INTERESTED IN USING AMATEUR-SATELLITE SERVICE FREQUENCIES?
— Frequently Asked Questions —
BACKGROUND. Most information provided here applies world wide because all administrations work from the same basic text: the Radio Regulations. A few specifically labeled items relate only to the USA.
Q1: What do you mean when you talk about the amateur service; the amateur-satellite service?
A: Amateur service: A radiocommunication service for the purpose of self-training, intercommunication and technical investigations carried out by amateurs, that is, duly authorized [licensed] persons [individuals] interested in radio technique solely with a personal aim and without pecuniary interest." (Emphasis supplied.)
Amateur-satellite service: A radiocommunication service using space stations on Earth satellites for the same purposes as those of the amateur service.
Q2: Graduate assistants are going to operate our satellite. Is that OK?
A: If they are compensated in any way to operate an amateur transmitter, the answer is no. If they are not licensed amateurs, the answer is also no.
Q3: Our satellite will carry cameras that will take pictures of the separation sequence for xyz corporation, builders of the multiple payload adaptor. We will give them the pictures. They require we don't make them public in case they show something embarrassing or something that didn't work right. Is that OK?
A: No. Every transmission from an amateur station must be in “plain language” or, in other words, in the clear. In the clear means that (1) technical descriptions of all emissions, codes, and formats are made publicly and widely available; and (2) technical descriptions must be sufficient to enable any technically competent licensed amateur radio operator to use the system. As a consequence, of course, all transmissions will be open to reception by anyone. (Encryption for critical spacecraft telecommand functions is accepted.)
Also, xyz Corporation has a financial interest in the communication resulting in commercial use of an amateur station, which is not permitted.
Q4: Our satellite will have no uplink. It's just going to send its GPS location every 2 minutes. Anyone will be able to listen to that and know where the satellite is. We want lots of people to be able to listen, so we picked amateur frequencies. Any problem with that?
A: Yes and no. You must be able to control the satellite transmitter in case it causes interference. So, you will have to have a telecommand uplink, no matter what service you license it in.
While your mission objective might be of interest to amateurs, transmitting information intended for reception by the general public is broadcasting, which is prohibited in the amateur service. However, transmissions directed to amateurs may be received by anyone without restriction.
Q5: We will control abcSat from our campus ground station. The satellite will only be turned on when over abcU and we will download the experiment data and give it to the principal investigator, Dr Smith. He and his grad students will write papers on the results and present them at the Small Sat conference following the launch. Afterwards, the data will be published on the web. Any problem with that?
A: Yes, there are several problems. First of all, transmissions from amateur stations must be in the clear and, therefore, open to reception by anyone.
Next, space stations in the amateur-satellite service must have sufficient Earth command stations established before launch to guarantee that the space station transmitter can be turned off in case of interference.
USA: One command station likely will be viewed as inadequate for the purpose.
Finally, Dr Smith, a paid member of the faculty, must be careful not to have made compensation of any kind relating to amateur transmissions from the satellite or Earth station. However, if Dr Smith, or anyone else, receives experiment data from the satellite without making a transmission, there’s no problem.
Q6: In order to be sure no one can take over our satellite we plan to encrypt all transmissions both ways. It's just easier to encrypt everything. We have spent a lot of time and money on this project and don't want anyone messing it up.
A: Then, you must operate in another radio service. Remember, all amateur radio transmissions must be in the clear.
Q7: Our satellite is being built to help poor people in Gronkia. We have volunteer doctors and nurses there who run clinics for patients with AIDS. We will use the satellite to exchange patient data, diagnosis, and treatment information. Since it is a store and forward satellite using common software and amateur frequencies, it will be available to amateurs to exchange messages also, so that makes it ok. Is that right?
A: Making a satellite available for general amateur use is OK if all other operational requirements are met. Use of the satellite by licensed amateurs to support your humanitarian efforts would be OK if (1) they are not compensated and if (2) Gronkia, as well as the country where the messages are received from the satellite, both permit messages to be sent by amateurs on behalf of other people.
USA: Current “Third Party Traffic Arrangements” are listed at: http://www.arrl.org/FandES/field/regulations/io/3rdparty.html. Consult with the national society of amateur radio operators in your country for their listing.
Patient privacy may be the biggest issue: encryption will be necessary, which may not be used in the amateur service. We commend your efforts to help in Gronkia. But, amateur radio is not the way to go.
Q8: We can't afford solar panels for our satellite. But xyz Corp. has agreed to provide panels in exchange for our project 'qualifying' them in space. We will collect telemetry on their performance along with the normal telemetry from the satellite, all of which will be published and available to all amateurs. Does using free commercial solar panels disqualify us from using the amateur bands?
A: It depends. The issue is compensation (pecuniary interest). As long as you meet all amateur requirements, then using freely donated hardware (or software) and sharing what you learn as an amateur is fine. Implicit understandings that you will share data shouldn’t be a problem so long as the sharing isn’t a condition of the donation, which would be a form of compensation. Free will donations have made many satellites and on-board experiments possible.
Free will donations, by definition, are always made with no expectation of anything in return. Indeed, a written record of the donation may be helpful; even necessary.
USA: If donation value (cash or in-kind) exceeds $250, IRS requires that the donor be given a receipt.
At the same time, no data may be hidden. Remember, amateur transmissions must be in the clear and, therefore, open to reception by anyone.
Q9: We are building a satellite that will have transmitters and receivers on both amateur frequencies and commercial frequencies. We plan to operate our experiments and gather some science data using the commercial frequencies for about a year. After that first year, we will have all the data we need and would like to switch to the amateur frequencies and open the satellite for general use by hams. Is that a problem?
A: No, not at all. So long as all the other criteria for amateur stations are met, the plan you describe is just fine. In fact, it's a great way to add to the on-orbit satellite resources in the amateur community while meeting your commercial data requirements.
Q10: Our satellite measures phenomena that lead to devastating natural events. We hope it will prove our ability to measure and predict those events and save thousands of lives. If it works well, we have capital lined up to build a constellation of these satellites and sell the data to governments and researchers for a nominal fee. This is a humanitarian effort using very new science and we don't want to make a profit, just cover our costs. We plan to use amateur frequencies because we don't have the money to get a commercial license. Is this OK?
A: We commend your humanitarian efforts and hope they succeed. Nevertheless, the commercial interests mean that this satellite cannot be in the amateur-satellite service.
Money to work through the licensing process is well spent because it provides an inexpensive measure of insurance: the process helps account for (1) stations which might cause harmful interference to your project and (2) other stations which would receive interference from your satellite, which may require it to be shut down.
Q11: We have developed an amazing new digital coding/decoding system that improves the performance of a satellite link by XX dB. It is fantastic! We plan to demonstrate this new coding technology on amateur frequencies and want amateurs to be the first to benefit from our amazing new technology. We plan to sell the CODEC software to all interested amateurs for only $10 per copy. Of course, we will maintain the source code for our software so that we may later sell copies for a larger sum, allowing us to recover our costs and then make a profit.
A: Commercial enterprises cannot use amateur stations. The developer’s investment (pecuniary interest) cannot rely on the use of an amateur station.
Q12: So, how do I get an amateur radio operator’s license?
A: You take an examination prescribed by the Government consisting of radio and electronic theory, radio law, and operating practices. Limited Morse code proficiency must be shown for licenses giving privileges below 30 MHz. Get more information from you local society of amateur radio operators.
USA: A lot of useful information is at: http://www.arrl.org/hamradio.html.
Q13: Can the University get a ham license?
A: No. Amateur licenses are granted only to individuals. The University may have a club station. But, an individual licensed amateur radio operator will be named as trustee for the club station license. The trustee is personally responsible for proper operation of the club station, not the University.
Q14: What will happen if I don’t have a license and proceed to launch anyway?
A: For security reasons, governments world wide monitor the airwaves. Fines and jail terms (or worse in some countries) await illicit radio operators. Also, amateur radio operators are among the best at finding and identifying new signals on the air and they cooperate closely with government authorities.
USA: The US Department of Transportation will deny launch authority if the satellite has no license.
Q15: How should we proceed if our satellite system is not eligible to use the amateur-satellite service?
A: In many examples here, satellites not qualified to use the amateur-satellite service would be eligible in an existing service or, particularly for short term projects, an Experimental License. See Article 27 of the Radio Regulations.
USA: Obtaining an experimental license is not expensive requiring only a straightforward letter application. Usually, a license can be obtained in three to six months. FCC publishes experimental rules in 47 CFR Part 5. On-line, see: http://www.access.gpo.gov/nara/cfr/waisidx_02/47cfr5_02.html. AMSAT may be able to help you with the process.
Q16: Where can I find more information about rules, services, and other frequency issues?
A: The International Amateur Radio Union (IARU) publishes a good background paper on the subject. See: http://www.iaru.org/satellite/sat-freq-coord.html.
USA: FCC Rules and Regulations are available on-line from the US Government Printing Office. See: http://www.access.gpo.gov/cgi-bin/cfrassemble.cgi?title=200247.
And, the NTIA Manual of Regulations & Procedures for Federal Radio Frequency Management is online at: http://www.ntia.doc.gov/osmhome/redbook/redbook.html.
Q17: Why should I bother to look at these references?
A: All countries and operating agencies world wide rely on the ITU Radio Regulations to help maximize the use of the radio spectrum and to minimize interference — something very important to your project. You’ll find universally accepted nomenclature, emission designations, service types, frequency allocations, and other important and worthwhile references. Many administrations copy major parts of the Radio Regulations into their domestic Rules and Regulations.
USA: FCC and NTIA implement the Radio Regulations domestically where you will see much of the Radio Regulations copied into domestic rules.
USA Q18: If I get a grant from the Government to build a satellite, who is responsible for finding frequencies?
USA A: The Government.
Before funding a project, the Government agency must get frequency support. See: The White House, Executive Office of the President, Office of Management and Budget, Circular A-11. NTIA implements Circular A-11 in the NTIA Manual of Regulations and Procedures (the Redbook).
10.0.2 Satisfying OMB Circular A-11
OMB Circular No. A-11 specifies in Section 34.1: "You must obtain a certification by the National Telecommunications and Information Administration, Department of Commerce that the radio frequency required is available before you submit estimates for the development or procurement of major communications-electronics systems (including all systems employing space satellite techniques)." NTIA certification of spectrum support can be obtained using the procedures in this chapter. The matter of preparation and submission to OMB of budget estimates for Government systems is covered in Section 8.2.5. (Emphasis supplied.)
Good luck with your project!
Call or write AMSAT if you have questions. We will do our best to help you.
Radio Amateur Satellite Corporation (AMSAT®)
PO Box 27
Washington, DC 30044-0027
Tel: (301) 589-6062