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AMSAT, ARRL Comment In FCC Orbital Debris Mitigation Proceeding:

from The ARRL Letter on April 11, 2019
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AMSAT, ARRL Comment In FCC Orbital Debris Mitigation Proceeding:

AMSAT has told the FCC https://www.amsat.org/wordpress/wp-content/uploads/2019/04/Comments-of-Radio-Amateur-Satellite-Corporation-IB-Docket-No-18-313.pdf 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 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.

In separate comments https://ecfsapi.fcc.gov/file/10406073482911/ARRL%20Comments%20WT%20Docket%20No.%2018-313%2004_05_2019.pdf, 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 https://www.fcc.gov/ecfs/). Read more http://www.arrl.org/news/amsat-comments-in-fcc-orbital-debris-mitigation-proceeding. -- Thanks to AMSAT News Service

Source:

The ARRL Letter

Member Comments:
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AMSAT, ARRL Comment In FCC Orbital Debris Mitigation Proceed  
by W1ITT on April 12, 2019 Mail this to a friend!
Orbital debris is potentially harmful, no matter from whose satellite it emanates. If a piece of one of our hobby amateur satellites breaks someone else's bird, it will cost them the use of a valuable resource. I fail to see why hams, if we are going to be good orbital neighbors, deserve any exemption from the common sense rules that govern the orbital realm. Certainly, we cannot do anything to lessen the effects of China's 2007 test, nor of India's dopey stunt this year where they demonstrated that they have a rudimentary ASAT capability, but we can at least do unto others as we would have them do unto us. I would hope that the FCC would stuff this selfish proposal into the bin, where it belongs.
 
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