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!

Michael Ossmann AD0NR at Chaos Computer Camp

Rad1o Badge 50-4000 MHz SDR Transceiver given to attendees at the Chaos Computer Camp 2015

Rad1o Badge 50-4000 MHz SDR Transceiver given to attendees at Chaos Computer Camp 2015

The lectures at the Chaos Computer Camp, taking place August 13-17 in Mildenberg, Germany, are being streamed live to the web.

Mike Ossmann AD0NR – Image Credit www.insinuator.net

Mike Ossmann AD0NR – Image Credit http://www.insinuator.net

Among the attendees is radio amateur Michael Ossmann, AD0NR, who was guest speaker at the 2015 Dayton Hamvention AMSAT / TAPR banquet.

The founder of Great Scott Gadgets he grew up as a computer nerd embracing the hacker ethos. Eventually Michael became very interested in the security of wireless systems such as a remote keyless entry, a garage door opener, Wi-Fi, and Bluetooth. He designed Ubertooth One, a Bluetooth sniffer that was successfully funded on Kickstarter.

Not one to rest, Michael later designed and successfully funded HackRF One, an open source SDR platform that attracted the attention of the amateur radio community.

The @rad1obadge issued to Chaos Computer Camp attendees is a full-featured 50-4000 MHz SDR Transceiver with an output power of 5-7 dBm.

It is based on a Wimax Transceiver which sends I/Q samples in the range of 2.3 to 2.7 GHz to an ARM Cortex M4 CPU.

Michael Ossmann AD0NR at Chaos Computer Camp 2015

Michael Ossmann AD0NR at Chaos Computer Camp 2015

The CPU can then process the samples stand alone for various applications (like FM receiving, Spectrogram display, RF Controlled power plugs, etc.) or send the samples via USB 2.0 to a Computer where they can be processed with the help of GNU Radio.

The extended frequency range is provided by a mixer that can be inserted into the RF path. For immediate usage, the board contains a 2.5 GHz chip antenna which can be replaced with an easily soldered Antenna connector for usage in different frequency ranges. The rad1o also contains an LCD and Joystick as did the r0ket from the last CCCamp.

A talk given on Thursday evening, August 13, covered the inception and creation of this year’s Rad1o Camp Badge. From a description of the hardware including differences to the HackRF one, the software concept and extension possibilities to first projects done by attendees. Michael Ossmann AD0NR makes a guest appearance towards the end of the video.

Watch the @rad1obadge 50-4000 MHz SDR Transceiver talk
https://media.ccc.de/browse/conferences/camp2015/camp2015-6884-the_rad1o.html

Watch the @SatNOGS Open Source Satellite Ground Station Network talk
https://media.ccc.de/browse/conferences/camp2015/camp2015-6926-satellite_open_ground_station_network.html

Chaos Computer Camp 2015 https://events.ccc.de/camp/2015/wiki/Main_Page

Live Streaming https://streaming.media.ccc.de/

Recordings are at https://media.ccc.de/browse/conferences/camp2015/

Schedule https://events.ccc.de/camp/2015/Fahrplan/

Rad1o transceiver with antenna socket - Credit Tom Theisen

Rad1o transceiver with antenna socket – Credit Tom Theisen

Watch the talk Adventures of a Hacker Turned Radio Ham which Michael gave at the AMSAT-TAPR Banquet at Dayton in May 2015.

In it he talks about his unique perspective on the community as an outsider looking in, why he resisted getting an amateur radio license for years, and why he finally decided to join.

Michael shares his thoughts on what it means to be a hacker, what it means to be a ham, and what amateur radio may look like in the decades to come
https://amsat-uk.org/2015/07/12/tapr-amsat-2015-talks/

Michael Ossmann AD0NR on Twitter https://twitter.com/michaelossmann

Antennas at Chaos Computer Camp 2015 - Credit Daniel Cussen EI9FHB

Antennas at Chaos Computer Camp 2015 – Credit Daniel Cussen EI9FHB

AMSAT’s FOX-1 Ham Radio CubeSat

AMSAT FOXIn HamRadioNow episode 85 Gary Pearce KN4AQ talks to a pair of AMSAT Vice Presidents – Tony Montiero AA2TX (Engineering) and Mark Hammond N8MH (Education) who tell us about the new Fox-1 Satellite.

They explain why AMSAT must transition from a bunch of hams who put up satellites for us to use, to a provider of the platform and communications for space science experiments for education (that also happen to have repeaters and transponders we can use).

Fox-1 is scheduled to launch from Vandenburg in November 2014 on the NASA ELaNa XII mission into a 470 x 780 km at 64 degrees inclination orbit. It will employ passive magnetic stabilization and carry a 435.180 MHz to 145.980 MHz FM voice transponder and an optional sub audible FSK digital carrier channel.

Watch HamRadioNow Episode 85: AMSAT’s Fox-1 Satellite

IARU Coordinates Frequencies for Fox-1A Ham Radio CubeSat
https://amsat-uk.org/2013/06/04/iaru-fox-1a-cubesat-frequencies/