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AMSAT Comments in FCC Orbital Debris Mitigation Proceeding

04/09/2019

AMSAT has told the FCC that several proposed rule changes related to the mitigation of orbital debris would have an extremely detrimental effect on both the Amateur Satellite Service and AMSAT’s ability to launch and operate new satellites, including AMSAT’s upcoming GOLF satellites. AMSAT filed comments on April 5 on an FCC Notice of Proposed Rule Making (NPRM) in IB Docket 18-313. AMSAT argues that amateur satellites often have longer mission lifespans than other small satellites and that the FCC 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, either by transferring to a parking orbit or re-entering the atmosphere within 25 years of mission completion. Current practice is to assume a “zero-year” mission and to require that amateur satellites meet the debris regulations.

AMSAT also urged the Commission to consider alternatives to a proposed rule that would restrict to altitudes of 650 kilometers or less satellites in low-Earth orbit that plan to meet the orbital debris mitigation guidelines through atmospheric re-entry. AMSAT noted that, had this rule been in place, it would not have been permissible to deploy AO-85 and AO-91 in their current elliptical orbits with apogees of approximately 800 kilometers, even though both 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 higher than 1,000 kilometers. This proposed rule would prohibit GOLF-1’s deployment at that altitude.

The Commission’s proposed rules would further require that Amateur Satellite licensees indemnify the government against any claims made against the US due to the operation of a satellite. AMSAT believes this proposal would end the ability of AMSAT, or any other entity in the US, to launch and operate amateur satellites and urged the FCC 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 FCC has proposed requiring encryption of any command links as well as satellite telemetry. AMSAT called the proposed rule “unnecessary and counter to the spirit of the Amateur Service” and said open access to telemetry is expected of Amateur Radio satellites and critical to their educational component.

In separate comments, ARRL said it supports “reasonable efforts to mitigate orbital debris” but that the FCC “must tailor its regulations for the Amateur Satellite service” and “not inadvertently impair the service’s continuing vitality by applying rules crafted for commercial satellite services.”

In this regard, ARRL supports AMSAT’s positions, which suggest that “the nature of the modifications needed [should] achieve the Commission’s expressed regulatory objectives without needlessly impairing the Amateur Satellite service.”

ARRL said the FCC should exempt amateur satellites or otherwise ameliorate its proposed indemnification requirement and said that only telemetry “used to command onboard propulsion systems” should be subject to encryption. 

ARRL also said amateur satellites proposed for disposal by atmospheric re-entry should not be restricted to orbital altitudes of 650 kilometers or lower, and that the longer duration of amateur satellite missions should be factored into the time required for a satellite to naturally de-orbit or be transferred to “a parking orbit.” 

Interested parties may file reply comments by May 5 via the FCC Electronic Comment Filing Service (ECFS). – Thanks to AMSAT News Service



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