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ARRL Satellite Bulletin ARLS009 (2020)

ARLS009 ARRL Comments in Orbital Debris Mitigation Proceeding

QST de W1AW  
Space Bulletin 009  ARLS009
From ARRL Headquarters  
Newington, CT  October 14, 2020
To all radio amateurs

ARLS009 ARRL Comments in Orbital Debris Mitigation Proceeding

In comments to the FCC, ARRL targeted two specific areas of concern
regarding a Further Notice of Proposed Rulemaking (FNPRM) in IB
Docket 18-313 - mitigation of orbital debris in the new space age.

In an earlier phase of the proceeding, ARRL filed comments and met
with FCC staff to discuss the proposed rules. In comments filed on
October 9, ARRL focused on the areas of indemnification and
maneuverability/propulsion. Indemnification places the liability for
any possible damage from a satellite on an individual or entity.
ARRL reiterated its assertion that, as a practical matter, an
indemnification requirement "would seriously impair the ability of
amateur and university experimenters to launch and operate
satellites under US auspices" due to the potential liability and
high insurance cost.

The FNPRM can be found online in PDF format at, .

ARRL's comments cited a letter from University Small Satellite
Researchers, submitted on behalf of 24 named professors last April,
contending that the requirement "would effectively preclude a large
proportion of academic SmallSat missions because public universities
typically cannot legally enter into indemnification arrangements."

ARRL argued that if the FCC does adopt an indemnification
requirement, it should allow either the owner or the licensee of an
amateur space station to provide indemnification. In the Amateur
Satellite Service a licensee can only be an individual. An
individual licensee is unlikely to accept liability for a satellite,
but a satellite owner might. In its own comments, AMSAT similarly
asked for language that would allow satellite owners as well as
licensees to indemnify the US for the operation of an amateur radio

The FCC proposal also would require that all space stations deployed
in low-Earth orbits higher than 400 kilometers (about 250 miles) be
able to maneuver with the use of some sort of onboard propulsion
system. ARRL urged adoption of an exception for "a limited number of
amateur and similar experimental satellites" that are below a
specified size and mass and either standalone spacecraft or in a
constellation of no more than four or five individual satellites.
ARRL suggested a size limit of 36 x 24 x 12 centimeters and 12
kilograms in mass.

"This would accommodate the types of small satellites most often
used for experimental purposes by radio amateurs," ARRL told the
FCC. "Such satellites are small in number [and] have limited to no
capacity to implement maneuverability using current technology due
to their small size," yet provide valuable platforms for
experimentation and student experience.

Alternatively, ARRL asked the FCC to consider increasing the
400-kilometer low-Earth orbit limit, since satellites placed into
orbit from the ISS and from ISS service vehicles "often are in
higher orbits but share the same characteristics as those that orbit
below 400 kilometers." Doing so would help to preserve the
educational and experimental benefit of such satellites, ARRL said,
provided "such vehicles are shown to pose no risk to the
International Space Station and will return to Earth within the
specified time limit."

In concluding its remarks, ARRL asked for "reasonable
accommodation," given the public benefit of the Amateur Satellite
Service, rather than lumping small experimenters and researchers
with large corporate entities planning to launch thousands of


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