The FCC Weighs In

For background, please see the original TracMe article, “That’s No Personal Locator Beacon! – When is a Personal Locator Beacon not a PLB?”

On Wednesday of this week, just as I was getting ready to leave for Salt Lake City to attend Outdoor Retailer, I received an email that included the latest posting to the TracMe file on the FCC’s web site. This was an email to TracMe from the FCC, as well as copies to both the test lab and American TCB, the Telecommunication Certification Body (TCB) that actually issued the TracMe FCC certification (for many lower powerd equipment such as FRS radios, the FCC farms out the approval process to TCBs that do all the work and the FCC just accepts it unless a challenge is raised by someone.)

Well, it seems that the U.S Coast Guard convinced the FCC that TracMe’s use of “Personal Locator Beacon” to describe their device was inappropiate. The FCC wrote:

“Subject: This is a Part 95B device – Not a Personal Locator Beacon (95K)

The US Coast Guard has requested that the applicant change the Description field from Personal Locator Beacon to a description of the applicants choosing that is more representative of the device. The description, “Personal Locator Beacon” (PLB), is an equipment class for Part 95K devices. This is a Part 95B device. The US Coast Guard and the FCC feel that this is a misrepresentation of the device and could result in confusion with safety-of-life Part 95K PLBs. Please modify the description to something other than Personal Locator Beacon.”

Note that the date on this email is July 10, fully 2 1/2 weeks prior to my email exchange with Joe Rainczuk, CEO of TracMe, when he defended their use of the term even though he already was advised by the FCC that they too had finally determined that its use was a misrepresentation (read Joe Raiczuk’s email).

It takes approximately 30 days for items to be posted on the FCC site, which is why we didn’t find it until the last minute, but they surely knew.
The FCC goes on the say:

The items indicated above must be submitted before processing can continue on the above referenced application. Failure to provide the requested information within 30 days of the original e-mail date may result in application dismissal pursuant to Section 2.917(c).

In other words, get this fixed and don’t be slow about it.

With the delayed posting, their response won’t be known for potentially another 30 days, if they waited to the last minute to do so…or unless they let us know what is the new name they have chosen. Or, perhaps they are going to contest the issue in court. Typically, going up against the FCC is a fool’s errand, and a very expensive one at that.

I wanted to see how TracMe reacted to this FCC action at Outdoor Retailer before commenting. Fast forward to OR where Friday is the 30th day and where they have made not the slightest effort to do anything about the issue. Everywhere you look it was “TracMe Personal Locator Beacon.” Being fair, you’d not expect that on short notice they could change everything, but you would think they would at least make some effort. Apparently not…

Update: TracMe to FCC: You Can’t Make Us

The ETS evaluation of the TracMe is now available: www.equipped.org/tracme_eval.htm

TracMe’s Next Act…

Given the forces arrayed against them, you’d think they’d get the message and do the right thing instead of being so difficult, but to top it off, he’s decided to misrepresent my position regarding his product. Since I posted my blog entry and issued press releases, he has posted on the TracMe web site News page a photo of he and I shaking hands when he was here with an early prototype of the unit to demonstrate it to me (link to TracMe News page).

His posting of this photo is an obvious effort to somehow counter my efforts to critisize his misuse of the PLB nomenclature for his homing beacon by implying some sort of endorsement by me of the TracMe beacon. He falsely exaggerates the results of that very cursory demonstration and takes my comments made that day out of context.
If you haven’t figured out by now, I have not endorsed this beacon. I haven’t published anything negative either. I haven’t even completed our evaluation or published the results. The only thing I have done is related to his misrepresentation of the beacon as a PLB. I took this action because of their marketing push, so as to ensure that consumers and journalists are aware of the issue. My associates are this weekend conducting some additional testing to determine maximum range under optimum conditons and in various orientations, which previous testing suggests may be critical.

Bottom line is we have demanded that TracMe remove my name and photo from the site (read the lawyer’s demand letter).

We’ll keep you apprised of developments.

The ETS evaluation of the TracMe is now available: www.equipped.org/tracme_eval.htm

UPDATE: Friday, August 24, 2007: TracMe has removed the image and text.

When is a Personal Locator Beacon not a PLB?

406 MHz Personal Locator Beacons (PLBs) are earning a well-deserved reputation for saving lives. These personal-sized distress beacons (large pocket sized) use the same technology that’s been used in marine and aviation (EPIRBs and ELTs) for many years and saved thousands of lives. If you’re headed out into the backcountry, especially if solo, you should be carrying a PLB. Recently, a new product introduction has led to confusion regarding PLBs. Let’s clear up the confusion.

Since 1990 the international COSPAS-SARSAT search and rescue organization has been using the term Personal Locator Beacon in official internationally recognized published documents to describe this distress beacon and regulate its minimum performance.

When activated, PLBs transmit a 5-watt digital signal to two types of satellites that are part of the COSPAS-SARSAT search and rescue system. Low Earth Orbiting satellites use Doppler technology to provide search and rescue (SAR) a distress alert (in other words, notification that you need help) and your location in no more than 90 minutes anywhere in the world and generally within 45 minutes in North America. Between 70 degrees north and south latitudes (which covers most of North and South America, for example) they also transmit to Geostationary satellites orbiting 22,300 miles up over the equator, providing a distress alert within just 3-5 minutes. If equipped with GPS, and most PLBs sold today are GPS equipped, they can also provide your location as well, again in just 3-5 minutes.

Free registration that includes emergency contacts allows SAR to quickly confirm if the distress alert is real and often provides additional useful information to those coming to rescue you. PLBs function worldwide, they can be used as easily in Africa or Antarctica as in Arizona or Alaska (though the actual rescue may take longer in some places than others).

Location accuracy is within 2 miles for a Doppler position and within 100 yards for a GPS enhanced position. In real life, even with just the Doppler position responders to 406 MHz beacon alerts often fly to the location provided and immediately locate the survivors within view. PLBs are also equipped with a lower powered 50 milliwatt 121.5 MHz homing beacon that can be used for final location if necessary. This is the standard distress homing frequency used worldwide and SAR operators are equipped and trained to use sophisticated direction finding (DF) receivers that operate on this frequency. 406 MHz DF equipment with even better performance is also now being fielded. The 406 beacon community likes to say that 406 MHz distress beacons take the “search” out of “Search and Rescue.” That equates to more lives saved.

Click here for an overview of how the COSPAS-SARSAT system works.

The 5-watt PLB distress signal is strong enough to penetrate even the heaviest forest canopy and has been shown to work even in deep narrow canyons and similar challenging terrain. PLBs are waterproof and abuse resistant.

The current generation PLBs weigh less than 10 ounces and cost about $650 with GPS. Previous generation PLBs, which weigh 12-14 ounces, cost from $450 – $550, without or with GPS, respectively.

Introducing the TracMe

The recently introduced “TracMe Personal Locator Beacon” is only $150 and weighs just 1.6 ounces. It is so small it could fit on your keychain. Because the manufacturer (TracMe Beacons Pty Ltd of Australia) is using the same PLB nomenclature, you might be tempted to believe it has similar capabilities to a real PLB, and given the lower price, weight and size, be tempted to purchase it as a distress beacon. Don’t!

A distress beacon that doesn’t notify someone you are in distress and provide location information is no distress beacon. TracMe is simply a homing beacon, nothing more.
The TracMe operates on FRS (Family Radio Service) channel 1. Yes, the same FRS frequency as used by those ubiquitous inexpensive “walkie-talkies” you see at Wal-Mart, Cabela’s and elsewhere.

When activated it transmits a recorded message, a beep and then “Help…Emergency,” every 15 seconds. This analog transmission does not serve as a distress alert, unless someone quite close just happens to be monitoring or talking on Channel 1, unlikely in most cases. Unless someone notifies authorities, for example that you are overdue retuning home, nobody knows you need help. Break a leg the first day of a 5-day backpacking or hunting trip and you’ll be waiting a long time for anyone to come looking. They also have to know to notify SAR that you are equipped with the TracMe device for it to be at all useful. (TraMe does provide an instructional card for SAR that you are supposed to leave on the dash of your vehicle at a trailhead. That only works in some scenarios.)

Once someone comes looking for you, the idea is that the TracMe device will allow SAR to locate you by homing on the transmission. Since virtually no one in the country is currently equipped to do so, and it requires a significant expenditure to buy the specialized DF equipment, as well as time and effort to train how to use it, you certainly can’t count on this capability anytime real soon. So, even with TracMe offering their DF kit (image right) on loan for training, that’s at best only a start and it’s a big country out there. It’s a classic chicken or egg situation.

The TracMe transmits at “less than 10 mW” (compared to 500 mW for an FRS radio), so range is very limited. TracMe claim 5 miles, but that is under ideal conditions, and supposedly 20 miles with “specialist DF equipment” in an aircraft (look for a full report on ETS soon, but probably not until after the Outdoor Retailer show next week). FRS is line of sight so in even moderately difficult terrain, it is easily blocked. If you’ve ever used FRS radios, even with their 50 times more powerful transmitter, you understand the limitations. The search team requires a pretty good idea where to come looking for you in the first place, or they don’t stand a chance, and neither will you.

If direction finding equipment is not available, the likely scenario at least in the near term, the only other way to locate you is to box your position with FRS radios and then look towards the center of the plotted locations. In other words, SAR crews have to find the limits of reception of the signal in multiple directions and mark that on a map. That can be time consuming and difficult in anything but unchallenging terrain. Using an aircraft when one is available, this method can more easily cover larger areas to narrow the search area. This is all better than nothing, but a far sight less effective and more time consuming than DFing the signal.

TracMe explains the limitations and does state that it isn’t a 406 MHz PLB, but that doesn’t mean everyone will read the “fine print” or understand it. This is not only true of consumers, but also of retail salespersons who may not be adequately trained or who are more interested in making a sale. There are significant concerns in the SAR community, including the responders and providers, not just manufacturers of 406 MHz PLBs; that people will purchase this so-called Personal Locator Beacon believing that it provides the considerable capability of a real 406 MHz PLB. That could end up killing someone.

They have expressed their concerns to TracMe and TracMe have chosen to disregard their concerns. TracMe feel that their disclaimers adequately address this. However, TracMe also says in their literature and on their web site that TracME is “suitable for” (among others listed): Yachting, Boating, Fishing, Kayaking, Canoeing, Climbing, General aviation, Outback 4 wheel driving and “all outdoor adventure activities“. Oh, really?

The seriousness of this issue was brought home to me as the result of recent emails enquiring about this so-called PLB for uses that would only be appropriate for a 406 MHz PLB. However, most consumers are not going to be writing me for advice. There is definitely already confusion out there, and TracMe is just barely starting to ramp up their marketing efforts.

Whether or not the TracMe device is a viable and effective solution for locating people who are lost or in distress is an entirely separate issue which has yet to be determined (look for a full report on ETS soon, but probably not until after the Outdoor Retailer show next week). TracMe may well have a place in the effort to save lives, however, it should be obvious after this brief comparison that it is not a PLB in the sense of the widely accepted use of the term in either the SAR community or the public at large. This is not the PLB that we have come to know as a result of recent rescues and considerable news coverage.

Bottom line is that a real 406 MHz PLB alerts authorities that you need help, tells them where you are and also tells them who you are. The TracMe does none of that. A true PLB, in my opinion and that of most SAR authorities, provides satellite distress alerting and inherent location capability that really can save your life.

TracMe says, “most simply, we call it that because it is – using ordinary English – an accurate and precise description…Our lawyers and trademark offices around the world have called the phrase personal locator beacon a generic description of the device.” It is possible that it is, indeed, entirely legal, COSPAS-SARSAT wasn’t prescient enough to trademark the term, but is it ethical?

Call me cynical, but in my opinion there’s really only one logical explanation for TracMe to have chosen to call their device a PLB. They could have used any number of equally descriptive and marketable names. However, then they wouldn’t have benefited from all the publicity that PLBs have received and will likely continue to receive.

In any case, the important point is that as they escalate their marketing efforts you should not be confused by TracMe’s misleading, in my opinion, use of “Personal Locator Beacon;” caveat emptor.

Follow-on Blog entry: TracMe: Curiouser and Curiouser – FCC to TracMe: It’s NOT a PLB!

The ETS evaluation of the TracMe is now available: www.equipped.org/tracme_eval.htm

Links:

TracMe

Equipped To Survive “Ultimate Personal Locator Beacon FAQ”

NOAA SARSAT

406 MHz PLB Manufacturers (currently available to consumers in the U.S.):

ACR Electronics

McMurdo

With yesterday’s tragic collapse of the bridge in Minneapolis, once again people are asking what they could do to escape their car if they suddenly found themselves underwater.

First, you must stay calm. Second, you cannot open the door, you must escape through the windows. If the windows are already open, you are more or less home free, assuming you were able to get a full breathhold before the water fills up the car.

All windshields are laminated glass which you cannot escape through. Side windows are almost always tempered safety glass that will shatter and crumble into small bits if struck with a sharp object or with a blunt object and enough force.

Once the window is broken, the water will rush in and you will have to wait until the car is pretty much full to get out, you can’t fight against the incoming rush of water. So stay calm, hold your breath once the water gets high enough, then release your safety belt and swim out through the window.

It’s best to stay buckled in until you are ready to leave. Be prepared to cut the belt if the release is jammed.

As with so many other survival situations, having the right tool makes surviving much easier. There are two readily available tools specifically designed to help you escape a car, underwater or not, that will do the job, the Life Hammer and the Res-Q-Me.

My pick is the Res-Q-Me since it is so compact and easy to use. It’s what I carry. It’s small enough to fit on your key chain. This makes it readily available if needed, but you can also hang it from the seat belt or var visor and any other secure location in the car. It has to be secure and within easy reach. You don’t want it to get lost in an accident because it wasn’t securely held in place.

The Res-Q-Me has the two essential tools you need. Pull it loose from the clip that is used to attach it to your key rig or a split ring or chain and a safety cutter is revealed. This is a miniature version of the seat belt cutters used by safety and rescue personnel.Just slide the belt into the slot and the razor blade easily cuts it.

At the other end is an automatic punch. Just press it hard against the window and the spring will automatically drive the pointed punch into the glass, shattering it. It’s that easy.

If you’re traveling in your car and going to be next to water (along a shore or on a ferry) or over water (bridge), you owe it to yourself and your passengers to carry a tool that will help you to escape.

Renowned mountain flying instructor and author of Mountain Flying Bible, Sparky Imeson, was involved in a crash during an instructional flight in Montana over the weekend. He and the student survived. Details can be found here in this article.

The part that has me puzzled is why an experienced person like Sparky would leave the crash site. Hopefully we’ll eventually be able to talk to him about it, but for now this serves as a good object lesson.

Had Sparky stayed put, he would have been located early Monday morning, not Monday afternoon. This is pretty typical. Someone goes for help and they either are rescued far later than the victims left at the original accident site, and often in worse physical shape, or they die trying to get help while those who were left behind survive (the Kim tragedy being a perfect example of the latter. This is a pretty common scenario for SAR to see.

Usually, you want to stay at the crash site (or accident site or wherever you find yourself lost) unless there are extraordinary extenuating circumstances that make it unlikely anyone will come looking for you or no shelter is available. If leaving, be sure you know where you are going and how you will get there, leaving a note and preferably a ground signal indicating the direction taken. But, it is almost always better to Stay Put!

If they had a 406 MHz Personal Locator Beacon (PLB) the issue would have been solved. Based on the time line in the article, with a PLB they would likely have been rescued Sunday afternoon. Even better.

For pilots, let me stress that the ELT in your aircraft is NOT reliable. Doesn’t matter even if it is a 406 MHz unit. Too many things can go wrong and the ELT will not work, including the aircraft burning up, as was the case in this instance. In my opinion, an ELT should be treated as backup to a PLB.

I look forward to talking with Sparky about this incident, but in the meantime, don’t try to be a hero. Stay put and let Search and Rescue have its day.

Additional information: Sparky Imeson’s Mountain Flying Web site.

For a long time I and others have been suggesting that NOAA could save money by eliminating the NOAA proof of registration decal for PLBs and ELTs. This was originally designed for use on EPIRBs where there are regulatory requirements for commercial vessels that the Coast Guard check that the EPIRB is registered. When the regulatory standards for 406 MHz ELTs and then PLBs were developed from those original EPIRB standards, the requirement for the decal was left in, even though it served no real purpose.

This has become a more serious issue as PLBs became smaller and smaller. The real estate on the beacon taken up by the decal has become an ever increasing portion of what little space is available. It could be put to far better use. Meanwhile, most owners who registered their 406 MHz ELTs couldn’t access them to apply the decal anyway. That ELT is buried in the tail where they cannot easily reach it or would have to have a mechanic do the deed. All for no good reason. Bottom line is that virtually nobody applied the decal to either PLBs or ELTs, but every two years NOAA sent out a new decal with updated registration.

NOAA has finally seen the light and announced at the 2007 Beacon Manufacturers Workshop last week that they would be eliminating the decal for PLBs and ELTs. They will still require a notice that the beacon has to be registered, but that will be far less onerous and simple and costs the government nothing.

NOAA spokesperson Lt. Jeff Shoup said it would take about two months for the change to go into effect. It still needs to be published in the Federal Register before then and they are still working out changes to their process to cope with the elimination.

Let me emphasize that the proof of registration decal is still required for EPIRBs and that this does not eliminate the need to register your 406 MHz ELT and PLB. Registration is critical to gain all the benefits from the COSPAS-SARSAT system.

It’s a small victory for common sense, but we’ll celebrate any we can get. Thanks NOAA!

Doug Ritter Introduces First Ever Paul® Knife Collaboration

Gilbert, Arizona – Doug Ritter today introduced the first ever collaboration with Paul W. Poehlmann, the creator of the Paul® Knife. The Doug Ritter RSK Mk4 Gentleman’s Folder™ is a limited edition run of 300 serialized knives based on the original Paul® Presto and produced by Lone Wolf Knives®. Ritter added his signature wide chord drop point blade and special high grade materials and finishes.

The high grind 2.4-inch blade is made of Crucible’s superb CPM S30V high carbon stainless steel with Ritter’s signature stonewashed finish and the recuved edge of the original Presto. The Presto’s stainless frame is also stonewashed. The patented Paul® Axial Lock allows ambidextrous one-hand opening.

The handle overlays are custom laid silver tweed G-10 composite, CNC machined to reveal the beautiful weave with a satin finish. This represents the first ever use of these materials and finish on a Paul® Knife.

The blade and handle flow together in a perfect balance of grace and style. Taken all together this is an elegantly understated and striking folder that is also very functional

The wide chord and high flat grind provide a more acute cutting edge angle for better slicing capability. The blade’s spine incorporates a more prominent ramped thumb rest for enhanced control and security.

“This is not simply a lightweight gentleman’s folder or show piece. I took it out and beat the crap out of it, using it just as I would my utility/survival folders. It performed solidly and retained its edge as you would expect from an S30V blade. It is truly a superbly practical and robust knife, much more than just a pretty face,” said Doug Ritter.

“I am pleased beyond words with your new RSK Mk4™ Paul® Presto Folder. Truly a homogenous combination of design, premium materials and outstanding workmanship,” said Paul W. Poehlmann.

The Doug Ritter RSK Mk4 Gentleman’s Knife™ is priced at $182 and is available exclusively from Aeromedix.com starting at 12:00 Noon EDT on Tuesday, May 15th. Aeromedix is offering complimentary FedEx Ground shipping (continental U.S. only until May 31).

For additional details, images, etc. on this extraordinary knife, see: www.DougRitter.com/DR_RSK_Mk4.htm

A lot of us involved in the outdoors and survival have for years used Foodsaver home vacuum packaging equipment. There are lots of advantages to vacuum packaging your supplies and gear including reduced volume, protects the contents, longer shelf life, and more. It was not cheap and the special bags and bulk rolls of vacuum packaging material have always been something of a rip-off, but compared to the alternative, it was relatively affordable. On the positive side, it worked reasonably well and you could make up really small packages with little effort.

Unfortunately, their version of progress leaves us out in the cold. My older Ultra model finally started to give out. The vacuum was getting a wee bit weaker, taking longer to suck things down and the sealer strip wasn’t doing very well sealing. In the midst of doing a project, it was obvious I needed to get a replacement…right now! Off to Costco to grab one off the shelf for $129. The price of expediency.

When I got it home and unpacked the new machine I discovered that the bastards had made two changes that might work well for their bottom line, but screwed us. The designed the new unit so that it is impossible to seal right up close to the item being packaged, leaving at least one inch of material between that and the seal, then another inch between that and the vacuum chamber. (See photo below showing the new one (black) and the old one (white). Click on photo for higher resolution image)

How convenient that they now waste even more of their proprietary material. That’s money in their pocket. Plus, we can no longer make up vacuum packages as small as before. OK, I’m not happy, but it’ll do until I can get my old machine repaired.

WRONG! They no longer offer service or repair of older models. The best you can hope for is a discount coupon on a new machine. Isn’t that customer friendly?

I have avoided upgrading to something like the SINBO snorkle style machine due to the initial expense of buying the larger quantities of packaging material. Even though in the long run it is cheaper, in the short run it requires quite an outlay of cash. I may not have much of a choice now. (UPDATE: Bought a SINBO and haven’t looked back.)

Let this be a warning to anyone thinking about buying a Foodsaver. The company and its products suck, and we’re not just talking about vacuum here.

Chris Venti, with a management background from General Electric, has purchased the assets of Survival, Incorporated, maker of the StarFlash signal mirror, BlastMatch and StrikeForce firestarters, WetFire Tinder and SaberCut Saw, among others. These were also marketed to civilians under the Ultimate Survival brand. The new company is called Ultimate Survival Technologies. Financial backing has been provided by The Insight Group. Survival, Inc. founder Rick Stewart is not associated with the new company.

All of the existing inventory has been moved into their manufacturing facility in Monroe, Washington. Current inventory is limited, but new production is expected to commence shortly. Their new web site is: www.ultimatesurvival.com

Contact:

Ultimate Survival Technologies
14428 167TH Avenue SE
Monroe, WA 98272-2915
206-965-9660
Toll Free: 866-479-7994
Fax: 206-965-9659

Since Survival, Inc. went under, I’ve received hundreds of phone calls and emails looking for their products or alternatives. This latest development should make a lot of folks very happy. I wish the new company the best of luck.

Seems like I touched a raw nerve during my interview on The Ten Essentials (see my previous blog entry). On the ETS Survival Forum a few folks have taken issue with my assertion that because so few people know how to use a map and compass today, they would do better to include a mapping GPS as the first of the Ten Essentials. Noted one poster, “Doug, I’m shocked and appalled. Blindly depending on only a GPS is a good way for the unwashed masses to get themselves into big trouble.”

He then goes on to suggest in another post, “How about Stay out of the !@#%&* woods until you can grasp the most basic fundamentals of using a map and compass.”

My response:

How about being realistic?

Reality is what it is. You cannot change human nature and you cannot legislate common sense. I can try to encourage the use of available tools that may actually get used. Will some misuse them or be stupid? Sure, but we don’t stop putting anti-lock brakes on automobiles because a well-trained driver in many cases can stop shorter with more control or because some people are encouraged to take more risks in adverse conditions assuming they will save them. Overall, it saves lives.

I’ll stick with my advice because I know that it’s the best overall solution considering the audience and the reality that is out there today. That’s my job. I don’t allow myself the luxury of being idealistic. It’s counterproductive.

Read the whole thread here and offer your own thoughts.

Steve Sergeant, Producer and Host of The WildeBeat recently interviewed me for a show on the subject of “The Ten Essentials.” Here’s his introduction and links to the show:

Since it’s mysterious introduction by the Mountaineers early in the twentieth century, the 10 Essentials have been the list that everyone should know, and few could recite with certainty. In this edition, Doug Ritter, the executive director of the Equipped To Survive Foundation, and Amy Racina, author of the book Angels in the Wilderness, compare notes on some of their ideas of the 10 essentials.

http://www.wildebeat.net/index.cgi/shows/skills/E079.html

Includes link to combined first and second parts, which would be the best way to listen. If you prefer to read rather than listen, there is also a transcript of both shows available on this page.

Also, at http://www.wildebeat.net/supplements/E079/ there are some additional portions of the interview with me that weren’t included with the two part show itself, a bonus as it were.