FCC Gets More Requests for Federal Coordinated Effort on Orbital Debris
The FCC shouldn't go it alone on updating orbital debris regulations but should coordinate with other agencies, numerous satellite interests said in docket 18-313 replies last week. The Commerce Department in initial comments asked the FCC to pause the rulemaking proceeding (see 1904080033). But commenters didn't reach consensus on issues like orbital spacing between large constellations and how best to assess risk.
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Even some commissioners acknowledged the importance of federal agency interrelationships that are relevant to debris issues, Boeing said. The Satellite Industry Association backs creating an interagency working group for making a cohesive U.S. policy on safe space operation. It said Commerce should work with the FCC and other agencies to ensure a unified federal regime for space traffic management, space situational awareness and orbital debris mitigation.
Being for orbital spacing is a "common sense view," OneWeb said. But Boeing said minimum spacing requirements between the altitudes of non-geostationary orbit (NGSO) systems would be arbitrary and beyond the scope of the rulemaking proceeding.
Backing the reviewing of collision risk on an aggregate basis, OneWeb said doing so allows the fully analysis of potential impacts on large NGSO constellations, and that arguments otherwise are "misguided." Also supporting an aggregate approach, Orbcomm said risks are affected by factors that can be controlled by satellite system operators, including number of satellites in a constellation and the mass and size of each, and NGSO applicants are licensed to launch and operate constellations, not individual satellites. There's widespread agreement any new rules should be imposed on a per-satellite basis rather than aggregate requirement, SpaceX said.
Adopting aggregate risk standards would mean different standards for each satellite operator depending on the number of satellites it wants to put up, Amazon said. It said if the FCC adopts a performance-based standard for requiring maneuverability, that should be the ability to maneuver at least 5 kilometers within 48 hours of a conjunction warning.
The Commercial Smallsat Spectrum Management Association (CSSMA) said it's concerned about the possibility of the FCC regulating nontraditional propellants without looking at the technical specifics of the propulsion system. It said using 400 kilometers as the breakpoint for justification of orbit selection is arbitrary -- tied to the International Space Station now but perhaps obsolete when a new space station is deployed someday at a higher altitude. CSSMA opposes requiring low earth orbit operators below 2,000 kilometers having to de-orbit within five years of the end of a satellite's operational life, since that could drive out of business some of its members that couldn't meet that requirement. It said the FCC should consider a sunset rule grandfathering in existing and pending licensees under existing rules.
The FCC ought to clarify its proposed revision of the rule requiring coordination during orbit-raising maneuvers, since "coordination" could be subject to misinterpretation, being often used in reference to formal procedures in ITU rules and not defined in the draft NPRM, Eutelsat said. Opposing regulation of satellite designs, it said the FCC "has long avoided getting into the equipment design business."
The New York University Institute for Policy Integrity urged the FCC look at market-based alternatives such as a credit trading system that would require buying or creating offset credits for every increase in risk. That's rather than prescriptive regulation or a fee system to incentivize debris reduction, it said.
The record supports requiring all NGSO applicants identify other satellites using or proposing to use a similar orbit and to describe the coordination measures to be taken to address collision risk, SES/O3b said. An array of university small-satellite researchers from such institutions as Massachusetts Institute of Technology and University of Hawaii said whatever rules the FCC adopts shouldn't preclude university research missions in orbit. They cautioned against maneuverability or propulsion requirements especially below 600 kilometers. They said the 25-year disposal requirement may need updating, but it's unclear what risks come from it.
Given the regulator's track record in regulating orbital debris mitigation since 2004, it should continue being the sole regulator for commercial satellite orbital debris issues, AT&T said. It said there's strong support for keeping the existing process of evaluating license extension requests on a case-by-case basis.
Boeing pushed the agency to ensure debris rules aren't a barrier to market entry. It said the FCC saw no support for it requiring NGSOs justify why they chose a particular orbit above 650 kilometers, and the agency shouldn't try to regulate "the highly sensitive orbital altitude selection process." It said NGSO constellations should avoid altitudes with high amounts of debris, but satellite operators have incentive enough to select safe altitudes without restrictions.