| August 24, 2000, with updates in blue and red
during May 2007
GMRS Pirates
from Across the Sea
"Just when you
thought it was safe
to get back on the air."
by Doug Smith, KAF9830,
and President, Personal Radio Assn., Inc
In early 2000, GMRS licensees in the
San Francisco Bay Area began hearing mixed English and foreign language radio
traffic on GMRS frequency 467.575. Since this is a repeater input, it was
immediately assumed the radio traffic originated with unlicensed users, or
pirates. Three such occurrences have been documented between January and
August. One in the Oakland/San Francisco area, another in the Port of
Sacramento, and the most recent at the Port of Benicia. Listening over a four
day period to the Benicia pirate it was discovered the radio operators were all
carrying hand-held radios aboard ship. Operators made reference to leaning over
the starboard side of the boat and used other seafaring terms.
NorCal GMRS licensees, an ad-hoc group
of GMRS repeater owners, user groups, and interested licensees were actively
attempting to identify the source of the signals. One weekend the signal was
determined to be from the area around the Port of Sacramento. Doppler DF was
used to get within less than a mile of the signal until the operators stopped
using their radios. At a subsequent appearance of the pirate, a beam heading
taken from the Martinez, CA marina pointed directly at the docks of the Port of
Benicia under the Carquinez Bridge. Given the content of the radio traffic, and
the points where activity was present, NorCal assumed they were dealing with a
returning vessel or multiple vessels that visit California water ways.
As luck would have it, the day that
NorCal visited the Port of Benicia the radio activity on the GMRS repeater
input had ceased. The boat had sailed. That wasn't the end of the story
however.
As you might have guessed I was the one
who made the last frustrating trip to the Port of Benicia. I was determined to
find out why someone would select 467.575 as a ship-board radio frequency. It
was a dumb choice since 462.575/467.575 has 4, maybe 5 very high level
repeaters in the Bay Area. One on Mt. Diablo, one or two in Santa Clara, and
another in the hills above San Mateo. A local radio shop would have to know a
pirate like this would be noticed and challenged. I knew though, that
conditions like this had not stopped unscrupulous radio companies from putting
commercial business users on local repeater inputs before. NorCal has been
instrumental in removing at least four prior repeater input pirates placed in
service by prominent two-way radio engineering companies. This abuse of law and
privilege is one the two-way radio industry's dirty little secrets.
There was something different or odd
about this particular use of 467.575. Three times NorCal had heard activity
near the water and twice had confirmed the activity was coming from different
port locations in Central, California. It was time to do a little research.
This pirate was probably a ship from Europe or the UK. The frequency 467.575 is
a mandatory ship's radio channel for large boats registered in the UK. European
vessels are also authorized to use it. The channel, 467.575 is one of two GMRS
repeater inputs, in the USA, used for on-board ship radio traffic in other
parts of the world. The other GMRS channel used by foreign shipping is
467.550.
Enter the Internet
Given my suspicions, I went to my
favorite Internet search engines and looked for references to
"467.575." The first site I found was a scanner enthusiast website
titled "The Radio Spectrum UK Allocations. " This
site listed 457.575 to 467.575 as frequencies for ship-board communication.
After more searching I found the website of the European Radio Communications
Office. The ERC had an official European frequency allocation
document that provided detailed information about the US GMRS frequencies used
as ship-board channels elsewhere in the world. This link is to the
European Radiocommunications Committee ERC Report
25. You will need the Adobe Acrobat reader to view this document.
(The Acrobat reader can be obtained at Adobe.com)
ERC Report 25 is formally titled,
"Frequency Range 29.7 to 105 GHz and Associated European Table of
Frequency Allocations and Utilisations, Brussels, June 1994, revised in Bonn,
March 1995, and in Brugge, February 1998. This document makes the following
reference to approved uses for 467.550 and 467.575 in Europe. I have also
listed one other band of approved frequencies for reasons you will understand
in a moment:
On board communications
457.525 - 457.575 MHz, (maritime).
On Board communications
467.525 - 467.575 MHz, (maritime.)
I later visited the website of Her
Majesty's Maritime
and Coast Guard Agency, the MCA. The UK Coast Guard had a form to
fill out if a site visitor had questions about maritime regulations so I asked
about use of 467.550 and 467.575 in American ports.
NTIA Information
In the meantime I located information
about this allocation from an American source. The following is taken from the
National Telecommunications and Information Administration, Office of Spectrum
Management, International Table of Frequency Allocations Footnotes,
Footnote Number 669-- "In the maritime mobile
service, the frequencies 457.525 MHz, 457.550 MHz, 457.575 MHz, 467.525 MHz,
467.550 MHz and 467.575 MHz may be used by on-board communication stations. The
use of these frequencies in territorial waters may be subject to the national
regulations of the administration concerned. The characteristics of the
equipment used shall conform to those specified in Appendix 20." Footnote
670 further describes the allocations, "In the territorial waters of
Canada, the United States and the Philippines, the preferred frequencies for
use by on-board communication stations shall be 457.525 MHz, 457.550 MHz,
457.575 MHz and 457.600 MHz paired, respectively, with 467.750 MHz, 467.775
MHz, 467.800 MHz and 467.825 MHz. The characteristics of the equipment used
shall conform to those specified in Appendix 20.
This means of course, that in the
United States, foreign vessels are not permitted to use radio frequencies
allocated for use by GMRS. They are allowed to use other radio channels
according to Footnote 670.
A Word from the MCA
GMRS Web Magazine received a very
detailed email message from Simon Cockburn, Head of Radio Safety for the MCA
(UK Coast Guard) regarding the use of these radio frequencies. A copy of the
letter is available as a Word document - right click here and save to your disk. Mr Cockburn
said in his letter, "In the UK this frequency is used by our Department of
Trade and Industry and on board ships on a primary basis." He went on to
list the various international regulations associated with the use of GMRS
channels in the US as maritime channels elsewhere:
- ITU Radio Regs Vol 1 Article S5.287
allocates 467.575 MHz as one of the channels for on-board communications within
the Maritime Mobile Service.
- ITU Radio Regs Vol 1 Article S5.288
does not list 467.575 MHz as a preferred channel for use within US Territorial
Waters.
- (UK Regs) Both MPT 1253 & 1254
state that portable equipment for on-board communications on seagoing ships
shall be fitted with at least the channels 467.525 MHz, 467.550 MHz &
467.575 MHz.
- ETSI (European) specification ETS 300
720, which supersedes the UK MPT's, includes 467.575 MHz as one of six channels
which must be fitted to UHF on-board communications systems and
equipment.
In the opinion of Mr. Cockburn,
"It would appear from Article S5.287 that the NTIA, on behalf of the US
Government, can regulate the use of this frequency in US territorial waters. I
assume the Office of Spectrum Management at the NTIA would be able to assist
you further. "
Now Comes FRS Channel 8!
The ITU Radio Regulations citing the
allocations were also provided by the MCA. There was an additional surprise
contained in the rule. Family Radio Service channel 8, or 467.5625 is also
allocated for on-board ship communication! "S5.287 In the maritime mobile
service, the frequencies 457.525 MHz, 457.550 MHz, 457.575 MHz, 467.525 MHz,
467.550 MHz and 467.575 MHz may be used by on-board communication stations.
Where needed, equipment designed for 12.5 kHz channel spacing using also the
additional frequencies 457.5375 MHz, 457.5625 MHz, 467.5375 MHz and
467.5625 MHz may be introduced for on-board communications. The use of
these frequencies in territorial waters may be subject to the national
regulations of the administration concerned. The characteristics of the
equipment used shall conform to those specified in Recommendation ITU-R M.1174
(see Resolution 341 (WRC-97)). (WRC-97) "
The ITU regulations do specify what
on-board frequencies ships should be using in US territorial waters:
"S5.288 In the territorial waters of the United States and the
Philippines, the preferred frequencies for use by on-board communication
stations shall be 457.525 MHz, 457.550 MHz, 457.575 MHz and 457.600 MHz paired,
respectively, with 467.750 MHz, 467.775 MHz, 467.800 MHz and 467.825 MHz. The
characteristics of the equipment used shall conform to those specified in
Recommendation ITU-R M.1174."
ITU Equipment Characteristics
There is a long list of ITU
specifications for on-board stations using these frequencies. The most
significant for purposes of this article are :
Output power shall not exceed two
watts.
Frequencies may be used for
single-frequency and two-frequency simplex operations.
The frequency deviation shall not
exceed ± 5 kHz.
An antenna mounted on the ship shall
not be more than 3.5 m above the level of the bridge.
If the use of a repeater station is
required on board a ship, the following frequency pairs shall be used (see also
RR No. S5.288 [No. 670]):
- 457.525 MHz and 467.525 MHz
- 457.550 MHz and 467.550 MHz
- 457.575 MHz and 467.575 MHz
You will notice the last two repeater
pairs! If a ship enters US waters and continues to use their ship-board
repeater, we could very well hear their activity broadcast from the highest
point of the ship as it cruises through our ports. This explains why NorCal had
heard the radio transmissions so clearly over such a wide area. The altitude of
the ship's bridge is quite high compared to the land and the sea below. In
relatively flat terrain where the signals were heard, the height of the antenna
on the vessel could cause the signal to be heard over a significant
area.
We don't know which maritime company
visits the USA and continues to use 467.575, but we know more than we did when
we started. It should be a lot easier to find the pirate and report them to the
FCC the next time.
May 2007:
Since 2000 I moved to a home within eight-hundred feet of the Chesapeake Bay on
Maryland's Western Shore. Here I found that virtually every ship visiting US
waters is still in direct violation of ITU regulations. Ship's Captains and
Radio Officers are ignoring our regulations and even those written into ITU
regulations. Not only do ITU regulations specifically state that a government
(ours in this case) has the RIGHT to direct ships to use preferred channels as
our own NTIA has done, but those same ITU regulations FORBID ships from
interfering with our communications in our country whenever they are in our
territorial waters. In addition to the prohibition against interference, there
is also a station identification requirement which is never honored. I have
heard ships on EVERY GMRS channel and not just the two 467 channels.
We did speak with the FCC on this
matter. The FCC suggested that since a foreign flagged vessel may be difficult
to contact, that GMRS licensees should notify their nearest FCC office. If a
GMRS licensee has identified the vessel provide that information to the FCC.
Our local Enforcement Bureau suggested it might handle the issue by a telephone
call to the local harbor master. We think that is a good solution. GMRS
licensees want the interference to repeaters to cease and helpful telephone
contact between our government and the pirate should fix the problem.
In 2005, three Personal
Radio Association founders went to Washington D.C. to meet with Kris Monteith,
Bureau Chief of the FCC Enforcement Bureau. At that time, we addressed this
issue as a major concern of the PRA and it's members in U.S. port cities. Mrs.
Montieth assigned Assistant Bureau Chief, George Dillon, to look into this
issue on our behalf. The PRA waited over one year and we heard from FCC Special
Counsel Riley Hollingsworth:
Hollingsworth:
"I've been asked to respond to your inquiry to George Dillon. Regarding
the Chesapeake Bay area, we have been under the impression that it has mostly
cleared up, at least in regard to the Dominion LNG terminal, due to your
working relationship with Dominion. To the extent it hasn't and you detect that
the ships are going into a specific facility, let me know and we'll request the
facility to advise the ship captains that GMRS is not to be used by crew. This
goes for other ports too such as Los Angeles or San Francisco.
Hollingsworth: Now
here's the dilemma from our viewpoint. These communications are among ship crew
members and not between ship and shore. It would be virtually impossible to
police that unless we had roving maritime field agents in boats monitoring the
ships. It just isn't practical, especially given the present day priorities of
Homeland Security. We are not in a position to police crew member hand held
radio use on every foreign vessel coming in our ports.
Hollingsworth: The
realistic answer is that this is just a downside of using GMRS near a
seaport. All services have a downside. Land mobile in the 50 MHz band gets
all kinds of unknown interference from great distances. 800 MHz is subject to
ducting, or interference from unusually distant transmitters due to mountain
top locations. 150 MHz band is fluky as well, and in cellular there are often
dropped calls. Satellite communications are often affected by rain. There is no
ideal RF method and that's why we have alternative communications services.
Hollingsworth: Given
our resources and the nature of this problem, the most we can do is request
port authorities to advise foreign ships entering ports not to use GMRS
channels.
2007: The PRA has never
left the FCC with the impression that this problem was "close to
resolution" or "confined to three ports." We also find it silly
on the part of the Commission to reduce the interference problem to that of a
few deck hands with portable radios after we have provided them with
information completely to the contrary. Interference comes from bridge mounted
radio systems and on-board radio repeaters that cause interference over
hundreds of square miles during tropospheric events. We have repeatedly
mentioned this problem it in FCC rule makings and have been fighting the
interference in California and Maryland with Field Offices for the last twelve
years. We have anecdotal accounts of this problem being brought to the
attention of FCC Field Offices in the State of Washington, Pennsylvania and New
York over the last twenty years. The FCC made assumptions that made it easier
for them to walk away from their responsibility which is to protect GMRS
licensees from harmful interference as they do any other radio service. We also
know from Commission contacts that WTB is pressuring EB to not enforce GMRS
anticipating license by rule. WTB denied this in a face to face meeting with
them in 2006. The FCC had apparently completely forgotten that we would accept
an educational effort to resolve this growing problem and that we were not
expecting an FCC agent to race to every complaint. We found that assertion
rather humorous but the argument specious. Many of the points made in this
response we took great exception to. We did not expect to hear this kind of
rationale from our own FCC. We felt this response was unwarranted so we pushed
back. Kris Monteith met with Mr. Dillon and Mr. Hollingsworth and agreed to an
educational effort in part by asking the Coast Guard for assistance. An
inter-agency memo went to the Coast Guard in October 2006. It is now May 2007
and there is NO CHANGE in the amount of shipping activity at any port. We have
seen no proof of any educational effort just promises that letters will be
sent. We may soon have no other recourse but to write Congress. If you are a
licensee that is suffering interference you need to speak up and speak up now.
The PRA needs to know who you are.=and where the interference is. If you do
nothing we lose the fight.
Suspect a maritime intruder if you hear
foreign language traffic on repeater inputs 467.550 or 467.575 and no
identified GMRS traffic on the repeater outputs 462.550 and 462.575. If you
hear signals wider than an FRS signal on 467.5625 consider that this might be a
from a hand-held radio aboard a ship in a port near you!
I don't know whether these
International pirates are a serious threat to GMRS. My feeling is we will get
compliance if we can locate one or two of these users and have the FCC and
Harbor Master contact them. My sincere thanks to Simon Cockburn, Head of Radio
Safety for the MCA for providing information that was so helpful in putting the
remaining pieces of this puzzle together. Also kudos to GMRS Web Technical
Editor, Paul Shinn, for leading the chase in the Port of Sacramento a few
months back. I would also like to thank the San Francisco office of the FCC for
the wisdom and counsel on this matter.
2007: The foreign
shipping pirate is a very serious intruder. We have heard from licensees across
the US. Licensees have complained to the FCC Field offices for over twenty
years and gotten very little assistance. The solution is in the law. ITU
Regulations forbid ships from interfering with communications in countries they
visit. Specific frequencies are authorized for visiting ships. This problem
does not have to be. It cannot be likened to a dropped call on a cellular
system, rain causing lapses to satellite reception, or an annoying natural or
man-made noise source. GMRS already copes with ducting and interference from
our own sources. Regulation should prevent added interference from foreign
maritime sources.
2007: No thanks to the
FCC, I was able to secure the assistance of the local LNG facility owned by
Dominion. This company has gone out of its way to protect our interests and to
protect the community. They take security seriously, unlike the FCC that has
completely ignored any home-land security problem associated with ships failing
to obey our laws. The PRA and I are proud to have an association with Dominion.
We believe that licensees can work out similar agreements where ships dock
whether or not the FCC finally chooses to do the right thing. We can't tell you
if the FCC has done anything since as of late 2006 they no longer make letters
available to us or the Amateur radio community. We are in the dark as far as
the FCC is concerned. In closing I can only say that I continue to rely on the
personal word of two people at the FCC whom I have grown to respect, Riley
Hollingsworth and Kris Montieth. When they say it is so I assume it is. I can
also continue to hope.
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