Thanks for pointing this out, Joe. I had seen this come by a couple of days ago and AMSAT will certainly be filing comments on the proposed rulemaking as we have in the past.
I struggle with the idea that the FCC is the appropriate agency to impose these requirements, especially to the extent that they exceed NASA's own standards. That said, they are determined to do this.
Five years post-mission disposal in LEO is not necessarily a major problem given the available launches these days, but the Commission needs to be flexible in allowing universities and non-profit organizations like AMSAT to experiment with simple, low-cost methods of achieving this goal - like simple tethers - that may not be 100% reliable or provide absolute certainty of deorbiting within that timeframe. The regulations have always stated that you must have a plan to achieve disposal, not that you must dispose of them, but in practice they have not accepted methods that haven't been space-proven.