https://ecfsapi.fcc.gov/file/107291223105915/Icom%20Ex%20Parte%20Comments%20In%20Maritime%20Rule%20Making%207-29-2016.pdf
They make quite interesting reading. For anyone interested in DSC radio operation, I recommend visiting the above link and reading ICOM's remarks. ICOM points out that the FCC has already changed their rules regarding DSC radio features several times without seeking public comments before implementing the change, resulting in the adoption of rules that require mandatory inclusion into DSC Class-D radios of complex and unnecessary features. ICOM further asserts that "few (if any)" DSC radios on the market now provide these features. They also comment that "requiring these parallel procedures, introduced as part of Rev. 13, only serve to needlessly increase the cost of Class D equipment for services not necessary for recreational use." ICOM says, in part:
Icom’s review of the equipment capabilities of other manufacturers of VHF-DSC
equipment is that few (if any) manufacturers comply with the following provisions of
ITU-R M.493-13 Annex 4: 1; 2.19; 2.21; 2.22; 3.1.5; 3.2.5; 3.2.5.1; 3.3.3.1; 3.2.5.2;
3.2.5.3; 3.2.6; 3.2.6.1; 3.2.6.2; 3.2.6.3; 3.3.1; 3.3.2; 3.3.3.2; and 3.3.4. Each of these
provisions are automated procedures that run in parallel with other automated procedures.
Icom respectfully requests that the Commission undertake a complete review of [ITU-R M.493-14]
requirements, and adopt only those alterations which are mandatory, or otherwise found
to be important for United States ships. Further, until the Commission completes its
review of these provisions, Icom urges the Commission to temporarily waive the rule
provisions cited below, pending the outcome of this proceeding.
Regarding the proposed changes recommended by the Radio Technical Commission for Maritime Services (RTCM), their recommendations can be found at
https://ecfsapi.fcc.gov/file/60001459665.pdf
The FCC's request for comments can be found at:
https://ecfsapi.fcc.gov/file/60001569598.pdf