PARIS — The U.S. Federal Communications Commission (FCC) relaxed its proposed rules relating to on-board propulsion for small satellites and the minimum satellite size eligible for a lower-cost regulatory procedure in response to industry requests.
The agency has also extended, to six years, the license duration for the streamlined procedure.
The FCC expects to vote on its new regulation, “Streamlining Licensing Procedures for Small Satellites,” on Aug. 1.
A proposed order on the new regulations, more than a year in the making, was published July 11: http://bit.ly/2LXVF07
In most respects, it confirms the FCC’s earlier definition of what satellites will be eligible for the streamlined procedures, where the license fee for a constellation of a maximum of 10 satellites will be $30,000 instead of $471,575 now, plus annual regulatory fees of $122,775 for fiscal-year 2018: http://bit.ly/2ZJ0M8I
Eligible applications for the streamlined regime:
— Constellations of 10 satellites or fewer.
— Satellites with a launch mass of 180 kilograms or less.
— Satellite systems that have provided certified orbital debris risk mitigation procedures.
— Operators must agree to operate on a non-interference basis with satellites already in service, and to accommodate future users in their spectrum.
But there are three major changes in the proposed order compared to the original notice issued in April 2018.
The six-year license
The first modification will extend the license duration from five years to six years, including the mandatory deorbit phase, to give smallsat operators more time. In another concession to the smallsat sector, the FCC said the six-year time clock starts only when the satellites are in their intended orbit and have begun functioning.
The agency said operators had been concerned that the FCC’s earlier proposal would mean a satellite dropped into its operational orbit but unable to function would seem the six-year countdown.
For streamlined licensing, only not-too-smallsats
The second modification relates to the size of the satellites eligible for the streamlined licensing process. The FCC had earlier wanted to set a limit at a 1U cubesat — 10cm x 10cm x 10cm.
The proposed order modifies that, so that only spacecraft measuring more than at least 10cm at their smallest dimension will be eligible for the expedited licensing regime.
Satellites would also be required to carry a telemetry marker so that ground teams are able to distinguish it from other satellites.
The FCC says the U.S. Air Force’s 18th Space Control Squadron (18 SPCS), which handles satellite tracking, can track 1U cubesats and that this is the reference the agency used to set a limit on minimum satellite size.
Some smallsat operator groups had argued that the agency would set rules on traceability without specifying a given satellite size.
The agency responded that very small satellites and spacecraft that in other ways do not qualify for the streamlined licensing procedure can always use the standard Part 25 licensing regime.
Allowing PocketQubes and other very small satellite designs would require more FCC review, which would defeat the point of the streamlined procedure, the FCC said.
The agency said it will deal with the question of whether all satellites should carry markers to enable them to be identified as part of the agency’s ongoing orbital debris regulatory update.
A propulsion requirement above 600 km, not the 400-km ISS orbit
The third modification to its earlier proposal has to do with which satellites should be forced to carry on-board propulsion to avoid collisions with other satellites or with debris, and to assure non-interference with astronaut-carrying vessels including the International Space Station and the vehicles serving it.
The ISS operates at 400 kilometers, which is where the FCC set its earlier propulsion requirement.
The proposed order raises that ceiling to 600 km to provide flexibility for operators. The FCC said a satellite can be expected to re-enter the atmosphere passively, by the force of atmospheric drag, within six years.
Some companies had argued that the advance of non-propulsive technologies enables satellites to be deorbited just as reliably without propulsion. Here too, the FCC acknowledged the point but said those technologies would be subject to the usual Part 25 regulations to enable the agency to study them in detail.
Applicants in any event must describe, in detail, their collision-avoidance strategy as a condition of getting a license.
Satellite operators SpaceX, Iridium and SES/O3b voiced concerns that too many small satellites would be transiting through the 400-kilometer orbit, on the way up and down, and that the orbital-debris risk would be high.
The agency did not disagree, but said that this is another concern that is best addressed by the orbital debris regulation it is preparing.