Life to get more difficult for US Cubesat operators.
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
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
Sent via AMSAT-BB(a)amsat.org. AMSAT-NA makes this open forum available to all interested persons worldwide without requiring membership. Opinions expressed are solely those of the author, and do not reflect the official views of AMSAT-NA. Acceptable Use and Privacy Policies available at https://www.amsat.org/about-amsat/
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It would be nice if cubesats were not assumed to have a 0 life too (i.e. 5 years from the real end of mission rather than launch). For example AO-91 should not yet have the clock ticking. One could argue the same for 92, 95, and 109 too.
On Fri, Sep 9, 2022 at 1:00 PM Paul Stoetzer n8hm@arrl.net wrote:
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
Sent via AMSAT-BB(a)amsat.org. AMSAT-NA makes this open forum available to all interested persons worldwide without requiring membership. Opinions expressed are solely those of the author, and do not reflect the official views of AMSAT-NA. Acceptable Use and Privacy Policies available at https://www.amsat.org/about-amsat/
View archives of this mailing list at https://mailman.amsat.org/hyperkitty/list/amsat-bb@amsat.org To unsubscribe send an email to amsat-bb-leave(a)amsat.org Manage all of your AMSAT-NA mailing list preferences at https://mailman.amsat.org
Sent via AMSAT-BB(a)amsat.org. AMSAT-NA makes this open forum available to all interested persons worldwide without requiring membership. Opinions expressed are solely those of the author, and do not reflect the official views of AMSAT-NA. Acceptable Use and Privacy Policies available at https://www.amsat.org/about-amsat/
View archives of this mailing list at https://mailman.amsat.org/hyperkitty/list/amsat-bb@amsat.org To unsubscribe send an email to amsat-bb-leave(a)amsat.org Manage all of your AMSAT-NA mailing list preferences at https://mailman.amsat.org
Right, the regulation is not necessarily a big problem - the way it's implemented is the most important thing.
73,
Paul, N8HM
On Fri, Sep 9, 2022 at 4:14 PM Burns Fisher wb1fj-bb@fisher.cc wrote:
It would be nice if cubesats were not assumed to have a 0 life too (i.e. 5 years from the real end of mission rather than launch). For example AO-91 should not yet have the clock ticking. One could argue the same for 92, 95, and 109 too.
On Fri, Sep 9, 2022 at 1:00 PM Paul Stoetzer n8hm@arrl.net wrote:
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
Sent via AMSAT-BB(a)amsat.org. AMSAT-NA makes this open forum available to all interested persons worldwide without requiring membership. Opinions expressed are solely those of the author, and do not reflect the official views of AMSAT-NA. Acceptable Use and Privacy Policies available at https://www.amsat.org/about-amsat/
View archives of this mailing list at https://mailman.amsat.org/hyperkitty/list/amsat-bb@amsat.org To unsubscribe send an email to amsat-bb-leave(a)amsat.org Manage all of your AMSAT-NA mailing list preferences at https://mailman.amsat.org
Sent via AMSAT-BB(a)amsat.org. AMSAT-NA makes this open forum available to all interested persons worldwide without requiring membership. Opinions expressed are solely those of the author, and do not reflect the official views of AMSAT-NA. Acceptable Use and Privacy Policies available at https://www.amsat.org/about-amsat/
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It states end of mission which is open ended. On the surface, this would likely require additional cost for CubeSat operators and developers. Let’s say we created AO-91 under these proposed five year standards. If AO-91 stops responding one day, how can you guarantee it deorbits? It would require a backup deorbit system. Do we install a deadman’s switch? Better yet, how was AO-91 designed so it deorbits within 25 years EOM?
Drag sails and other drag devices have been designed such as the DD3 and Spinnaker3 (RIP). It still feels sort of experimental and in the research realm.
There could be a RFC period where various designs are proposed for different platforms. Then, iterate on those and give designers time to adapt their platforms before proposing a five year limit. A quick Googling says 855 CubeSats were launched from 2002 to May 31, 2018. Since most if not all CubeSats go to LEO, this proposal feels targeted at CubeSats and SpaceX though SpaceX has a larger budget than say a University funded CubeSat.
That being said, the amount of artifacts in LEO appears to be accelerating.
Some other quick Googling says about 1300 satellites were launched to LEO in 2020 with about 3,000 satellites in LEO. How many should have deorbited by now due to EOM? None? Then even with the five year rule we haven’t solved the real problem.
On Fri, Sep 9, 2022 at 4:25 PM Paul Stoetzer n8hm@arrl.net wrote:
Right, the regulation is not necessarily a big problem - the way it's implemented is the most important thing.
73,
Paul, N8HM
On Fri, Sep 9, 2022 at 4:14 PM Burns Fisher wb1fj-bb@fisher.cc wrote:
It would be nice if cubesats were not assumed to have a 0 life too (i.e. 5 years from the real end of mission rather than launch). For example AO-91 should not yet have the clock ticking. One could argue the same for 92, 95, and 109 too.
On Fri, Sep 9, 2022 at 1:00 PM Paul Stoetzer n8hm@arrl.net wrote:
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
Sent via AMSAT-BB(a)amsat.org. AMSAT-NA makes this open forum available to all interested persons worldwide without requiring membership. Opinions expressed are solely those of the author, and do not reflect the official views of AMSAT-NA. Acceptable Use and Privacy Policies available at https://www.amsat.org/about-amsat/
View archives of this mailing list at https://mailman.amsat.org/hyperkitty/list/amsat-bb@amsat.org To unsubscribe send an email to amsat-bb-leave(a)amsat.org Manage all of your AMSAT-NA mailing list preferences at https://mailman.amsat.org
Sent via AMSAT-BB(a)amsat.org. AMSAT-NA makes this open forum available to all interested persons worldwide without requiring membership. Opinions expressed are solely those of the author, and do not reflect the official views of AMSAT-NA. Acceptable Use and Privacy Policies available at https://www.amsat.org/about-amsat/
View archives of this mailing list at https://mailman.amsat.org/hyperkitty/list/amsat-bb@amsat.org To unsubscribe send an email to amsat-bb-leave(a)amsat.org Manage all of your AMSAT-NA mailing list preferences at https://mailman.amsat.org
Sent via AMSAT-BB(a)amsat.org. AMSAT-NA makes this open forum available to all interested persons worldwide without requiring membership. Opinions expressed are solely those of the author, and do not reflect the official views of AMSAT-NA. Acceptable Use and Privacy Policies available at https://www.amsat.org/about-amsat/
View archives of this mailing list at https://mailman.amsat.org/hyperkitty/list/amsat-bb@amsat.org To unsubscribe send an email to amsat-bb-leave(a)amsat.org Manage all of your AMSAT-NA mailing list preferences at https://mailman.amsat.org
participants (4)
-
Brian Wilkins -
Burns Fisher -
Joseph B. Fitzgerald -
Paul Stoetzer