W3BE'S BE Informed!
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BE Informed 1.6

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Hams at Sea

John B. Johnston W3BE

Q. I am taking a 7-day Caribbean Sea cruise for which I intend to take a HF rig and antenna along with me. As I understand it, I will have to append “/MM” to my call sign for the station identification announcement. That would make it “W4***/MM.” Is this correct?

A. Not if your station is going to be transmitting under the authority of your FCC license grant. Section 97.119(a) says: Each amateur station, except a space station or telecommand station, must transmit its assigned call sign on its transmitting channel at the end of each communication, and at least every 10 minutes during a communication, for the purpose of clearly making the source of the transmissions from the station known to those receiving the transmissions. No station may transmit unidentified communications or signals, or transmit as the station call sign, any call sign not authorized to the station.

   According to your license grant shown on the ULS, your station’s FCC-assigned call sign is W4***. Your station, therefore, - at least while it is transmitting under the authority of your FCC-issued license grant – is obligated only to transmit that unadorned FCC-assigned call sign when making the Section 119(a) station identification announcement.

Q. But an indicator appended to my station’s call sign might help in making more QSOs. I want to alert my listeners on the band that I am aboard a Caribbean Sea cruise ship. Otherwise, they may not realize that my station is at sea and overlook my CQs. How should I add one?

A. Just say something like: “This is W4*** slant mark aboard the cruise ship Colossal Mermaid of the Caribbean Sea” or whatever floats your boat.

Q. But I only intend to work CW. That indicator has too many characters to key. I want something a whole lot shorter. What should I use?

A. You have a lot of choices. Section 97.119(c) says: One or more indicators may be included with the call sign. Each indicator must be separated from the call sign by the slant mark (/) or by any suitable word that denotes the slant mark. If an indicator is self-assigned, it must be included before, after, or both before and after, the call sign. No self-assigned indicator may conflict with any other indicator specified by the FCC Rules or with any prefix assigned to another country.

   To make it meaningful, however, you need for the monitors/listeners to your station’s ID announcement transmissions to comprehend what it is you are trying to tell them. That’s where the Section 97.119(c) identifier appendage comes in. It might give our monitors/listeners a clue that your station is transmitting from somewhere other than the postal mailing address shown on the ULS.

   For a station transmitting from a vehicle traveling in a place where the FCC regulates our amateur service, Appending a Self-assigned Indicator To Your Station Call sign BE Informed No. 4.1 recommends appending WV for waterborne vehicles. That selection is within the ITU-assigned nationality identifier series WA-WZ assigned to the United States.

   Do not append the letters M or MM in your Section 97.119(a) station identification announcement unless your transmitting authority is from the United Kingdom of Great Britain and Northern Ireland. Their appendage to an FCC-assigned call sign would be non-compliant with Section 97.119(c) because they are their rightfully-assigned nationality identifiers. Cooperate with the amateur operators in those countries and with our DXers who rely upon those nationality identifiers while stalking the bands.  

   A simple alternative – as well as being a good amateur practice - is for your optional self-assigned indicator to be disassociated from your station call sign, i.e., replacing the “/” character with a short “pause” after the transmitted station identification announcements. Then the self-assigned indicator becomes just another part of the transmitted text. That will eliminate all issues with the Section 97.119(c) station identification announcements.

Q. But I don’t like WV for an identifier. What else can I use?

A. It’s your choice among everything except those that conflict with an indicator specified by the FCC rules or with any prefix assigned to another country. Whichever indicator you choose to append to your FCC-assigned call sign, you want your listeners to understand its meaning.

Q. Is it OK to use a club station call sign on a cruise? I have been informed that an amateur station on a cruise must ID by the control operator’s primary station call sign. 

A. That may be correct when the amateur station apparatus is located aboard a non-U.S.-flag vessel. Check out the regulatory and station identification transmission necessities with the appropriate foreign government regulatory authorities. Most cruise ships seem to be registered in either the Bahamas, Panama, Italy, Malta, or the Netherlands. Where the ship will be within the territorial limits of still other countries, multiple transmitting permissions/compliances will probably be required. Don’t assume that that the rules of every foreign regulator are identical to our FCC’s Part 97. You must be competent to perform properly the duties of an amateur service licensee as required by the hosting country.

   Otherwise - except from those places where our amateur service is regulated by some other country - a Section 97.5(b)(2) club station is authorized by Section 97.301 to transmit Section 97.109 amateur service communications from a master-of-the-ship-approved Section 97.11 ship installation located anywhere in the World.

Q. Are there any cruise ships registered in the United States?

A. For one, reportedly, the Pride of America is an ocean-going U.S.-flagged vessel staffed by American officers and crew. 

Q. Do we need permission from our club station licensee trustee to use our club call sign?

A. Of course. Your Section 97.5(b)(2) club station licensee trustee is your club’s designated station manager. Section 97.103(a) says in pertinent excerpt: The station licensee is responsible for the proper operation of the station in accordance with the FCC Rules. Read W3BE Checklists for Domestic and Foreign Amateur Service Licensees in Places Where the U.S. FCC Is Our Regulator BE Informed No. 1.0.

Q. When our cruise ship is visiting a foreign port, what call sign do we use?

A. In accordance with the station identification regulations for the hosting country, send the call sign assigned to the station as shown on your transmitting permission document. If you don’t have an amateur service license from that country, you might be eligible for some sort of reciprocal operating permission.

   In some countries, the regulator assigns to an amateur station engaged in reciprocal operation a call sign consisting of the host country’s nationality prefix appended with the FCC-issued call sign. Even so, the rules of the host country are applicable. Show respect to your hosts and your host country’s rules.

Q. Can our club station license trustee enter into some sort of arrangement with the host country so as to bypass the need for each of our members having to obtain individual reciprocal operator permission?

A. That is something for the regulators within the visited countries to determine. Routine reciprocal operating authority is usually a permission granted to an individual amateur operator. As U.S. hams should know, a Section 97.5(b)(2) club station license grant carries no operator privileges.

Q. What else should I know about cruise ship operating?

A. Be knowledgeable of Section 97.11 Stations aboard ships or aircraft. It says:

   (a) The installation and operation of an amateur station on a ship or aircraft must be approved by the master of the ship or pilot in command of the aircraft.

   (b) The station must be separate from and independent of all other radio apparatus installed on the ship or aircraft, except a common antenna may be shared with a voluntary ship radio installation. The station's transmissions must not cause interference to any other apparatus installed on the ship or aircraft.

   (c) The station must not constitute a hazard to the safety of life or property. For a station aboard an aircraft, the apparatus shall not be operated while the aircraft is operating under Instrument Flight Rules, as defined by the FAA, unless the station has been found to comply with all applicable FAA Rules.

    You could very likely encounter some complex regulatory circumstances with which to contend. First and foremost, there are the rules of the country in which the ship is registered. If you are uncertain whether the master of the ship is aware of those rules when approving your installation and operation, check with the communications regulatory agency of the ship’s country of registry. While you are aboard the ship, you may be obligated to observe those rules. If you are unable to do that, do not cause or allow your station to transmit.

   When the ship is within the territorial limits of our United States, moreover, you are also obligated to comply with Part 97. They are your working rules in this situation, but do not exceed any limitations laid down by the master of the ship.

   Sections 97.5(a)(1) and (2) say:

   (a) The station apparatus must be under the physical control of a person named in an amateur station license grant on the ULS consolidated license database or a person authorized for alien reciprocal operation by §97.107 of this part, before the station may transmit on any amateur service frequency from any place that is:

       (1) Within 50 km of the Earth's surface and at a place where the amateur service is regulated by the FCC;

       (2) Within 50 km of the Earth's surface and aboard any vessel or craft that is documented or registered in the United States.

   Do not presume that your cruise ship is registered or documented in the United States just because it sails from a U.S. port.

Q. What if the rules of the ship’s country of registry are different from the FCC rules?

A. The more restrictive of the two sets of rules apply. The same pertains while on the high seas unless the regulations of the country of the ship’s registry allow otherwise. The Caribbean is within ITU Region 2. Should your cruise be in the Mediterranean, you would be within ITU Region 1. A cruise to the far Pacific could be in ITU Region 3. Sections 97.301 and 97.303, therefore, take these regions into account when authorizing transmitting frequencies and specifying sharing requirements.

   Then there is the circumstance where the ship is within the territorial limits of a country with which our United States has reciprocal operating arrangements. The working rules in this situation are those of that reciprocal hosting country. Its regulations apply exclusively, including station identification requirements. These countries – which include numerous Caribbean destinations - are listed on the FCC website.

   Also, subject to the regulations in force in the country visited, a U.S. citizen holding a General, Advanced, or Amateur Extra Class operator license granted by the FCC is supposed to be authorized to utilize temporarily an amateur station in a European Conference of Postal and Telecommunications Administrations (CEPT) country that has implemented certain recommendations with respect to the United States. The person must have in his or her possession a copy of FCC Public Notice DA 09-2031 dated September 10, 2009; proof of U.S. citizenship; and evidence of the FCC license grant. These documents must be shown to proper authorities upon request. Read Section 97.3(a)(12).

   For a U.S. citizen to operate an amateur station in a country belonging to the Inter-American Telecommunication Commission or Comisión Interamericana de Telecomunicaciones (CITEL), there is an International Amateur Radio Permit. It is a document issued pursuant to the terms of the Inter-American Convention on an IARP by a country signatory to that Convention, other than the United States. Read Section 97.3(a)(24).

   Finally, there is the circumstance where the ship is within the territorial limits of a country with which our United States does not have a reciprocal operating arrangement. Unless there is some other understanding between the ship’s country of registry and your hosting country, you are on your own. The regulations of that hosting country apply. You might also check with the master of the ship.    

   Bon voyage!

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April 18, 2017

Supersedes all prior editions