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. 

73,

Paul, N8HM

On Fri, Sep 9, 2022 at 11:58 AM Joseph B. Fitzgerald <jfitzgerald@alum.wpi.edu> wrote:

The FCC wants to "adopt a five-year rule, which would require space station operators planning disposal through
uncontrolled re-entry into Earth’s atmosphere to complete disposal as soon as practicable, and no
more than five years following the end of mission."

see https://docs.fcc.gov/public/attachments/DOC-387024A1.pdf

No exemption for us hams operating under Part 97 of the FCC rules either, although waivers for certain research
and scientific missions may be granted.


de KM1P

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