Smallsat Definition, Propulsion Seen as Sticking Points in Streamlining NPRM
One of the biggest issues in the FCC small satellites authorization streamlining rulemaking might be its definition of a smallsat, experts said at an FCBA event Thursday. The requirement that smallsats above a certain orbit have collision avoidance capabilities also could face pushback, said Spire counsel George John. Development of such propulsion technology for smallsats is still "getting there," he said.
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Satellite Industry Association President Tom Stroup said the NPRM adopted at the April commissioners' meeting (see 1804170038) is "a good start," saying SIA hasn't reached consensus on a position.
The NPRM's aim is another route for authorization since existing processes aren't always a good fit for emerging commercial smallsats, said International Bureau Satellite Division lawyer Merissa Velez. She said the proposed streamlining process would obviate having to go through a processing round and give a one-year grace period in which to launch without having to file a surety bond. It would provide a lower application fee -- $30,000 -- than what's charged for non-geostationary orbit applications, plus lower regulatory fees.
To qualify for streamlined processing, the FCC proposes capping Part 25 smallsat license at 10 satellites per license and that the satellites top out at five years in orbit, including time to deorbit. The NPRM asks whether it should use a different lifespan. It would define a smallsat as 180 kilograms or less and no smaller than a 10-centimeter cube, though it asks whether that mass should be different. The NPRM proposes allowing deployment only for smallsats capable of collision avoidance in orbits above the International Space Station.
The agency asks whether smallsats in the streamlined process should have to protect other services and accept interference when operating in frequency bands shared with non-satellite services or whether they should get primary or secondary inference protection. It cites 137-138 MHz and 148-150.05 MHz and 1610.6-1613.8 MHz that potentially could accommodate smallsat operation and asks what service rules or limits might be needed.
One problem is there aren't good propulsion options today for smallsats, with Spire relying on differential drag and attitude control systems for moving a satellite, John said. He said the smallsat operator hopes to see an expansion of the types of satellites that can be streamlined. Stroup said it's also unclear whether the NPRM would let an operator apply for multiple licenses, and that such multiple licenses could lead to gaming of the system.
Stroup said SIA is working with the Global VSAT Forum on industry best practices for orbital debris, though coming to consensus about how to handle different orbital bands is challenging. SIA in April announced U.S. space situational awareness policy recommendations, including suggesting the country develop an SSA policy that focuses on mitigation and management of orbital debris.
John said modeling shows a very low risk of collision with cubesats. He said Spire's 60-plus cubesats are in orbits between 385 and 625 kilometers, subject to significant atmospheric drag. He said that, plus the small size of cubesats, means little debris in the event of a collision and thus they pose low orbital debris risks. Orbits higher than 700 kilometers "are not self-cleaning," and the satellites at those orbits and higher are typically larger, thus posing bigger debris dangers, John said. Spire is a member of the Commercial Smallsat Spectrum Management Association, and John said it will likely comment in the smallsat proceeding, though its major focus now is at the ITU.