[ans] ANS-095 AMSAT News Service Special Bulletin - AMSAT Files Comments in FCC Orbital Debris Mitigation Proceeding

Paul Stoetzer n8hm at arrl.net
Fri Apr 5 14:28:35 UTC 2019


AMSAT NEWS SERVICE SPECIAL BULLETIN
ANS-095.01

In this Special Bulletin:

* AMSAT Files Comments in FCC Orbital Debris Mitigation Proceeding

SB SAT @ AMSAT $ANS-095.01
ANS-095 AMSAT News Service Special Bulletin

AMSAT News Service Special Bulletin 333.01
 From AMSAT HQ KENSINGTON, MD
DATE April 5, 2019
To All RADIO AMATEURS
BID: $ANS-095.01

AMSAT Files Comments in FCC Orbital Debris Mitigation Proceeding

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]

/EX

In addition to regular membership, AMSAT offers life memberships,
and sustaining donors to AMSAT Project Funds, will be eligible to
receive additional benefits. Application forms are available from
the AMSAT Office.

Primary and secondary school students are eligible for membership
at one-half the standard yearly rate. Post-secondary school students
enrolled in at least half time status shall be eligible for the
student rate for a maximum of 6 post-secondary years in this status.
Contact Martha at the AMSAT Office for additional student membership
information.

73 and Remember to help keep Amateur Radio in space,

This week's ANS Contributing Editor,

Paul Stoetzer, N8HM
n8hm at amsat dot org


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