(f) Availability—approaching or leaving ports

CW-On radio watch: Radio officer ilable for communications, either in lio room or at any other location necary to facilitate communications rered for safety, navigation, and ship idling.

A3-Elsewhere: Deck officer must perform exacting navigation and ship handling duties to avoid collision or grounding, in heavy traffic and narrow channels at port entrances. Radiotelephone operating would distract deck officer from these vital duties to the detriment of his own and other vessels' safety.

5. EFFECTIVENESS

The effectiveness of CW for satisfactory communications is 17 decibels greater n voice. The reason for this very great difference, which represents a power io of 50 to 1, is that with voice most of the intelligence is carried by the weak sonants and most of the power is dissipated in the less effective vowel nds.

The facts are entirely different with CW where all of the power radiated is in form of useful communication.

The 50-to-1 power ratio mentioned above has been arrived at without conering the interference which is normal on the bands. A voice communicaa has to be at least 6 decibels better than all other communications on the ae band in order to be intelligible; but, if any other signal as strong as, or nger than, the one being considered, is present anywhere within 6 or 8 kiloles, the communication is impossible.

There is an entirely different story on CW. With highly selective receiver, reak CW signal can be selected and copied although other signals may be ch stronger and less than 1 kilocycle away. As the 50-to-1 power ratio is ived at under perfect conditions, it can be seen that this ratio is greatly reased as interference increases.

In what is termed the local area (roughly north from 20° N.) our ship-to-ship munication is always difficult. In the summer and fall months when more n 4,000 boats are actively endeavoring to get their ideas across to each other, -s virtually impossible ** *" (symposium papers delivered at the RTCM ing assembly meeting, April 28. 29, 30, 1954, San Francisco, Calif., "Commuations-Tunaboat Fleet," by Harold F. Cary, general manager, American aboat Association, p. 12). Similar conditions prevail in Hawaiian waters.

(b) Effect of harmonic radiations

W-Slight: A qualified operator can

A3-Bad: Severe interference from ect desired signal against background harmonics can make communication imany others by tuning, supplying beat possible.

Thus radiophone requires from 3 to 36 times more space in the crowded quency spectrum than radiotelegraph.

(b) Flexibility

CW-Good: Qualified radio officer A3-Severely limited: Only 10 pe can adjust and calibrate for frequency. set channels on most units; no de possessing technical ability to calibre

(c) Selection of appropriate frequency

CW-Good: Selection of appropriate A3-Poor: Limited to preset char frequency in medium or high frequency bands by qualified radio officer assures reliable communication at all times on one or another channel.

nels; further limited by lack of qual fied man with sufficient know-how # make proper selection.

8. PERFORMANCE RECORD OF BOTH SYSTEMS

CW-Excellent: The history of maritime radiotelegraph is an unsullied record of fidelity by radio operators, of the sea safety radiotelegraph network that has been growing to maturity during the past 50 years.

at sea.

A3-Very poor: There has been pa international network composed of radiotelephone equipped vessels. The requirement for compulsory radiotele phone equipment is only first going inte effect.

Of the 39,000 licensees, 34,000 are pleasure craft, incapable of participating in any sea safety network useful to large vessels, such as the Matson ships.

"In 1948, the maritime nations of the world convened in London, England, and adopted a new safety at sea convention. That international conference, regnized for the first time the shipboard radiotelephone as an instrument capable of being used effectively in a marine safety communication system in place of telegraphy. Although such acceptance is confined to the smaller cargo vessels, the action was highly significant in tentatively elevating the stature of telephony I use the word "tentatively" because in my opinion at least, the wisdom of raising telephony to this higher plane must be demonstrated by actual erperience in its practical operation as a safety communications system at sea ***" (symposium papers delivered at the RTCM spring assembly meeting, April 28, 29, 30, 1954, San Francisco, Calif., Radio Technical Commission for Marine Services, Washington, D.C., "Maritime Telephone Service From the Governmental Point of View," W. N. Krebs, Chief, Marine Division, Federal Communications Commission," p. 38). [Emphasis supplied.]

"The enforcement staff of the Commission is severely limited in number. This situation, being directly related to the allocation of Government operating funds, is quite beyond the control of the Commission * * *" (p. 47).

"Considering the wide diversification of interests among the 39,000 ship station licensees and the absence of any centralized or national organization of these licensees in the United States there is need for the best possible leadership in this field ***" (p. 47).

Has this situation improved appreciably? All reports since indicate it has not. Thus :

"The Commission devoted special effort to an enforcement problem occasioned by the misuse of radiotelephone distress and calling frequency by small boats. Superfluous communications and unauthorized transmissions have been hampering the use of this frequency for its intended high-priority purposes Unfortunately, the number of corrective actions is greatly exceeded by the number of transgressions. A disregard for official notices heralds a real and difficult

›blem. Also, in the case of small boats, the captain usually serves as liotelephone operator and has a tendency to ignore his responsibility to keep adio watch on the distress and calling frequency" (p. 138, FCC Report for cal Year 1959).

More recently in the Commission's last available annual report, we learn that re are now 116,000 station licenses issued to small boats, and only "some eling off in the number of violations ***. However, much work remains to done, both from an enforcement and educational standpoint, to alleviate the otic conditions that still exist in certain areas" (p. 141, FCC Report for scal Year 1962).

These are the undisciplined, "chaotic conditions" that exists in the radioephone system which militates against withdrawing vessels from the discined, orderly, and efficient radiotelegraph safety network, as Matson seeks lo.

A3 (continued):

"The larger vessels that have had radiotelephone installations have operated in a manner not conducive to confidence in this medium to date. While there are doubtless many other examples of failure of radiotelephone to provide safety, we refer the Commission to the four marine casualties listed below for example of the manner in which this medium has been inadequate.

RADIOPHONE IN DISTRESS-SOME CASE HISTORIES

(1) The U.S.S. "Benevolence" case.-The collision of cargo vessel SS Mary ckenbach and U.S. Navy hospital ship U.S.S. Benevolence, discussed in detail ve, points up the following: The master, preoccupied with ship-handling oblems, understandably failed to perform adequately on radiophone for safety. -ster is, after all, not a radio officer but a deck officer by background, training, d outlook. It must be expected that safety, distress, and general communicans would deteriorate if the substitution of a combination deck officer-radio erator for the qualified radio officer who now performs his specialized functions l, were allowed. Such substitution has not been permissible under U.S. law, should it be.

(2) The SS “Princess Kathleen" case.-Attached, as appendix F, a copy of article by Harold Lockwood, radio officer of the SS Hawaiian Craftsman scribes the grounding and sinking of the SS Princess Kathleen (ARA Log, nuary-February 1953 issue, p. 13). We respectfully urge upon the subcomttee the second, third, fourth, fifth, and eighth paragraphs, especially. They eal the inexperience of deck officers for distress communication and their coccupation with important other duties during emergencies.

(3) The SS "Joao Costa" sinking.-We have attached as appendix G, an arle by Mr. L. F. Joslyn, radio officer of the SS Compass, on the SS Joao Costa king (ARA Log, May-June 1953 issue, p. 25). Note that survivors were cued by the international radiotelegraph sea safety network although odds re against the 62 crewmembers being picked up. What stacked the cards inst these men was the fact that this vessel was equipped with radioteleone. Though it was of the type that could be keyed for radiotelegraph transssion, there was one important factor missing. The ship lacked a qualified raofficer who could get the radiotelephone working or who knew how to operate - key. This sort of experience would be a constant, were qualified radio cers lacking from the sea safety network; the happy ending would, however, ruled out except by the rarest stroke of luck.

4) SS "Loide Panama” collision.-We attach, as appendix H, an article by . Joseph T. Silva, radio officer on the SS Gulftrade on the collision of that sel with the Brazilian freighter, SS Loide Panama (ARA Log, Novembercember 1953 issue, p. 33). Note that the third mate of the SS Loide Panama s a combination mate-radio operator who was evidently too busy with his ies to even attempt to transmit safety communications for 45 minutes after collision. Even then, his signals were inadequate. Had the SS Gulftrade been able to supply radiotelegraph communications in this situation, there ld have been serious loss of life due to the long delay in getting on the air.

CONCLUSIONS TO BE DRAWN FROM THE ABOVE FOUR MARINE CASUALTIES

In any evaluation, the following conclusions must be reached :

(1) Deck officers already have more than enough important duties to perfe during safety emergencies, without the additional function of communications being thrust upon them.

(2) Deck officers, though competent in their own field, lack the skill, training and experience necessary to adequately perform the function of safety munications.

(3) Only the timely and effective intervention of radiotelegraph-equipped ships salvaged the situations where the deficiencies of radiotelephone Wed present.

(4) When radiotelephone is substituted for radiotelegraph, there is a COLS quent decrease of sea safety for that particular vessel as well as for all ship ping, and the records show radiotelephone has performed miserably in ener gencies involving safety at sea.

APPENDIX D

AFL-CIO MARITIME COMMITTEE RESOLUTION ON SAFETY AT SEA THROUGH RADO Whereas the Matson Navigation Co. applied on February 18, 1963, to the Federal Communications Commission for an exemption that would permit a semiautomated vessel Matson is building to navigate in the interisland trade in Hawaii without complying with the requirements of the Communications Act of 1934 as amended for radiotelegraph equipment, watches, and radio officers. The FCC refused to grant this exemption; and

Whereas on June 27, 1963, Matson brazenly announced, in a letter to all west coast maritime unions, that in their proposed manning of the interisland vessel they "have not included a licensed radio operator *** the Federal Communications Commission has refused to grant us an exemption and has given us an administrative ruling that this vessel required radiotelegraph equipment and. therefore, the addition of one licensed radio operator to the manning set forth. Matson, however, is not in agreement with this ruling, and it is our intention to introduce a bill to amend the Communications Act of 1934 to provide an exemp tion from this requirement with respect to our proposed interisland container vessel"; and

Whereas on September 19, 1963, Representative Walter Rogers of Texas introduced H.R. 8508 "to amend section 356 of the Communications Act of 1934. to permit cargo ships on voyages between Hawaiian ports to carry radiotelephone in lieu of radiotelegraph installations." The AFL-CIO Maritime Committee. and the American Radio Association, AFL-CIO, have continually at frequent intervals, requested advance notice to appear at hearings on this bill in the interest of safety of life at sea of the maritime workers in the organizations it represents as well as of the seamen and passengers who might be traveling aboard other vessels in the waters navigated by this vessel, and in the public interest; and

Whereas the House Interstate and Foreign Commerce Committee's Subcommittee on Communications and Power held hearings on February 18, 1964, upon only 18 hours' notice and disregarding urgent requests that these hearings be postponed or at least held open to permit the AFL-CIO Maritime Committee and the American Radio Association, AFL-CIO spokesmen to be heard in behalf of the maritime workers and the public interest in sea safety; and

Whereas the lives of the men who sail aboard this ship as well as the seamen and passengers who travel aboard other vessels in the waters navigated by this ship are protected by the radiotelegraph equipment, manned by licensed. skilled, and experienced radio officers who maintain safety radio watches and thus knit all vessels into a radiotelegraph sea-safety network that makes it possible for every ship to call upon every other vessel in distress and thus makes each vessel a potential lifeboat for all other vessels; and

Whereas the hazards encountered by vessels that navigate in the waters between the ports of the Hawaiian Islands are as great as those which face vessels covered by the congressional intent in adopting the 1937 amendments to the Communications Act of 1934, including section 356. Such protection provided by Congress after years of careful study and hearings following the Morro Castle, Mohawk, and Vestris disasters, should not lightly be set aside; and

Whereas spokesmen of the seamen have a right to be heard in their own behalf I in the public interest in sea safety: Now, therefore, be it

Resolved, That

. The AFL-CIO Maritime Committee, firmly opposed to any weakening of the liotelegraph sea-safety network, by exemption, waiver, or special legislation, ongly opposes passage of H.R. 8508 or any similar legislation, without public rings upon adequate advance notice at which the spokesmen of maritime rkers may be heard; and

. The AFL-CIO Maritime Committee urges that full hearings be held on s bill before it is reported or action taken on it; and

. The AFL-CIO Maritime Committee urges Members of Congress to refuse cial-interest legislation requests by Matson Navigation Co. or any other steamp company or group of companies which may seek to weaken the structure of ety of life at sea through radio in the interest of increasing profits through ing the costs of providing safety; and

The AFL-CIO Maritime Committee will take all steps necessary to insure t profit-greedy steamship companies do not succeed in attempts to reduce ety under pretexts of so-called technological improvements, automation, mechzation, or otherwise. We will protect the lives of seamen and passengers on comated and mechanized vessels and in the waters navigated by such vessels ly as much as on conventional ships. We view attempts to remove radio ofrs, who provide the maximum degree of safety, both preventative and redial, as attempts to reduce the survival possibilities of seamen and passengers en faced with the hazards of the sea.

Adopted: February 21, 1964.

BAL HARBOUR, FLA.

APPENDIX E

DEFINITION OF RADIO OFFICER

Section 2(a). As used in this agreement, the term 'Radio Officer' shall an any person employed by the Company who operates and maintains a Radio tion, including radiotelegraph, radiotelephone, or any electronic devices used communicating between vessels and/or between vessels and shore, on any of · U.S. Flag vessels operated by the Company pursuant to Section 1, and o is authorized by the proper authority to operate and maintain a mobile dio Station including any communication devices as aforesaid.

To assure proper operation and maintenance of the above mentioned comnications equipment, the Union and the Company agree that all persons who rate and/or maintain such equipment shall be holders of a valid first- or ond-class Radiotelegraph Operator's License."

JURISDICTION OF ARA

Section 3(b). The Union shall have complete jurisdiction over all work olved in the operation and/or maintenance of all radio and/or electronic comnications devices as described in Section 2 ( a ).”

DUTIES OF RADIO OFFICER AND LOCATION OF RADIOTELEPHONE

Section 22(a). Radio Officers shall perform all duties incident to the operan and maintenance of all radio and/or electronic communications devices on sels operated by the Company. All radio and/or electronic communications rices, described in Section 2(a), including Radiotelephone, when carried, shall located only in the Radio Room and shall be operated and maintained only the Radio Officer."

PAYMENT FOR RADIOPHONE OPERATION

Section 23(b) 16. (A) On freighters which carry radiotelephone equipment, · Radio Officer shall receive additional basic monthly wages of Ten dollars ty cents ($10.40) effective June 16, 1961, Ten dollars dollars sixty-three cents 10.63) effective June 16, 1962, Ten dollars eighty-seven cents ($10.87) effective ne 16, 1963, and Eleven dollars eleven cents ($11.11) effective June 16, 1964, · operating the Radiotelephone during regular watch hours. Overtime shall payable for all Radiotelephone operation outside of regular watch hours for ndling of ship's business only. Radiotelephone calls other than ship's business