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ARRL General Bulletin ARLB013 (2018)

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ARLB013 ARRL Urges Regulatory Regime to Keep Non-Amateur Satellites
off Amateur Spectrum

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ARRL Bulletin 13  ARLB013
From ARRL Headquarters  
Newington CT  July 11, 2018
To all radio amateurs 

SB QST ARL ARLB013
ARLB013 ARRL Urges Regulatory Regime to Keep Non-Amateur Satellites
off Amateur Spectrum

ARRL wants the FCC to facilitate bona fide Amateur Satellite
experimentation by educational institutions under Part 97 Amateur
Service rules, while precluding the exploitation of amateur spectrum
by commercial, small-satellite users authorized under Part 5
Experimental rules. In comments filed on July 9 in an FCC proceeding
to streamline licensing procedures for small satellites, ARRL
suggested that the FCC adopt a "bright line test" to define and
distinguish satellites that should be permitted to operate under
Amateur-Satellite rules, as opposed to non-amateur satellites that
could be authorized under Part 5 Experimental rules.

"Specifically, it is possible to clarify which types of satellite
operations are properly considered amateur experiments conducted
pursuant to a Part 97 Amateur Radio license, and [those] which
should be considered experimental, non-amateur facilities, properly
authorized by a Part 5 authorization."

ARRL said it views as "incorrect and overly strict" the standard the
FCC has applied since 2013 to define what constitutes an Amateur
Satellite, forcing academic projects that once would have been
operated in the Amateur Satellite Service to apply for a Part 5
Experimental authorization instead. This approach was based, ARRL
said, on "the false rational" that a satellite launched by an
educational institution must be "non-amateur" because instructors
were being compensated and would thus have a "pecuniary interest" in
the satellite project. ARRL said well-established Commission
jurisprudence contradicts this view.

ARRL told the FCC that justification exists to expand the category
of satellite experiments conducted under an Amateur Radio license,
"especially those in which a college, university, or secondary
school teacher is a sponsor." But, ARRL continued, a compelling need
exists to discourage Part 5 Experimental authorizations for
satellites intended to operate in amateur allocations by non-amateur
sponsors, "absent compelling showings of need."

"There is no doubt but that Amateur Radio should be protected
against exploitation by commercial entities, and there should be a
compelling justification for a Part 5 Experimental license issued
for a satellite experiment to be conducted in amateur spectrum,"
ARRL said. "A defining criterion for this latter category should be
that there is no other spectrum practically available in lieu of
Amateur Radio allocations."

ARRL noted that International Amateur Radio Union (IARU) policy
regarding satellites operated in Amateur Radio spectrum is only to
coordinate satellites where licensees and control operators are
radio amateurs and having a "mission and operation" consistent with
the International Telecommunication Union (ITU) Radio Regulations'
definitions of the Amateur and Amateur-Satellite services.

Resolution 659, adopted at World Radiocommunication Conference (WRC)
2015, included protective language against non-amateur satellites
operating in Amateur-Satellite spectrum, and the exclusion of any
amateur bands from spectrum that might be considered at a future WRC
for allocation to the Space Operation Service.

IARU announced in 2017 that it would no longer coordinate
non-amateur satellite operations and adopted new satellite frequency
coordination guidelines. Under that policy, educational and
university satellites may be coordinated only when an identified
amateur component exists, and the mission is to teach and train
students in satellite communication and building and launching
satellites. The individual responsible for the satellite's
communications must be an Amateur Radio licensee. IARU will also
continue to coordinate space stations operating under an amateur
license and having "a clear amateur mission," as well as satellites
where a licensing administration directs the use of an amateur band.

ARRL asserted that incorporating Amateur Radio in experiential
learning using small satellites - e.g., CubeSats - is good for
Amateur Radio, for students, and for the advancement of technology,
and it urged the FCC to adopt a regulatory paradigm that encourages
this approach.

AMSAT-NA also filed comments in the proceeding. The AMSAT remarks
reflect several of the same concerns expressed by ARRL, including
the suitability of authorizing certain satellites built by
universities and non-profit organizations in the Amateur Satellite
Service, and expressing opposition to satellites licensed as
experimental under FCC Part 5 rules operating in the Amateur
Satellite bands. Interested parties may file reply comments in the
proceeding, IB Docket No. 18-86, by August 7, 2018.
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