The Owner's Cost-Cutting Plan for an A1 Passenger Run
Your company runs a 21 m fibreglass passenger vessel, certified for 12 passengers and 3 crew, on a scheduled 40-minute run between a mainland harbour and an island 11 nautical miles offshore. The whole route lies inside the coverage of a coast station that maintains continuous VHF DSC watch on channel 70, and the vessel never goes outside it. The owner, cutting costs before a refit, proposes three changes: remove the 406 MHz EPIRB because "A1 ships don't need one"; replace the fixed 25 W DSC VHF and its separate DSC controller with two 5 W handhelds, one kept charged in the wheelhouse; and drop the NAVTEX receiver because "the forecast is on the phone". The SART is in date and the liferaft was serviced in spring. The vessel is registered and licensed in the flag State. The owner wants your written opinion before the surveyor arrives, and has already ordered the handhelds.
1. Is this route Sea Area A1, and what would change if the winter timetable extended the run 5 nm beyond DSC coverage for 20 minutes at each end?
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A1 is defined by radio coverage, not distance from land: the vessel must be within coverage of at least one coast station providing continuous DSC alerting on VHF channel 70 (with radiotelephony on channel 16 available), and that coverage must be continuous for the whole passage. Eleven nautical miles is irrelevant if the coverage is there; eight nautical miles behind a headland could still be outside it.
If the winter extension leaves coverage, even for 20 minutes, the vessel is no longer A1-only for that part of the voyage. It enters A2 and would need the A2 fit (MF DSC alerting, or another station's coverage), or the timetable must change. Note the word continuous: a station outage, a failed antenna or terrain shadowing can put you outside A1 without the vessel moving. Confirm coverage in writing with the coast station or the Administration for both timetables before you answer the owner - do not rely on the chart or on "we've always been fine".
2. Which of the owner's three proposals can you accept, and on what basis?
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None as proposed.
- EPIRB. Under SOLAS IV/7 a 406 MHz EPIRB is not required for a ship engaged exclusively in A1 (the A1 fit uses a 9 GHz SART). But that is a SOLAS baseline, not the whole answer: the certificate for a domestic passenger vessel is issued against national rules that are frequently stricter, and the EPIRB is the only device that alerts an RCC automatically from a liferaft if the vessel sinks fast and there is no time for a voice call. Do not endorse removal without the Administration's written agreement.
- Handhelds. No. The carriage requirement is met by a fixed installation with continuous automatic DSC watch on channel 70, 25 W and a masthead antenna, plus a dedicated emergency power source. A 5 W handheld at deck level has a fraction of the range, keeps no automatic watch, and depends on someone remembering to charge it.
- NAVTEX. A phone forecast is not an approved MSI receiver. It fails when the cell network fails and it carries no navigational or SAR broadcasts.
Recommend keeping all three and repairing the fixed set.
3. The owner wants the EPIRB off by Saturday and the surveyor arrives tomorrow. What is your sequence of actions?
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- Get the rule in writing - ask the Administration, or the classification society issuing the certificate, for the applicable carriage requirements for this vessel and route, including the winter variant.
- Confirm A1 coverage for the whole route, both directions, in writing, with the coast station or Administration.
- Verify the kit - EPIRB registration, battery and HRU dates; SART battery; emergency power source; the fixed set's DSC watch.
- State your position in writing before Saturday: the vessel is in A1, the full A1 fit is required, and removal is not authorised by you. "The owner decided" is not an exemption; exemptions come from the Administration.
- Record it - a dated entry in the radio log or the vessel's records of what was proposed, what you advised and what was decided.
A restricted operator's real duty here is not to design the fit but to refuse to certify a downgrade you cannot justify, and to push the decision to the authority that actually owns it.