Smallsat Streamlining Proposal Sees Rifts on What Constitutes a Smallsat
The FCC's proposed streamlining of authorizations for small satellite operators is raising issues of how best to define who falls in that smallsat category, with satellite interests not coming to a universal consensus. There also was disagreement on inter-satellite link bands. commissioners adopted the streamlining NPRM in April (see 1804170038), with docket 18-86 comments due Monday, replies Aug. 8.
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Backing the proposed 10-satellite system size, 180 kilogram (397 pound) mass limit and altitude limits for satellites without propulsion systems was Iridium (see here). EchoStar also backed the number and size limits and said smallsats should be required to operate on a secondary, noninterference basis with respect to other satellite operations when the small satellite operations are consistent with existing frequency allocations in the international table of frequency allocations. Boeing called for a 30-satellite cap and against any specific limit on smallsat size or mass. SpaceX said "spectral efficiency" -- with specified bandwidth and power limits -- also should be among the criteria for determining whether an applicant can get streamlined treatment.
SpaceX said a five-year license term should be the upper boundary, not the default, and advocated a formula that uses the duration of a smallsat's mission to find the amount of time it's authorized to operate and complete deorbiting. Orbcomm said the 180 kilogram limit poses problems since that size rises to the level of potential orbital collision risk and points to greater possible interference issues. Rather than mass, the FCC should look at guidelines dealing with spectrum and orbit utilization, Orbcomm said, voicing concerns about smallsats having access to the 37-138 MHz and 148-150.05 MHz mobile-satellite service bands given lack of spectrum available. Globalstar said allowing stand-alone small-satellite operations in the 1610.6-1613.8 MHz band could lead to harmful interference to its services.
The total orbital lifetime shouldn't be a requirement for the streamlined process if the satellite meets existing Part 25 orbital debris requirements, said the Commercial Smallsat Spectrum Management Association. Rather than setting orbital debris rules just for smallsats, they should be subject of a separate proceeding that covers all operators and license types, CSSMA said. It said the proposed five-year license term is too short and that rules against license extensions or replacement satellites would make a streamlined process more expensive and risky. It pushed back against proposed altitude deployment limits.
When technically feasible, all commercial smallsats should have to share spectrum and orbital resources with existing and future commercial smallsats, with no rights of incumbency or higher obligations for new entrants, Boeing said. It said commercial smallsats should have to protect the operations of and accept harmful interference from existing and future non-streamlined Part 25 satellite licensees. Smallsat operators under those obligations shouldn't face bond requirements since they don't pose spectrum warehousing or speculation dangers, the company said. CSSMA made similar bond requirement arguments.
Iridium urged the agency to ensure existing mobile satellite services in the L-band are protected and called for smallsat-specific out-of-band emission limits and separation requirements for inter-satellite links in the L-band to protect low earth orbit systems. Inmarsat urged allowing inter-satellite links in the 1518-1559 MHz and 1626.5-1660.5 MHz and 1668-1675 MHz mobile satellite service uplink and downlink allocations. EchoStar urged allowing inter-satellite links only in frequency bands allocated for space-to-space operations.
The Open Research Institute said the proposed rules will lead to university research satellite programs inappropriately seeking authorization as amateur satellite services. It said university satellite programs need "reasonable licensing costs" or limited budgets will force them to seek experimental licenses via the amateur satellite service. That will "tend to block true Amateur Satellite projects driven by Radio Amateurs," it said. Amateur radio operator trade group ARRL said the streamlining proceeding is a chance to fix FCC interpretation of its Part 97 rules governing amateur radio and Part 5 rules governing experimental authorizations. It said the agency shouldn't make educational institutions get Part 5 licenses for amateur radio satellite experiments nor allow commercial smallsat use of amateur service and amateur satellite service spectrum. Radio Amateur Satellite Corp. opposed licensing satellites in the amateur bands under Part 5 and said universities and nonprofits should seek amateur authorizations instead.
The Satellite Industry Association suggested changes to Form 312 to apply for streamlined process, replacing the narrative section with verifications of certification. It said the $30,000 streamlined application fee should be re-evaluated in a year after the streamlined process takes effect, and the agency should consider lowering it for noncommercial service applicants.
When it comes to smallsats being used in commercial lunar missions, Moon Express said the FCC should raise that 180 kilogram mass retirement to 500 kilograms (1102 pounds) or count only the fuel-less mass of the spacecraft. SIA said the streamlined process should be available to missions that don't involve orbiting earth.