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It’s not clear to me why people’s attitudes towards bureaucracy generally aren’t more like the gun lobby’s: “Dang it! Why shouldn’t I be able to drive a car as fast as it will go? Or walk my pet alligator onto a commercial airplane? Or ride my motorcycle without a helmet everywhere I want? What’s wrong with this country? I can hide a gun in my y-fronts and walk around like Harvey Keitel in Reservoir Dogs, but who’s doing anything about all the other regulations that are crushing us? No one, that’s who! Life, liberty and the pursuit of happiness, right? It’s all there in the Constitution and Declaration of Whatever – it’s a matter of our freedom, F-R-E-E-D-O-M, people!” (are you off your meds? – ed.)
Distress
All bureaucracies have rules. The first rule is, the right hand doesn’t know what the left hand is doing. The second rule is, logic never crosses organizational boundaries, no matter how high the stakes. Let me give you an example. One that may save your life.
Modern marine radios have a function called Digital Selective Calling (DSC) that replaces voice calls, especially for emergencies. Originally designed for commercial traffic, DSC has made its way down the adoption curve all the way to (somewhat expensive) handheld VHF radios. Making distress calls faster, simpler and more accurate is a good thing. Important details like your unique Maritime Mobile Service Identity (MMSI) number and GPS location can be sent with the press of a button. That makes the Coast Guard happy. They will tell you, it’s all the better to find you with.
Responsibility
Radios on board American ships are administered by the Federal Communications Commission. The FCC expects you to have an MMSI number programmed into your DSC-capable radio as part of your ship’s station responsibilities. And that MMSI number better match your boat’s registration documents so that the Coast Guard will know exactly what kind of vessel you have and who they’re dealing with. Your boat’s MMSI will also get programmed into your Emergency Position Indicating Radio Beacon (EPIRB) and Automatic Identification System (AIS). EPIRBs are registered with NOAA at the Department of Commerce, as well as with the International Telecommunications Union (ITU) at the United Nations. Pretty cool, eh?
The UN also administers the Global Maritime Distress and Safety System (GMDSS) which increasingly uses, you guessed it, DSC to assist in search and rescue. Now, almost all of this is optional for boats under 300 tonnes. But we have it all, DSC on our high frequency radio, our VHF and our handhelds. Our MMSI is in our AIS system and our EPIRB. But, and this is a big but, it wasn’t easy getting it there.
Violation
When we bought and registered Aleta, we ended up having to get a new MMSI number. That meant reprogramming everything that had an old MMSI number in it. We bought a new EPIRB (the old one’s battery was up for replacement and the cost difference was negligible). Aleta’s VHF radio has a simple table that allows for easy MMSI updates – oddly in violation of FCC rules. Huh? Violation? Turns out the FCC doesn’t want MMSI numbers to be changed or otherwise messed around with once they’re programmed into the ship’s radio. Those radios stay with the ship and don’t move around. I’ve been told it’s to prevent spoofing, which, I guess, could lead to insurance fraud. Equipment is supposed to be returned to the manufacturer if changes are needed.
When I called our AIS supplier in Germany, they had a process for reprogramming our decade-old system remotely for a nominal fee. That was nifty. Our handheld DSC capable VHF radios had to be sent to California, but for $14 a piece they are ready for updating.
Meanwhile, our awesome ICOM M802 HF radio with DSC wasn’t so easy. When I called ICOM and asked them what I should do about updating the MMSI number, they didn’t really know. Call a dealer – and good luck, they said! WTF? I called dealer after dealer. None of them knew anything about it, or pulled the old, I’ll take your number and get right back to you on that, trick. WTFF? The radio is about the size of a microwave oven and seriously wired into the nav station. Pulling it out and sending it somewhere wasn’t practical. Nor was replacing it. It works just fine and it’s really expensive!
Workaround
There we were. A critical safety component that the Coast Guard cares about (i.e. an accurate MMSI as part of DSC) ensnared by the FCC’s rules for big vessels. No, it doesn’t make any sense. When I eventually found a workaround on the Internet based on some old bootleg software, my conscience wasn’t in the least bit troubled. Particularly, since it meant that we’d be a skosh safer on the high seas. Plus, I do everything I can to keep the Coasties and NOAA happy.
So, if you’re under 300 gross tonnes and need your MMSI updated in your iCOM M802, drop me a line. I’ll happily help you strike a blow for freedom!
love it
Reminds me of a prolonged and frustrating ‘conversation’ with HMRC (Her Majesty’s Revenue and Customs). ‘Customs’ being the operative word. I received an invoice in October (couple of years ago) and immediately send off a cheque by recorder post. The transaction appeared to have been accomplished when I saw a rather large debit on November’s bank statement. Forward on four months. Angry letter from above organisation asking where my payment had gone. I reassured them that they had had it in November and I had a statement to say that it had signed for at the end of October and the cheque cashed. That wasn’t a satisfactory response. Six months of haggling ensued until the cheque appeared in their ether. However, because of the length of time that had passed, I now owed six pounds administrative fee. I argued the toss for a further four months, was charged a late fee of six pounds which I refused to pay and, when asked if I could make up the amount outstanding, I, I replied that it had been their fault and I wasn’t paying the fee but didn’t have much choice about the actual tax charged .. When I added that it had been their mistake, the fastest reply ever recorded from a bureaucratic organisation was: ‘It was only a potential mistake. When I replied that I had the ‘potential, of being run over by a bus every day, I made sure that I was in full control of the Highway Code and therefore was extra vigilant when it came to crossing the road. I realised that sarcasm is not one of the qualities looked for at interview time. Six months later I received a reprieve for the six pounds and a refund of over £400 for administrative errors! Like Marlon, I can hang on for as long as it takes!
Well done! Persistence pays off! There must be a bureaucratic rule about never admitting to an error and blaming the other party. Americans are familiar with this when dealing with health insurance companies.