AMSAT Files Comments in FCC Orbital Debris Mitigation Proceeding

The Federal Communications Commission has proposed several rules changes related to the amateur satellite service as part of a Notice of Proposed Rulemaking (NPRM) related to the mitigation of orbital debris. AMSAT believes several of these rule changes would have an extremely detrimental effect on the amateur satellite service and AMSAT’s ability to launch and operate new satellites, including AMSAT’s upcoming GOLF satellites.

Today, AMSAT filed comments on the proposed rulemaking. In the comments, AMSAT argues that amateur satellites often have longer mission lifespans than other small satellite missions and that the Commission should take a mission duration of 5 to 10 years into account when determining whether or not an amateur satellite will meet the orbital debris regulations by transferring to a parking orbit or re-entering the atmosphere within 25 years of mission completion. The current practice is to assume a “zero year” mission and to require that amateur satellites either transfer to a parking orbit or re-enter within 25 years following launch.

AMSAT also urged the Commission to consider alternatives to a proposed rule that would restrict satellites in Low Earth Orbit that plan to meet the orbital debris mitigation guidelines through atmospheric re-entry to altitudes of 650 km or less. AMSAT noted that, had this rule been in place, AO-85 and AO-91 would not have been able to be deployed in their current ellipitcal orbits with apogees of approximately 800 km, despite the fact that both of these satellites will re-enter within 25 years due to their low perigees. Additionally, AMSAT noted that current plans for the GOLF-1 satellite are to meet orbital debris mitigation guidelines through atmospheric re-entry by deploying a drag device that will ensure re-entry within 25 years despite deployment at an altitude of above 1,000 km. This proposed rule would prohibit GOLF-1’s deployment at that altitude.

The Commission’s proposed rules would also require that amateur satellite licensees indemnify the government against any claims made against the United States due to the operation of the satellite. AMSAT believes this proposal would end the ability of AMSAT, or any other entity in the United States, to launch and operate amateur satellites and urges the Commission to consider alternatives, such as establishing a fund to pay any such claims, noting that the likelihood of such a claim is low.

For amateur satellites with propulsion, the Commission proposes a rule that would require any command links as well as satellite telemetry be encrypted. While AMSAT understands and agrees that a satellite carrying a propulsion system must have an encrypted command link, the proposal to require all satellite telemetry be encrypted is unnecessary and counter to the spirit of the amateur service. AMSAT notes that open access to telemetry is expected of amateur satellites and is critical to the educational component of amateur radio satellites.

Finally, AMSAT proposes that the Commission exempt amateur space stations co-located on other spacecraft from the orbital debris mitigation regulations, including any indemnification rule. Noting that AMSAT has pursued opportunities to fly a payload as a rideshare aboard government or commercial satellites, AMSAT argues that, as the satellite’s owner will need to meet orbital debris mitigation requirements to obtain the license in the primary mission’s service, requiring the amateur licensee to meet the orbital debris mitigation requirements as well is redundant. AMSAT proposes that Part 97 be amended to state that amateur space stations co-located on spacecraft with space stations authorized under Part 25 of the Commission’s regulations (for commercial spacecraft) or by the National Telecommunications and Information Administration (NTIA) (for government spacecraft) are exempt from these regulations.

AMSAT’s comments as filed may be read in their entirety below.

Comments of Radio Amateur Satellite Corporation - IB Docket No 18-313

The comments may be downloaded at https://www.amsat.org/wordpress/wp-content/uploads/2019/04/Comments-of-Radio-Amateur-Satellite-Corporation-IB-Docket-No-18-313.pdf.

The NPRM is International Bureau Docket #18-313 and is available at https://docs.fcc.gov/public/attachments/FCC-18-159A1.pdf.

Interested parties may file reply comments by May 5th at https://www.fcc.gov/ecfs/

AMSAT Announces 50th Anniversary Space Symposium in Washington, DC

The 2019 AMSAT 50th Anniversary Symposium will be held at The Hilton Arlington in Arlington, VA, in the Washington, DC Metro Area on October 18, 19, and 20, 2019.

The Hilton Arlington is located in the heart of the Ballston neighborhood of Arlington, VA. Connected to the Ballston Metro Station, the hotel offers easy and effortless access to Washington, DC’s top tourist destinations like the National Mall, Smithsonian museums and historic monuments. The hotel is six miles from Reagan National Airport and the National Mall.

The AMSAT Board of Directors Meeting will be held at the hotel on  October 16th and 17th. Tours of the Washington DC / Baltimore area will be held Sunday and Monday, October 20th and 21st. The banquet speakers will celebrate AMSAT’s long history, so please plan on attending the 50th Anniversary Symposium. You will be glad you did!

Keep checking ANS and the AMSAT Website for further updates and information, including hotel reservation details.

Es’hail-2/P4A Designated Qatar-OSCAR 100 (QO-100)

On November 15, 2018, Es’hail-2/P4A was launched on a Falcon 9 launch vehicle from the Cape Canaveral Air Force Station Space Launch Complex 40 in Florida. Es’hail-2/P4A was developed jointly by QARS (Qatar Amateur Radio Society) and Es’hailSat (the Qatar Satellite Company), with AMSAT-DL as the technical lead, and is the first geostationary amateur radio payload. The satellite has reached its final position at 25.9 °E, and the narrow and wideband transponders were successfully tested on December 23rd. The transponders are expected to be opened for general use in February 2019.

At the request of AMSAT Deutschland e.V., QARS, and Es’hailSat, AMSAT hereby designates Es’hail-2/P4A as Qatar-OSCAR 100 (QO-100). May the
100th OSCAR satellite be the guide star to future amateur radio satellites and payloads to geostationary orbit and beyond.

73,

Drew Glasbrenner, KO4MA
AMSAT VP Operations / OSCAR Number Administrator

 

GOLF-TEE $15,000 Matching Funds President’s Challenge

In October 2017 AMSAT announced the GOLF (Greater Orbit, Larger Footprint) program. The first project of the GOLF program is a technology demonstrator named GOLF-TEE (Technology Evaluation Environment). The design is a 3U CubeSat with deployable solar panels, ADAC (attitude determination and control), Software Defined Radio (SDR) Transponder, and a Vanderbilt University Low Energy Proton (LEP) experiment. Now is the time to begin work on the GOLF-TEE Project.

At the end of 2017, AMSAT has generous offers from two AMSAT Past Presidents for matching funds up to $15,000 for those that contribute to the GOLF-TEE campaign at https://www.paypal.com/cgi-bin/webscr?cmd=_s-xclick&hosted_button_id=STK27W4G9RMLC between now and February 15th. Make your donation twice as valuable by taking advantage of this opportunity and contributing, and help AMSAT fund the launch of the next series of satellites of the GOLF program. There are also donate buttons for GOLF-TEE on the AMSAT website. Planning is for a launch in 2019.

Donations of $100 and $1,000 or more will be eligible for a special AMSAT GOLF premium. (Both premiums are currently being designed, so please be patient awaiting delivery.)

AMSAT is a 501-(c)-(3) not-for-profit educational and scientific organization of amateur radio operators whose purpose is to design, construct, launch, and operate satellites in space and to provide the support needed to encourage amateurs to utilize these resources. Please consider a tax-deductible contribution to AMSAT to help underwrite the development and launch expenses of our GOLF satellite program.

Donors wishing to provide additional matching funds please contact Joe Spier, K6WAO at k6wao@amsat.org.

AMSAT Vice-President Engineering Jerry Buxton, N0JY, introducing GOLF at the 2017 AMSAT Space Symposium in Reno, NV.