The FCC received sharp differences of opinion on its proposal to streamline licensing for smallsat missions. With the comment period now closed, the agency will determine which of them to incorporate in its ruling, expected this autumn. Credit: FCC

LOGAN, Utah — A U.S. regulatory proposal that would require smallsat operators seeking streamlined licensing to include propulsion on their satellites if they orbit above 400 kilometers appears to be the most hotly contested issue in the FCC’s proposed rulemaking.

Another issue provoking strong reaction on both sides is what rules should apply to intersatellite links — satellite-to-satellite communications — in certain radio spectrum, and whether these transmissions risk causing interference to satellites in higher orbit.

Mitigating space debris and in-orbit collisions in low Earth orbits expected to be much more populated in the coming years was a common theme, and here too opinion was sharply divided.

The U.S. Federal Communications Commission (FCC) on Aug. 7 closed the final comment period on its “Streamlining Licensing Procedures for Small Satellites,” which is designed to make way for the fast-growing smallsat sector without threatening established systems, and without multiplying orbital debris.

Issued April 17, the Notice of Proposed Rulemaking elicited comments from more than 50 individual organizations. Established fleet operators like SES/O3b, EchoStar/Hughes, ViaSat, Iridium, Globalstar and Orbcomm were joined by startup constellation sponsors such as SpaceX, Audacy Corp. and Phase Four.

Associations including the Commercial Smallsat Spectrum Association (CSSM), the Commercial Spaceflight Federation (CSF) and a grouping of nine small-satellite university researchers presented detailed suggestions for how the FCC can help the dynamic new sector.

As is often the case in FCC proceedings, many waited until Aug. 7 before filing their last comments, the better to target opposing comments filed earlier.

Nursing an old would between Spire/Planet/Spaceflight and Orbcomm

Old wounds were reopened in the comments, notably a 2016 dispute between Spire Global, Planet and Spaceflight on the one hand and M2M/IoT constellation operator Orbcomm on the other over the orbital-collision risks of a Spaceflight-organized launch of 80-plus satellites, including spacecraft for Spire — an Orbcomm competitor — and Planet.

Orbcomm’s FCC petition to stop the launch resulted in a six-month delay in licensing. Orbcomm eventually withdrew its petition.

In its Notice of Proposed Rulemaking, issued April 17, the FCC wants to make it easier for smallsats, including commercial systems, to clear regulatory approval. The streamlined process would be available for systems of 10 satellites or less per application, with satellites weighing a maximum of 180 kilograms and a projected service life of five years.

Mitigating orbital debris and reducing the likelihood of collision risk is a major theme. The agency notably proposes that all satellites operating above 400 kilometers, which is the International Space Staton’s altitude, be obliged to carry propulsion systems.

The propulsion would serve two purposes: First, it would enable the satellites to perform collision-avoidance maneuvers in the event of a risk; it would also speed their deorbiting at the end of the mission life, reducing their potential to create more orbital debris.

Propulsion systems for cubesat-size satellites are developing quickly but are not yet mainstream. It’s also true that NASA has permitted, after careful vetting, the launch of satellites without propulsion above the space station’s altitude.

The CSF and CSSM both argue against mandating propulsion, saying that instead, the FCC should require that satellites seeking licenses under the streamlined process demonstrate an ability to maneuver, even if without propulsion.

First don’t make it worse: The FCC is weighing how to facilitate the growth of a promising new activity, smallsat operations, without opening the door to more orbital debris. Credit: NASA Orbital Debris Program Office

For the CSSM, an operator should be able to show the FCC that its satellites have “a method of collision avoidance that is significantly reliable to meet any then-existing requirements of the ISS program with respect to small satellites that cross the ISS orbit.”

A group of nine processors from universities with smallsat studies agrees, saying the FCC should leave open the possibility of other ways for satellites to maneuver.

Scott Palo, from the University of Colorado-Boulder and one of the signatories of the comment to the FCC, questioned whether arming a small constellation owner with a propulsion capability might not do more harm than good.

“The FCC is worried about debris. If you are not powered, how do you get away from the debris?” Palo said here Aug. 6 at the Small Sat Conference.

“On the flip side, I imagine Space Command’s head is going to explode when all these things are moving around up there and they’re trying to figure out how to track it,” Palo said. “So I am not sure the people thinking about this were thinking about the ops side of tracking.”

One of the dilemmas in space traffic management in the more highly populated LEO-orbit regimes is that moving to avoid a collision with a piece of debris may put you in the way of another piece of debris, or another satellite.

A CSSM dig at Iridium on mandating satellite propulsion

“Propulsion is not a panacea,” the CSSM said in its filing. “After all, one of the biggest debris events in history involved an active and propulsive satellite.”

That comment was aimed at Iridium, one of whose satellites in 2009 collided with a dead Russian spacecraft.

Among those filing comments to the FCC, Iridium and SpaceX are the most militant in wanting tough measures to limit debris and collision risk. SpaceX says all smallsats, whatever their orbital altitude, should carry some form of propulsion. SpaceX in this context is a company designing a 4,000-satellite broadband constellation.

Iridium wants smallsat’s to have propulsion above 400 kilometers, and also proposed that any licensee under the streamlined licensing procedure be stopped from launching any further satellites if one of its spacecraft has failed in orbit.

“This proceeding, if successful, will expand dramatically the number of spacecraft circling the Earth, many of which will be minimally tested prior to entering orbit,” Iridium said, warning the FCC to assure that its lighter regulatory touch for smallsats “does not lead to the rapid emergence of a new era of space junk.”

A similar debate has arisen over the FCC’s proposed requirement that smallsats licensed under the streamlined procedures carry specific identifiers so that they can be tracked, and that the satellites be of a minimum size to make them easier to track.

Several filers said these rules were too vague, and that the size of a satellite is an insufficient measure to determine traceability. The university professors’ group asks the agency instead to require a demonstration of trackability, without specifying satellite size or tagging.

SES and O3b, in their combined filing, support the idea of a telemetry marker being mandated on all satellites under the streamlined rules, and also approve a propulsion mandate for satellites above 400 kilometers.

Several filers worry that smallsat operators will seek to avoid the costlier, more-cumbersome standard FCC Part 25 licensing procedures and use the streamlined procedure to, in effect, license a large constellation by registering just 10 satellites at a time, the maximum allowed under the FCC’s proposal.

The CSSM disagreed, saying the streamlined procedure’s proposed licensing fee of $30,000 — a fee that several filers protested as too high for smallsat operators’ limited budgets — would by itself discourage “gaming” the system through multiple filings from the same organization.

In addition, CSSM said, the streamlined procedures apply only to satellites with five-year operating lives or less, and afford no spectrum protection, which would lead larger commercial systems to use the standard FCC procedures.