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

FCC Satellite Related Filings

FCC SealFor easier navigation of US FCC Satellite related filings Luke Rehmann has built an RSS feed of the FCC’s ELS and IBFS systems.

The FCC Experimental Licensing System provides companies with temporary authorization to conduct temporary experimental wireless communication lab-testing, space launch/recovery communication, and other short-duration wireless communication needs
https://fcc.report/ELS/

The International Bureau administers international telecommunications and satellite programs and policies, including licensing and regulatory functions. The bureau also promotes pro-competitive policies abroad, coordinates global spectrum activities and advocates U.S. interests in international communications and competition
https://fcc.report/IBFS/

Galileo GNSS/GPS – FCC to vote on use of signals in USA

FCC SealThe Federal Communications Commission (FCC) has said it will vote in November on whether to allow U.S. GPS receivers to access the Galileo global navigation satellite system (GNSS).

From an Amateur Radio perspective the key part is that the FCC will only be voting to waive its licensing requirements for non-federal operations with Galileo channels E1 and E5, subject to certain technical constraints.

This means they will not be voting on the E6 channel 1260-1300 MHz, these frequencies are also Amateur and Amateur-Satellite Service allocations. This suggests for 1260-1300 MHz the situation in the USA will be unchanged, the unlicensed use of the Galileo signal on channel E6 will not be permitted for non-Federal operations in the USA.

Read the Reuters story which also says Ajit Pai is proposing the first comprehensive review of the FCC’s orbital debris rules since their adoption in 2004
https://www.reuters.com/article/us-usa-fcc-gps-europe/fcc-to-vote-to-allow-u-s-devices-to-use-european-navigation-system-idUSKCN1MY2X6

2006 article – Galileo and amateur radio operations in 1260-1300 MHz
http://www.southgatearc.org/articles/galileo.htm

FCC Invites Public Comment on 10-10.5 GHz Petition

FCC SealThe ARRL report the FCC has invited public comment on a Petition for Rule Making (RM-11715) that would make a significant portion of the 10.0 to 10.5 GHz band available for wireless broadband services.

The Petition by Mimosa Networks Inc proposes a band plan for 10.0 to 10.5 GHz that, it says, would protect frequencies most often used by radio amateurs. The petition hinges on FCC adoption of rule changes that would put the 10 GHz band under Subpart Z of the Commission’s Part 90 rules. Subpart Z currently sets out regulations governing wireless licensing, technical standards, and operational standards in the 3650 to 3700 MHz band.

“The application of the coordination procedures and requirements provided in Subpart Z will ensure that Amateur Radio operations in the band will not be disrupted,” Mimosa told the FCC. “In addition, as a further safeguard, Mimosa proposes a band plan for the 10.0-10.5 GHz band that would protect frequencies in the band that are most often used by Amateur Radio operators.” The proposed band plan would specify 10.350 to 10.370 GHz as an “Amateur Calling Band,” and 10.450 to 10.500 GHz for Amateur-Satellite operations in the midst of 21 wireless broadband channels and a small guard band.

ARRL Chief Executive Officer David Sumner, K1ZZ, is quoted as saying “Mimosa’s proposed power limit of 55 dBW EIRP is very high, particularly for point-to-multipoint operations, and no mechanism has been proposed for ensuring that harmful interference to amateur operations does not occur.”

Read the full ARRL story at
http://www.arrl.org/news/fcc-invites-public-comment-on-petition-affecting-10-10-5-ghz-band

Petition for Rule Making RM-11715
http://apps.fcc.gov/ecfs/document/view?id=7022310834

Interested parties may comment on RM-11715 using the FCC’s Electronic Comment Filing System (ECFS).
http://apps.fcc.gov/ecfs/hotdocket/list

FCC Guidance On Obtaining Licenses For Small Satellites

Image of a CubeSat in Space

Image of a CubeSat in Space

The Federal Communications Commission (FCC) released a Public Notice to provide guidance concerning FCC licensing of spectrum for use by small satellites, including satellites that fall within the categories of pico-satellites, nano-satellites and cubesats.

The advent of such small satellite designs has brought with it dramatically lower launch costs, enabling a larger range of organizations to directly launch satellites. Institutions such as universities and research organizations that previously found it cost prohibitive to launch their own satellite can now participate in the exploration of space. Many of these participants may be unfamiliar with the spectrum licensing, scheduling and other requirements attendant on satellites. This Public Notice seeks to alert affected parties of these requirements and thus aid small satellite operators in the planning necessary for a successful launch operation.

Continue reading