AMSAT Files Comments Opposing Deletion of 3.4 GHz Band

FCC SealAMSAT has filed comments on the Federal Communications Commission’s Notice of Proposed Rulemaking which proposes to delete the 3.3 – 3.5 GHz (9 cm) amateur band, including the 3.40 – 3.41 GHz amateur satellite service allocation.

In the comments, AMSAT opposes the deletion of this allocation and emphasizes the necessity of adequate microwave spectrum for future amateur satellite projects, including AMSAT’s GOLF program and the Lunar Gateway.

AMSAT further notes that the most desirable allocations for use as uplinks are the allocations between 2.4 and 5.67 GHz. These allocations total 80 MHz. The most desirable allocation for downlink use is the 10.45 – 10.50 GHz allocation, totaling 50 MHz.

As many of the proposed uses include amateur television and high-speed data transmission with satellites in high earth orbit or lunar orbit, these allocations may quickly become inadequate. AMSAT also notes that the 2.4 and 5.67 GHz allocations are widely used for ISM and consumer devices, such as WiFi and Bluetooth-enabled devices. The 3.4 GHz allocation is shared between amateur use and other non-federal and federal licensees, but is free from the unpredictable interference of consumer devices.

While acknowledging that the 3.4 GHz amateur satellite service allocation is not currently used by any amateur satellites and that it is unsuitable for worldwide communication since it is not available in ITU Region 1, AMSAT identifies a number of potential future uses for the band as worldwide usage of the other available allocations increases. These potential uses include a future amateur satellite in geostationary orbit above the Americas.

In the comments, AMSAT also noted several non-amateur satellite uses of the broader 3.3 – 3.5 GHz amateur service allocation, including its wide use in mesh networking, EME communications, and contesting.

The full text of the comments as filed can be downloaded at https://tinyurl.com/ANS-054-FCC

Interested parties may file reply comments on or before March 22, 2020 at https://www.fcc.gov/ecfs/
The proceeding is WT Docket No. 19-348.

Source AMSAT News Service (ANS)

AMSAT in special 300th edition of ICQ Podcast

The popular ICQ Amateur Radio Podcast has been running for over 11 years and on August 4, 2019, the ICQ Podcast team released their 300th edition which features an interview with Treasurer and Past President of AMSAT Keith Baker KB1SF.

The first edition of ICQ Podcast was released by Father and Son team Martin Butler M1MRB and Colin Butler M6BOY on July 6, 2008 and since those early days the show has gone from strength to strength.

Released fortnightly on a Sunday at 0900 GMT the ICQ Podcast is available either as an MP3 download or as a YouTube version with optional auto-generated subtitles.

In the 300th edition, Martin Butler M1MRB is joined by Chris Howard M0TCH, Dan Romanchik KB6NU and Frank Howell K4FMH to discuss the latest Amateur / Ham Radio news and this episode’s special feature is the interview with AMSAT’s Keith Baker KB1SF which begins at 1:10:30 into the show.

ICQ Podcast Episode 300 with AMSAT Treasurer and Past President Keith Baker KB1SF

ICQ Podcast https://www.icqpodcast.com/

Keith Baker KB1SF https://twitter.com/kb1sf
Martin Butler M1MRB https://twitter.com/M1MRB
Colin Butler M6BOY https://twitter.com/colinbutler
Chris Howard M0TCH https://twitter.com/m0tch_chris
Dan Romanchik KB6NU https://twitter.com/kb6nu
Frank Howell K4FMH https://twitter.com/frankmhowell

AMSAT Files Comments in FCC Orbital Debris Mitigation Proceeding

Amateur Radio Satellites - To inspire, engage and educate the next generation

Amateur Radio Satellites – To inspire, engage and educate the next generation

AMSAT believes several of FCC’s proposed rule changes concerning orbital debris would have an extremely detrimental affect on the amateur satellite service.

The AMSAT News Service Reports:

The Federal Communications Commission has proposed several rules changes related to the amateur satellite service as part of a Notice of Proposed Rulemaking (NPRM) related to the mitigation of orbital debris. AMSAT believes several of these rule changes would have an extremely detrimental affect on the amateur satellite service and AMSAT’s ability to launch and operate new satellites, including AMSAT’s upcoming GOLF satellites.

Today, AMSAT filed comments on the proposed rulemaking. In the comments, AMSAT argues that amateur satellites often have longer mission lifespans than other small satellite missions and that the Commission should take a mission duration of 5 to 10 years into account when determining whether or not an amateur satellite will meet the orbital debris regulations by transferring to a parking orbit or re-entering the atmosphere within 25 years of mission completion. The current practice is to assume a “zero year” mission and to require that amateur satellites either transfer to a parking orbit or re-enter within 25 years following launch.

AMSAT also urged the Commission to consider alternatives to a proposed rule that would restrict satellites in Low Earth Orbit that plan to meet the orbital debris mitigation guidelines through atmospheric re-entry to altitudes of 650 km or less. AMSAT noted that, had this rule been in place, AO-85 and AO-91 would not have been able to be deployed in their current ellipitcal orbits with apogees of approximately 800 km, despite the fact that both of these satellites will re-enter within 25 years due to their low perigees. Additionally, AMSAT noted that current plans for the GOLF-1 satellite are to meet orbital debris mitigation guidelines through atmospheric re-entry by deploying a drag device that will ensure re-entry within 25 years despite deployment at an altitude of above 1,000 km. This proposed rule would prohibit GOLF-1’s deployment at that altitude.

The Commission’s proposed rules would also require that amateur satellite licensees indemnify the government against any claims made against the United States due to the operation of the satellite. AMSAT believes this proposal would end the ability of AMSAT, or any other entity in the United States, to launch and operate amateur satellites and urges the Commission to consider alternatives, such as establishing a fund to pay any such claims, noting that the likelihood of such a claim is low.

For amateur satellites with propulsion, the Commission proposes a rule that would require any command links as well as satellite telemetry be encrypted. While AMSAT understands and agrees that a satellite carrying a propulsion system must have an encrypted command link, the proposal to require all satellite telemetry be encrypted is unnecessary and counter to the spirit of the amateur service. AMSAT notes that open access to telemetry is expected of amateur satellites and is critical to the educational component of amateur radio satellites.

Finally, AMSAT proposes that the Commission exempt amateur space stations co-located on other spacecraft from the orbital debris mitigation regulations, including any indemnification rule. Noting that AMSAT has pursued opportunities to fly a payload as a rideshare aboard government or commercial satellites, AMSAT argues that, as the satellite’s owner will need to meet orbital debris mitigation requirements to obtain the license in the primary mission’s service, requiring the amateur licensee to meet the orbital debris mitigation requirements as well is redundant. AMSAT proposes that Part 97 be amended to state that amateur space stations co-located on spacecraft with space stations authorized under Part 25 of the Commission’s regulations (for commercial spacecraft) or by the National Telecommunications and Information Administration (NTIA) (for government spacecraft) are exempt from these regulations.

AMSAT’s comments as filed may be downloaded at https://tinyurl.com/ANS-095-Comments

The NPRM is International Bureau Docket #18-313 and is available at
https://docs.fcc.gov/public/attachments/FCC-18-159A1.pdf

Interested parties may file reply comments by May 5th at https://www.fcc.gov/ecfs/

[ANS thanks AMSAT Executive Vice President Paul Stoetzer, N8HM, for
the above information]

Register for AMSAT News Service emails at https://www.amsat.org/mailman/listinfo/ans

FCC rejects AMSAT Orbital Debris Petition

FCC SealARRL reports the FCC has rejected a Petition for Reconsideration that AMSAT filed 14 years ago, seeking to exempt Amateur Radio satellites from the FCC’s satellite orbital debris mitigation requirements.

The ARRL story says:

The Commission took the opportunity in a Notice of Proposed Rulemaking and Order on Reconsideration, released on November 19, that revisits its orbital debris rules for the first time since their adoption in 2004. Among other things, AMSAT had argued at the time of its Petition that applying the orbital debris requirements to Amateur Radio satellites would be cost prohibitive, and that the FCC had not indicated what constitutes an acceptable orbital debris mitigation plan.

Acknowledging that time has made some of AMSAT’s arguments moot, the FCC said the costs involved with modifications to comply with post-mission disposal requirements “are justified when balanced against the public interest in mitigating orbital debris.” The FCC said it determined that closer adherence to the disposal methods described in the rules was “warranted in order to limit the growth of orbital debris” in low-Earth orbit (LEO).

“In any event, in the years since the debris mitigation rules were adopted, and notwithstanding any costs imposed by FCC regulations, well over 150 small satellites have been authorized, with at least 20 of those considered amateur satellites,” the FCC said in its November 15 Order on Reconsideration. “It appears that, to the extent that any costs have been incurred, the main contributor to costs for amateur and similar LEO missions has to do with the availability of launches to appropriate orbits.”

The FCC also said that in the years since the FCC issued its Orbital Debris Order, “numerous licensees, including amateur satellites operating in LEO, have successfully satisfied our orbital debris mitigation requirements.

FCC Notice of Proposed Rulemaking and Order on Reconsideration
https://docs.fcc.gov/public/attachments/FCC-18-159A1.pdf

2004 AMSAT Petition for Reconsideration
https://ecfsapi.fcc.gov/file/6516493220.pdf

2004 FCC Second Report and Order IB Docket No. 02-54
https://docs.fcc.gov/public/attachments/FCC-04-130A1.pdf

Source ARRL http://www.arrl.org/news/fcc-rejects-2004-amsat-petition-to-reconsider-applying-orbital-debris-rules-to-ham-satellites

Videos of AMSAT Symposium talks

Videos of the presentations given at the 2018 William A. Tynan W3XO Memorial Space Symposium in Huntsville, Alabama, on Friday/Saturday November 2/3 are now available

Schedule of symposium presentations https://www.amsat.org/call-for-papers/

Watch Friday, November 2

Watch Saturday, November 3

Detailed information on the hunt for XO53

SSETI Express LogoFollowing on from the brief notes provided earlier, AMSAT-UK now have been given exclusive access to the full SSETI Express Phase E 400-800 THz Downlink Report. This report provides a clear insight into the work carried out during their recent campaign and to methods and equipment used.

It is worthy of note that ten years ago there was only one radio amateur in the launch team and that, since then, four of the other five team members have now obtained their licences.

Read the EXPRESS_E_ESA_2015-11-14_-_400-800_THz_Downlink_Report

As the report states, further observations will be much appreciated!