FCC 89-351 Federal Communications Commission Record 5 FCC Red
No.
1
improvements in the computed location of EPIRBs and
ELTs are directly related
to
carrier frequency stabilityY
RTCM suggests, therefore, that EPIRBs that meet the new
modulation characteristics be labeled in such a manner
that individuals purchasing EPIRBs will be able
to
iden-
tify those EPIRBs with the improved satellite detection
capability.
13
The requirement
to
label EPIRBs
is
sup-
ported by NASA.U The United States Coast Guard
(USCG) filed comments (USCG Comments) supporting
RTCM's petition and stated that requiring the labeling of
EPIRBs that meet the improved satellite detection
char-
acteristics would be
an
important addition to the Com-
mission's Rules.
15
8.
The USCG suggested making the changes proposed
by
RTCM administratively rather than through a rule
making proceeding.
16
Additionally, the USCG states that
it
is
unclear whether changes made by manufacturers
to
comply with the power distribution requirements for
EPIRBs will require a new application for type accep-
tance and requests that the Commission issue guidance
to
manufacturers concerning type acceptance for modified
EPIRBs.
17
9.
In a separate but related matter, the National Trans-
portation Safety Board (NTSB) recommended changes
to
the Commission's EPIRB Rules. As a result of its inves-
tigation into the sinking of the fishing vessel WAYWARD
WIND
18
NTSB
recommends that the Commission require
labeling all newly manufactured EPIRBs with battery
in-
stallation directions; the elimination
of
water activated
batteries in EPIRBs that do not float;
19
and, establishing
an inspection program for EPIRBs.
20
See
National Trans-
portation Safety Board Safety Recommendation M-89-6
through -8 dated February I, 1989.
IV.
DISCUSSION
10.
The proposals before us are intended to improve
performance, clarify and eliminate unnecessary rules, and
allow users
to
identify EPIRBs
and
ELTs that meet the
requirements for improved satellite detection. Because
EPIRBs and EL
Ts
are life saving devices used worldwide,
it
is
vitally important that
our
rules permit them
to
operate
as
effectively
as
possible
and
to
ensure that when
the devices are activated, search and rescue teams will
detect the distress signal and locate the ships
or
aircraft in
distress.
Further,
we believe the public interest will be
better served through a broader rule making proceeding
inviting public comment
on
modification and clarification
of EPIRB and EL T rules rather than an administative
proceeding incorporating the RTCM petition
as
suggested
by the USCG.
We
have taken similar steps in the past
to
improve EPIRB and EL T operation and believe the pub-
lic interest will
be
served if
we
do so again.
11. In Docket 87-133
we
modified the carrier power
requirements for EPIRBs and ELTs when operating with
an A3N emission
to
improve detection. While all EPIRBs
and ELTs are required
to
operate with A3N emission,
they are permitted
to
use other emissions
as
well. RTCM
and NASA supported extending the carrier power
require-
ments
to
all emissions.
We
agree. This should increase the
likelihood that EPIRBs and
EL
Ts, regardless of the type
of emission used to transmit a distress signal, will be
detected. Therefore,
we
propose that newly manufactured
EPIRBs and ELTs meet the carrier power requirements
168
adopted in PR Docket 87-133 for
an
A3N emission for all
emissions irrespective of whether there
is
modulation
present.
12.
We
are also proposing that the 121.500 MHz "hom-
ing" transmitter required
as
part of the 406 MHz EPIRB
21
meet the same carrier power characteristics. Although the
121.500 MHz
homer
is
restricted in power to
25
mW
22
and
is
intended
to
be used by search and rescue personnel
for close in direction finding, the
USCG and FAA have
indicated that requiring the "homing" transmitter
to
meet
the carrier power characteristics for improved satellite
detection adopted in PR Docket 87-133 could result in its
detection by the
COSPAS-SARSAT system and increase
the likelihood of lives being saved.
We
seek specific com-
ments regarding the proposed
output
power characteris-
tics for the 121.500 MHz "homing" transmitter required
as
part of the 406.025 MHz EPIRB.
13.
We
are also proposing
to
extend the carrier power
characteristics
to
all Class S EPIRBs. Currently, only
Class S EPIRBs that float must meet the improved sat-
ellite detection requirements. Class S EPIRBs not re-
quired to float do not have to comply with the improved
satellite detection requirements. Because Class
S EPIRBs
are intended specifically for stowage
on
survival craft for
use in potentially life threatening situations
we
propose
that both types must meet the improved satellite detection
requirements
to
increase the likelihood that the distress
signals transmitted will be received by the
COSPAS-
SARSA
T system.
14. Additionally,
we
are proposing
to
require that
EPIRBs using water activated batteries must float. EPIRBs
that use water activated batteries and do not float are
potentially unsafe since they have to be in the water
to
operate and,
if
not buoyed properly, will sink. Further,
we
are proposing rules requiring that the battery installa-
tion instructions
be
displayed
on
the EPIRB case.
As
previously noted
by
the
NTSB
an
improperly installed
battery can affect how an EPIRB floats. Requiring battery
installation instructions
on
a label will reduce the in-
cidence of improperly installed batteries and increase
their effective operation in
an
emergency.
15.
We
are proposing rules that eliminate all reference
to
FAA documents TSO-C91a and
D0-183
from the
EPIRB rules in Part
80.
Those documents are specific to
ELTs and are not applicable for EPIRBs.
Further,
the
elimination of reference
to
TSO-C91a and
D0-183
in the
EPIRB rules removes the requirement for EPIRBs to
have symmetric sidebands
as
requested by RTCM. Also,
we
are proposing rules eliminating the requirement that
EL
Ts
have symmetric sidebands centered about the car-
rier frequency 121.500 MHz and 243.000 MHz.
As
pre-
viously noted, NASA stated that symmetric sidebands do
not enhance detection by the
COSPAS-SARSAT system
and do not appear
to
be necessary.
16.
In
order to reduce the burden of testing EPIRBs for
type acceptance,
we
are proposing that the reduced radi-
ation level required for the Class A EPIRB test switch be
measured at
30 meters (98 feet) and referenced
as
a power
level instead of the
current
46
meters and field strength.
See
Section 80.1053(b)(3),
47
C.F.R. § 80.1053(b)(3).
There
is
no change in the technical standard, and
we
believe that this testing will be less burdensome
on
EPIRB manufacturers.
Further,
to be consistent with the
Safety Convention requirement for drop tests of EPIRBs
from
20 meters
we
are proposing that Class A EPIRBs
meet the technical requirements after free fall into water.