
[FONT="]You must have a separate Ship Portable Radio Licence for each hand held VHF DSC radio. This is because each individual radio is given a separate identity. The apparatus must not be used outwith UK territorial sea. So, it cannot be covered by a normal Ship Radio Licence, as this does not impose any territorial restrictions.
[/FONT]

Why do you see that as a problem?

Are you thinking that if you make a DSC distress call outside UK waters the local rescue service will respond to it if it's from a 235 number belonging to a fixed radio and ignore it if it's a 235 number belonging to a hand-held? Serious question.

Richard

 

[prv]

Why do you see that as a problem?

I didn't think he did?

Pete

 

[knuterikt]

As I understand it, the problem is that the international rules don't allow for DSC portables. They weren't thought of when the rules were written, and the authorities that need to agree in order to change them haven't got together and discussed it since.

After a few years stalling in the hope that the ITU would fix the matter properly, Ofcom gave up waiting and made up some rules to register DSC portables in what seemed a sensible way. However, as a U.K. agency they obviously don't have the right to unilaterally define what's legal worldwide, so they consider their self-issued DSC portable licenses to only be valid in U.K. waters and they make sure to tell you this when you apply for one.

In practice, it seems highly unlikely that anybody else will care. Just take out a UK station license for the portable and ignore the "territorial waters only" bit.

Pete

ITU has already given guidelines for this.
Read "Assignment of identities for handheld VHF transceivers with digital selectivecalling and global navigation satellite system"
https://www.itu.int/dms_pubrec/itu-r/rec/m/R-REC-M.585-7-201503-I!!PDF-E.pdf

 

[GHA]

Why do you see that as a problem?

Are you thinking that if you make a DSC distress call outside UK waters the local rescue service will respond to it if it's from a 235 number belonging to a fixed radio and ignore it if it's a 235 number belonging to a hand-held? Serious question.

Richard

Which may or may not be a problem in the real world.

I've no idea if it is a problem or not. It was (obviously a quote, I thought ) a quote to Ofcom documentation.

https://www.ofcom.org.uk/manage-your-licence/radiocommunication-licences/ships-radio/vhf-faq

 

[RichardS]

I've no idea if it is a problem or not. It was (obviously a quote, I thought ) a quote to Ofcom documentation.

https://www.ofcom.org.uk/manage-your-licence/radiocommunication-licences/ships-radio/vhf-faq

So what was your post # 2 all about ..... if you don't think there's a problem why say "it's a mess" and advise the OP to phone Ofcom?

Richard

 

[prv]

ITU has already given guidelines for this.

Thanks - that's news to me, and quite interesting.

Note that it was only published last year, whereas the Ofcom text that GHA posted was dated 2010. So it seems that the ITU eventually caught up - but now Ofcom are the ones trailing behind!

The ITU now say that DSC portables should be assigned an MMSI-like number (they maintain that it isn't technically an MMSI but the difference is purely theoretical) starting with "8" followed by the MID country code, so a UK-registered portable would be 8235xxxxx.

Unfortunately this differs from Ofcom's interim rule of issuing MMSIs starting 2359xxxxx. Of course Ofcom couldn't really have done anything else as they can't define new first-digit uses, and the ITU presumably didn't want to formalise <mid>9xxxxx because it can't be sure no other country hasn't already been assigning MMSIs in that range. Avoiding this kind of anomaly was exactly why Ofcom was reluctant to start registering DSC portables back then, but they eventually felt they had to give up waiting and do something.

I know the blurb for DSC Ship Portable licenses warned you that they might have to change your MMSI if this happened. I wonder whether they actually will? I suspect not. But I also wonder when they will start issuing new licenses following the ITU format instead of the local one?

Pete

 

[GHA]

So what was your post # 2 all about ..... if you don't think there's a problem why say "it's a mess" and advise the OP to phone Ofcom?

Richard

Forget it, go outside and argue with a seagull instead.

 

[RichardS]

Forget it, go outside and argue with a seagull instead.

Lol. Thought so! :encouragement:

Richard

 

[RichardS]

I didn't think he did?

Pete

GHA posted a view in #2 that handheld licensing in the UK was a mess.

In #3 I asked what the problem was with the licensing.

GHA answered in #4 with what he thought the problem might be.

I asked GHA in #6 why he thought that might be a problem.

And after that it all went to hell in a handcart.

Richard

 

[testmonkey]

They don't want me to put the MMSI of the mothership into the portable.
......
To me this is an important safety function to alert the mothership if I am in trouble in the dinghy, or in the water, or to alert a passing ship if I am in my liferaft.

Legalities aside - from technical point of view if you want to be able to alert the mothership from your dinghy then you will need different MMSI in the two DSC sets. If both units have the same MMSI the mothership DSC unit will ignore the handheld DSC distress message - you cannot DSC call your own MMSI. Or just try that on board a ship with two DSC units with same MMSI and see what happens.

 

[st599]

ITU require every member state to ratify a draft before it becomes a worldwide standard.

It's not Ofcom or ITU dawdling, it's certain member states.

 

[Momac]

2.4 VHF/DSC portables are only licensed for use in UK territorial waters
and
3.5 Applicants should note that the use of VHF/DSC Portable maritime radio
equipment under a Ship Portable Radio Licence is only permitted in UK
territorial waters.

So, I can't win.
To me this is an important safety function to alert the mothership if I am in trouble in the dinghy, or in the water, or to alert a passing ship if I am in my liferaft.
.

Imagine you had departed from the UK with the fixed DSC radio with its UK MMSI and the handheld radio with its UK MMSI having the prefix number.

On arrival where you are now what would you need to do to legally use the radio?

I suspect the UK license may well be accepted , presuming you are just visiting . Indeed will anyone know or care what MMSI you have in your handheld radio as long as you use it in accordance with the UK license .

.




.

 

[rogerthebodger]

Legalities aside - from technical point of view if you want to be able to alert the mothership from your dinghy then you will need different MMSI in the two DSC sets. If both units have the same MMSI the mothership DSC unit will ignore the handheld DSC distress message - you cannot DSC call your own MMSI. Or just try that on board a ship with two DSC units with same MMSI and see what happens.

My DSC HH and my DSC fixed radios have the same MMSI number and I have made ship to ship calls, position requests and position reports between these radios both ways and both respond as expected.

Not done a distress call but don't see why it should be different.

Our authorities do not know what they are doing and see this as yet another opportunity to make money from the general public.

 

[prv]

ITU require every member state to ratify a draft before it becomes a worldwide standard.

It's not Ofcom or ITU dawdling, it's certain member states.

Oh - is the ITU document linked above a draft, then? It doesn't obviously say so on the front, but I'm certainly not familiar with their document handling processes. Is a "recommendation" a sort of draft precursor to a regulation or something?

That would certainly explain why Ofcom haven't changed their approach yet.

Pete

 

[prv]

Imagine you had departed from the UK with the fixed DSC radio with its UK MMSI and the handheld radio with its UK MMSI having the prefix number.

On arrival where you are now what would you need to do to legally use the radio?

If the handheld is on a Ship Portable license and not on the Ship Station license then there is nothing you can do. Whether you carried it from the UK or fitted it in South America is not relevant.

Indeed will anyone know or care what MMSI you have in your handheld radio as long as you use it in accordance with the UK license.

But you cannot use it in accordance with the UK license, because one of the license terms is that you only use it in UK waters.

To be clear, this is purely a discussion about regulatory pedantry, not practicality. The practical answer is to register it on a Ship Portable license and use it wherever you are, nobody will care.

Pete