ࡱ> 463 &bjbj .0"lRRRRRRRfHHHH Tftttttttt Rttttt RRtt   t.RtRt t  RRth AAfHR0cc ffRRRRRead The Regulations! You Might Learn Something Many years ago I was locked away in a Bournemouth hotel with a solicitor and an ex-member of the Flying Squad. I was being taught the facts of life of our vocation. What I could, or could not (legally) do to any poor unfortunate who might cross my path, and how to catch them at it. I was also being taught the principles of regulation. To read through the words and identify their meaning; their purpose, what the regulator was seeking to achieve through the control. Much like a student reads Shakespeare, only more interesting! But perhaps most important of all, I was taught to guard against falling into the trap of believing regulation is a deity. Good regulation means whatever it needs to mean in order to maintain its fundamental purpose. Regulation must guide, never preach, nor ever be preached from. Alas, there are many preachers out there. Over the years I lost count of the number of times I read or heard statements made about the GMDSS regulations, which were utter rhubarb; It is written by the almighty one (and without wishing to blow my trumpet too hard, they probably meant me!) that this must be done to comply with the GMDSS, and to do anything other is the work of Lucifer himself!. Who is the latest wretch to be added to my list of blocks, stones, worse than senseless things who knew not the GMDSS? Time for the editor of this publication to stand up and be counted I fear; your recent statements regarding INMARSAT-C were tosh. There is nothing in regulation requiring any ship to install and use INMARSAT-C, at least not in SOLAS. The regulation requires a ship be able to receive maritime safety information (MSI) using INMARSATs enhanced group calling (EGC) system if it operates in sea area A3. And as I have in my possession a photograph of a stand-alone EGC receiver taken on a ship that otherwise fully conformed with the GMDSS with not an INMARSAT-C in sight, I think we can safely say: Mr Editor, Thou art proclaimed a fool, I think. But your mistake was understandable. To the best of my knowledge, this may have been the only example of a stand-alone EGC receiver ever built. All ships have invariably used EGC equipment incorporated into INMARSAT-C terminals. Why should this be the case? Intuitively a dedicated EGC receiver must be cheaper than an INMARSAT-C no display or keyboard for one. And the shipping industry is noted for wasting money. Batteries. GMDSS regulation also requires ships maintain communications when all normal, and emergency power is lost. If you wish to do this with INMARSAT A or B, fine, there are no regulations precluding it, but I suggest you buy a ULCC first. You may need one to carry the batteries for the aerial stabilisation system. A little exaggeration perhaps, but suffice to say providing a reserve power supply will make a fair dent in the wallet, and there can be no doubt the objective, maintaining communications in a dead-ship situation, can equally be fulfilled by an INMARSAT-C operating quite happily on a cheap(ish) dry-fit. And, of course, you get an EGC receiver thrown in for free! (Lots of other things too, like the ability to automatically identify and track the ship, but thats another issue.) In other words, it is the interaction of economics and regulation, not the regulation per se that ensures virtually every ship at sea, certainly every ship operating on global trade is now fitted with an INMARSAT-C, and would have great difficulty complying with the GMDSS regulation without one. But is it economics or regulation that has primarily determined this? Providing the regulation fulfils its objective, a rather academic point. Nevertheless a prescient regulator should maintain a close overview to evaluate the hazards posed by change and, from that, whether action is needed to the regulation - to address the potential risk involved. And change is coming with INMARSAT Fleet. With a solid-state antenna, Fleet is readily operable off a modest battery supply not much larger than that needed for an INMARSAT-C. Were someone to now come along with a stand-alone EGC receiver, providing the overall costs of this equipment plus the reserve supply for the Fleet is than an INMARSAT-C package, there is no economic case for using the latter to comply with GMDSS regulation. Does this pose a risk? From a regulators perspective, no, at least not for the foreseeable future. It makes no odds whether a ship uses an INMARSAT-C or a dedicated EGC to receive MSI. Thus the objective continues to be fulfilled despite the evolution in technology without the need to make change to regulation. Indeed a mark of good regulation is its ability to deal with a dynamic without being dynamic. In the longer term, if ships adopting Fleet do withdraw from INMARSAT-C, the financial viability of the latter system could be marginalized to some degree. This may have its own set of consequences for EGC. However, this has to be balanced with the other benefits. After all, INMARSAT Fleet is clearly superior to INMARSAT-C for rescue coordination communications so is it no bad thing to see INMARSAT-C being replaced? One of the reasons why the modern, proactive regulator should be more than proficient in risk assessment! On balance, I think it is fair to conclude GMDSS regulation is good. What makes it particularly good, though, is it has continued to allow the system to evolve. Up to a point, it imposes no barriers to technological change; although satellite communication providers other than INMARSAT might argue otherwise. Which is actually the finest endorsement any regulation can receive, as no regulation should ever stand in the way of evolution. And nothing is evolving more rapidly at the moment than communications technology. After all, in the time taken for the valves on our lamented HF transmitters to cool down, we have seen mobile data go from 1G, to 2G, to 2.5G to, if you believe the hype, 3G, although I have to accept, notwithstanding my own interest in 3G, it looks increasingly likely as if the next technology leap will be to, off-the-shelf and reliable IEEE 802.11 platforms Wireless Local Area Networks (LAN) to you and I. This is technology is already finding favour in ship-to-shore VTS based communications. Who knows what other safety benefits might be brought by this burgeoning, ultra-high bandwidth, low-cost and secure technology; the latest generations of which, through a certain irony, operate in the marine 5 GHz band!? If the regulations permit allow it to develop, of course. Unfortunately regulation can also be bad. The corollary, the mad, the bad and the crass regulation is that that has no ability to manage a dynamic. Where even the smallest perturbation in the system results in regulatory apoplexy, yet somehow, despite the amendments made, it never actually ever achieves its objective. But by far the worst regulation of all, and certainly a disaster for any industry whose lifeblood is change, is that which prescribes. Regulation that believes it needs to preach. Regulation that ordains unequivocally, and without latitude, that there can only be one (technological) solution to fulfil an objective and no other. Sometimes this is a necessary evil; maintaining compatibility in distress communications in the earliest generations of marine radio technology being one example the requirement to use, and only use 500 kHz. In the modern context, however, it would be difficult to identify any place for such stricture if only because it leaves the regulator, never mind those subject to control no option. From the date the prescription is set, should anyone attempt to use any other technology, notwithstanding their motive or the potential benefits they may be trying to bring to the system, including improvements in safety, they are, and must for all time be damned. Should there be anyone out there who believes they can ignore the direction issued by the regulator, once it has chosen to prescribe technology, then there are those who have similarly spent many hours in a hotel room in Bournemouth with a solicitor and an ex-member of the Flying Squad who will do everything in their not inconsiderate powers to stop you. Because, in their reading, the disciples (sorry about the biblical metaphors) will have no option but to conclude the principle meaning of regulation is to achieve an absolute monopoly for the technology so chosen, and to seek and destroy anything that does not conform; another week in Bournemouth! After all, if that is not what the regulator demands, why else would it have adopted the prescription? There is no other reason. And if this what they have done, certainly when it comes to anything to do with the evolution of information exchange at sea, Thou art proclaimed a fool, I think. /1  y&&&5\6] CJ^JaJ 01GHbc /0MN&cdP Q $!%!""M$N$&,1h. A!"#$%  i@@@ Normal CJOJQJ_HaJmH sH tH <A@< Default Paragraph Font66 Footnote TextCJaJ8&@8 Footnote ReferenceH*.U@. 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