ARRL, AMSAT Seek Changes in FCC Orbital Debris Mitigation Proposals

FCC SealARRL Washington Counsel Dave Siddall, K3ZJ, and AMSAT Executive Vice President Paul Stoetzer, N8HM, on April 8, discussed with senior FCC International Bureau staff by telephone the FCC’s draft Report & Order (R&O) on mitigation of orbital debris (IB Docket No. 18-313). The amateur representatives told the FCC staff that “two aspects of the draft regulations are of particular concern…. and would seriously hinder amateur radio’s future operations in space, if adopted as proposed without the relatively minor changes that we propose.”

First, ARRL and AMSAT requested a revision to proposed language that otherwise would allow only private individual licensees to indemnify the U.S. for the operations of an amateur space satellite. ARRL and AMSAT requested that satellite owners be added to that provision. The amateur representatives, noting that amateur radio licensees may only be individuals under the amateur rules, stated that “[i]n no other service would an individual be required to personally make a similar indemnification” and that “it would be difficult to impossible to find an individual Amateur Radio licensee willing to bear that risk.”

Second, ARRL and AMSAT asked the FCC to delay by 3 years the proposed effective date of April 23, 2022, for a rule that would require satellite operators to certify that space stations “be designed with the maneuvering capabilities sufficient to perform collision avoidance” for spacecraft designed to operate above 400 kilometers in altitude. Citing the long lead times to design and construct Amateur satellites, ARRL and AMSAT suggested that a more reasonable date would be April 23, 2025 and noted that, based on recent past years, only an estimated 3-5 amateur satellites likely would be launched during the extra period.

“We do not disagree with the purpose of this requirement,” they told the FCC staff, but “the proposed effective date is unreasonable in the case of amateur radio satellites.” The new effective date “would allow time for amateur spacecraft designers to adapt to this new requirement,” they said.

Citing the value of amateur satellites to the development of the commercial small satellite industry, and student participation in such projects, ARRL and AMSAT said a strong and robust Amateur Satellite Service will help inspire future developments in satellite technology. The requested changes to the draft R&O would help ensure that amateur radio continues to have a future in space and contribute to the public interest on an educational, non-pecuniary basis.

The FCC is expected to consider the R&O at its April 23 open meeting.
The AMSAT/ARRL document may be read in full at
https://ecfsapi.fcc.gov/file/10409353709408/AMSAT%20ARRL%2018-313%20Ex%20Parte%2004_08_2020.pdf

Source AMSAT News Service and ARRL https://www.amsat.org/mailman/listinfo/ans

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 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