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NEWINGTON, CT, Sep 9, 2004--New FCC Amateur Radio space station rules will impose requirements to mitigate orbital debris. The FCC adopted a Second Report and Order (R&O) in IB Docket 02-54 on June 9. The new rules, appearing September 9 in the Federal Register, affect Parts 5 (Experimental Service), 25 (Satellite Communications) and 97 (Amateur Service) of the FCC's rules and regulations. In general, they require submission of an "orbital debris mitigation plan" to the FCC with each license application. AMSAT-NA--the Radio Amateur Satellite Corporation--had wanted Amateur Radio exempted from orbital debris mitigation rules that went beyond what the FCC had proposed in its 2002 Notice of Proposed Rulemaking. AMSAT-NA President Robin Haighton, VE3FRH, said the organization is discussing the implications of the R&O but has no formal position yet.
"While AMSAT does not like to be restricted--we are free enterprise people--we do acknowledge that even space is not limitless," Haighton told ARRL. "The more debris there is, particularly in lower orbits, the more danger there is of collisions and eventually the greater the difficulty in defining launch windows."
Haighton said that between now and the AMSAT-NA Symposium and Annual Meeting in October, the AMSAT Board of Directors "will have a chance to evaluate the FCC position and try to develop our own guidelines and requirements for building AMSAT satellites."
The AMSAT-NA president said that while he personally agrees with the notion of limiting space debris, "the application of this principle may be a problem."
In its formal comments in 2002, AMSAT-NA commended the FCC for initiating the proceeding and agreed that the growing quantity of space debris "presents a potential problem to all who wish to use space" and that "methods of controlling and reducing it are called for."
The additional rules the FCC has ordered will significantly expand §97.207(g) in the Amateur Service rules governing space stations. The additional provisions will require "a description of the design and operational strategies the space station will use to mitigate orbital debris" that include statements covering several specific areas. Space station license grantees will have to state that they have "assessed and limited the amount of debris released in a planned manner during normal operations" as well as the probability that the space station itself could become a source of debris through collisions with other debris or meteoroids.
AMSAT's comments took "strong exception when it comes to meteors." Those launching satellites, AMSAT said, can assess the orbital parameters of known objects but "no such information is available for meteors."
Satellite licensees also must state that they have assessed and limited the probability of accidental explosions during and after completion of mission operations. "This statement must include a demonstration that debris generation will not result from the conversion of energy sources on board the spacecraft into energy that fragments the spacecraft," a new §97.207(g)(1)(ii) rule section specifies.
The launch of AO-40--then Phase 3D--in November 2000. An onboard incident the following month damaged and seriously compromised the satellite, which went dark earlier this year. |
The demonstration would have to address whether "stored energy" would be removed at the end of the spacecraft's life "by leaving all fuel line valves open, venting any pressurized system, leaving all batteries in a permanent discharged state and removing any remaining source of stored energy."
Satellite licensees will have to include a statement disclosing the "accuracy--if any--with which orbital parameters of non-geostationary satellite orbit space stations will be maintained." AMSAT has asserted that "state-of-the-art practices do not allow specification of the Keplerian orbital elements of spacecraft with sufficient accuracy to predict or avoid the collision of two space objects."
AMSAT pointed out that many smaller satellites of the type most likely to be launched for Amateur Satellite use lack propulsion systems to maintain a certain orbital tolerance or to deorbit the spacecraft when its mission is over. Most, AMSAT told the FCC, would burn up in the atmosphere.
The FCC has not yet announced an effective date for the new Part 97 rules.
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