Kochi to Malé on an A1/A2 certificate: sea-area judgement and the go/no-go decision
MV Sagar Kiran, 780 GT, Indian flag, is certificated for GMDSS sea areas A1 and A2. Her outfit is VHF DSC and radiotelephony, MF DSC with MF radiotelephony on 2182 kHz, one NAVTEX receiver, a 406 MHz EPIRB, two 9 GHz SARTs, three portable two-way VHF sets, and a reserve battery rated for one hour backed by an emergency generator. There is no Inmarsat terminal and no HF. She is fixed for a cement cargo from Kochi to Malé, about 360 nautical miles. For roughly fourteen hours in the middle of the passage the track lies more than 150 nm from the Indian coast, and the master may have to divert a further 40 nm west to avoid a developing depression. The owner wants to sail at 1800 today: 'Malé has a coast station and the Coast Guard is everywhere.' The charterer's agent adds that the Maldivian agent will monitor the vessel on VHF. You are the shore radio superintendent, asked for a written go/no-go before the agent confirms the berth at Malé.
1. Classify the sea areas the voyage will pass through and state, with reasons, whether the present certificate and outfit are adequate.
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Classification first, decision second.
- A1 is the area within radiotelephone coverage of at least one coast station where continuous DSC alerting is available, as published by the administration - in practice roughly 20-30 nm off the Indian coast.
- A2 extends outside A1 to the limit of MF DSC coverage on 2187.5 kHz from a coast station maintaining watch, about 150 nm.
- A3 is everything outside A1 and A2 that lies within the coverage of an Inmarsat geostationary satellite (nominally 70°N-70°S) using a recognised mobile satellite service; anywhere else is A4.
On the Kochi-Malé track the ship is in A1 on departure and in A2 while within about 150 nm of an Indian MF coast station. For the fourteen-hour mid-passage leg she is more than 150 nm offshore and therefore in A3. A Maldivian coast station answering on VHF does not convert A3 water into A2: A2 status depends on a published, continuously watched MF DSC service, not on someone being reachable by voice.
Verdict: no-go. The certificate of inspection, the ship station licence and the actual outfit cover A1/A2 only. Sailing into A3 with VHF plus MF alone puts the ship outside her licence and outside SOLAS chapter IV, and it leaves two gaps: distress alerting (no satellite or HF DSC means no route to an RCC once beyond MF range) and MSI reception (the NAVTEX picture collapses once the Indian coastal transmitters are left behind). A satphone in the owner's office does not close either gap.
2. Set out the minimum actions needed before departure, and explain why a non-GMDSS satellite phone or a commercial FleetBroadband would not solve the problem.
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Acceptable routes before sailing
- Fit a type-approved A3 terminal - either an Inmarsat-C with distress priority and EGC/SafetyNET, or an Inmarsat FleetBroadband variant approved for GMDSS with the dedicated distress function and SafetyNET. The fit must be accompanied by:
- an amended ship station licence from WPC and an amended cargo ship safety radio certificate after survey;
- updated reserve battery calculations, because the new terminal load has to be carried for the required endurance;
- a revised watch schedule and radio log format that include the terminal;
- beacon and MMSI records consistent with the new operating area.
- Re-route to stay within A2 - correct in principle, impractical for a 360 nm crossing, and it still needs the charterer's agreement.
- Anything else is not a solution.
Why a satphone or a commercial FleetBroadband fails: it is not type-approved for GMDSS; it has no maritime distress priority routed to a rescue coordination centre; it receives no EGC/MSI; it does not put an automatic position into a distress message; it has no DSC interface, no protected power supply and no alarm at the radio position. SAR authorities are not watching it, and it satisfies no carriage requirement for the sea area.
The compliant answer is to fix the equipment and the certificate, not the paperwork. If the terminal cannot be fitted and surveyed today, the sailing date moves - that is the superintendent's recommendation, in writing.
3. Once the ship is properly equipped for A3, what continuous watch requirements apply, and how does the MSI picture change on this route?
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Continuous watches in A3
- VHF channel 70 DSC - continuous.
- VHF channel 16 radiotelephony - continuous where practicable.
- MF 2187.5 kHz DSC if MF is retained. A ship may satisfy A3 by satellite alone, but if the MF/HF installation is fitted it is normally kept in the watch and the licence will reflect it.
- Inmarsat terminal: powered, logged in to the correct ocean region, distress alarm enabled, position updated, so that shore-to-ship distress priority and EGC are actually received.
- MSI: NAVTEX while in coverage, then SafetyNET/EGC.
The MSI change on this route: Indian NAVTEX transmitters are a coastal service. Somewhere in the middle of the crossing the receiver goes quiet, and it will be quiet exactly when a cyclone warning matters most. SafetyNET/EGC becomes the primary source - NAVAREA VIII for navigational warnings and METAREA VIII for weather in the Indian Ocean. That is the real argument for the Inmarsat-C/EGC fit, not the voice capability.
For the oral part of any inspection, the ROC holder must be able to demonstrate selecting the correct ocean region, checking the message categories are not filtered, confirming the terminal's position input, and showing where the received MSI is filed - not merely that the box is switched on.