Federal Communications Commission DA 09-612 
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
NATIONAL GMDSS IMPLEMENTATION 
TASK FORCE 
Request Regarding Maritime Mobile Service 
Identities
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WT Docket No. 07-230
ORDER
Adopted:  March 17, 2009 Released:  March 17, 2009
By the Deputy Chief, Mobility Division, Wireless Telecommunications Bureau:
1. Introduction. In this Order, we address a request1 filed by the National GMDSS 
Implementation Task Force (GMDSS Task Force).2 Specifically, the GMDSS Task Force seeks changes 
to the Commission’s processes regarding maritime mobile service identities.  On October 11, 2007, the 
Mobility Division sought comment on the GMDSS Task Force request.3 Over five hundred comments 
were received, mostly from individual vessel owners, but also from the United States Coast Guard 
(USCG), the Radio Technical Commission for Maritime Services (RTCM), and the GMDSS Task Force.  
For the reasons stated herein, we deny the request as this time, but will consider appropriate action at a 
later date.
2. Background. A maritime mobile service identity (MMSI) is a unique nine-digit number 
assigned to commercial and recreational vessels participating in the Global Maritime Distress and Safety 
System.4 The Commission assigns MMSIs to licensed vessels as part of the ship station licensing 
process.  Operators of vessels that are not required to obtain an individual ship station license (“exempt” 
vessels)5 can obtain MMSIs from designated private registration agents.6 Exempt vessels with privately-
  
1 Petition to Request the FCC to Adopt New Policies and Procedures Regarding MMSI Assignments (filed May 29, 
2007) (Request).
2 The GMDSS Task Force was chartered by the U.S. Coast Guard to supplement government functions in expediting 
the implementation of the Global Maritime Distress and Safety System.  The membership includes over 1,500 
representatives of government agencies, commercial vessel owners and operators, recreational vessel interests, 
training institutions, service agents, manufacturers, trade associations, and maritime labor organizations.
3 Wireless Telecommunications Bureau Seeks Comment on Request of National GMDSS Implementation Task 
Force Regarding Maritime Mobile Service Identities, Public Notice, 22 FCC Rcd 18383 (WTB MD 2007).
4 See, e.g., Amendment of the Commission’s Rules Regarding Maritime Automatic Identification Systems, Report 
and Order and Further Notice of Proposed Rule Making and Fourth Memorandum Opinion and Order, WT Docket 
No. 04-344, 21 FCC Rcd 8892, 8936 n.307 (2006).
5 A vessel is not required to be individually licensed if it is not subject to any radio equipment carriage requirement 
under any statute, treaty, or agreement to which the United States is a party; does not travel to foreign ports or make 
international communications; and does not carry equipment other than VHF (156-162 MHz) radios, emergency 
position-indicating radio beacons, and radar installations.  See 47 C.F.R. § 80.13(c).
6 See Commission Announces Agreements with Shine Micro, Inc., and United States Power Squadrons, Inc., and 
Termination of Agreement with Maritel, Inc., Regarding Assignment of Maritime Mobile Service Identities 
(MMSIs), Public Notice, 22 FCC Rcd 7329, 7330 (WTB MD 2007) (listing entities from which operators of exempt 
vessels can obtain MMSIs).
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issued MMSIs that later obtain individual ship station licenses receive new MMSIs in the licensing 
process.  Vessel owners that allow their licenses to expire (because they are no longer required to be 
individually licensed) do not retain their Commission-issued MMSI, and must obtain new privately-
issued MMSIs.
3. The GMDSS Task Force requests that the Commission alter its Universal Licensing 
System (ULS) so as to permit operators of exempt vessels that later obtain individual ship station licenses 
issued by the Commission to retain the privately-issued MMSI.7 It also recommends that the designated 
private entities be permitted to manage Commission-issued MMSIs when the operator of a licensed vessel 
decides not to renew the station license.8 The GMDSS Task Force argues that this would alleviate a 
burden on operators by eliminating the need to have the new MMSI programmed into their shipboard 
equipment, and prevent the same vessel from being assigned two MMSIs concurrently, which wastes 
numbers.9  
4. Commenters support these proposals.  In addition to reiterating concerns expressed by the 
GMDSS Task Force, they express frustration that upon receipt of a new Commission-issued MMSI, in 
many instances, the radio equipment must be removed from the vessel and sent to the manufacturer for 
reprogramming at the vessel owner’s expense.10 Such reprogramming might take several weeks or 
months, resulting in travel delays or travel without properly registered radio equipment on board.11 Some 
commenters believe that the burden associated with obtaining a new MMSI deters some vessel owners 
from complying with the individual licensing requirement, or from obtaining a new MMSI after allowing 
the vessel’s license to expire.12  
5. Previously, the GMDSS Task Force requested that the Commission to expand its MMSI 
database to incorporate additional data fields by revising the Commission’s application forms to require 
submission of the expanded data when applying for a station license and when renewing such licenses.13  
In 2003, the Wireless Telecommunications Bureau, Public Safety and Private Wireless Division14 granted 
the request to the extent of adding the additional data fields to the application form for new ship station 
licenses.15 The additional information is not, however, required of licensees renewing ship station 
  
7 Request at 4.
8 See id. at 4-5.
9 See id. at 2-3.
10 See, e.g, RTCM Comments at 2; Christian David Rhynalds Comments at 1; Richard Galasso Comments at 1.
11 See, e.g, Preston Bateman Comments at 1; Edward Jemerich Comments at 1; James Griffing Comments at 1.
12 See, e.g, James Hagy Comments at 1; Richard H. Schuman III Comments at 1.
13 See Wireless Telecommunications Bureau Seeks Comment on Request that the Commission Collect Full 
Maritime Mobile Service Identity Data Set Recommended by the International Maritime Organization, Public 
Notice, 17 FCC Rcd 26114, 26114 (WTB PSPWD 2002).
14 The Commission reorganized the Wireless Telecommunications Bureau effective November 13, 2003, and the 
Public Safety and Critical Infrastructure Division assumed the relevant duties of the Public Safety and Private 
Wireless Division.  See Reorganization of the Wireless Telecommunications Bureau, Order, 18 FCC Rcd 25414, 
25414 ¶ 2 (2003).  Pursuant to a reorganization effective September 25, 2006, certain duties of the Public Safety and 
Critical Infrastructure Division were assumed by the Mobility Division.  See Establishment of the Public Safety and 
Homeland Security Bureau, Order, 21 FCC Rcd 10867 (2006).
15 See Wireless Telecommunications Bureau Promotes Increased Maritime Safety by Expanding Collection of 
Maritime Mobile Service Information, Public Notice, 18 FCC Rcd 10165, 10165-66 (WTB PSPWD 2003) (adding 
data fields for name, address, telephone number, and fax number for emergency contact person ashore; emergency 
contact number for alternate contact ashore; radio installation for ship and survival craft; emergency position-
(continued....)
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licenses that were initially granted before the additional data fields were added to the form.16 In the 
instant request, the GMDSS Task Force again recommends that the Commission require licensees to 
provide the expanded data when they apply for license renewal, and further recommends that the 
Commission periodically contact licensees and other MMSI registrants to verify that the data on file 
remains correct, and that the MMSI is still active.17
6. USCG strongly supports these proposals.  It states that the additional information helps to 
identify the entity transmitting the distress signal,18 and to determine whether the distress call is genuine, 
thus resulting is efficient and effective allocations of resources.19  
7. Discussion.  We agree with the commenters that there is merit to the GMDSS Task 
Force’s proposals.  It appears that permitting exempt vessels with privately-issued MMSI numbers to 
retain these MMSIs when they later obtain a Commission-issued individual ship station licenses, and 
permitting the designated private entities be permitted to manage Commission-issued MMSIs when the 
operator of a licensed vessel decides not to renew the station license, would be more efficient than 
maintaining the current wasteful system of dual MMSIs, and would eliminate unnecessary paperwork, 
expense, and delay.  It also could improve the safety of individual vessel owners as it would minimize the 
incidence of travel without properly-registered MMSIs.  
8. We also agree that it would be beneficial to require licensees to update their information 
in the licensing system and provide additional data when their ship station licenses are renewed.  We do 
not think, however, that the Commission should be required to periodically verify the information in the 
database by contacting individual licensees, as there is no evidence in the record that outdated information 
in the licensing system poses any problems to the Commission, licensees, or entities that rely on the 
accuracy of such information.
9. Therefore, we agree that our licensing system should be altered so that it would accept 
the entry of a privately-issued MMSI and process an individual ship station license application, without 
automatically issuing a new MMSI number.  We, however, do not think it necessary to alter the current 
system immediately and only for this sole purpose, because such alteration would require substantial and 
costly reprogramming.  Such reprogramming should be done in conjunction with the forthcoming 
upgrade of the licensing system.  We therefore intend to consider the proposal described in the GMDSS 
petition in more detail at the time when the upgrade is scheduled.  All technical and administrative 
matters in connection with the proposal and all other related matters will be addressed then.
10. Ordering Clause. Accordingly, IT IS ORDERED that, pursuant to Sections 4(i) of the 
Communications Act of 1934, as amended, 47 U.S.C. § 154(i), and Section 1.41 of the Commission’s 
Rules, 47 C.F.R. § 1.41, the Petition to Request the FCC to Adopt New Policies and Procedures 
Regarding MMSI Assignments filed on May 29, 2007, by the National GMDSS Implementation Task 
Force IS DENIED.  
11. This action is taken under delegated authority pursuant to Section 0.131 and 0.331 of the 
  
(...continued from previous page)
indicating radiobeacon identification code and homing frequency; type and number of survival craft; and capacity 
for persons on board).
16 See FCC Form 605 Main Form Instructions at 5 (requiring radio service code, application purpose, call sign, FCC 
Registration Number, and fee information to renew a license).
17 See Request at 3-4.
18 USCG Comments at 2.
19 Id. at 3.
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Commission's Rules, 47 C.F.R. §§ 0.131, 0.331.
FEDERAL COMMUNICATIONS COMMISSION
Scot Stone
Deputy Chief, Mobility Division
Wireless Telecommunications Bureau