Hi all,
Further to my earlier e-mail about the Omnibus R&O, my recommendation for now is that AMSAT proceed with the IARU coordination process for the proposed Eagle frequency plan, but that any out-of-the-ordinary action with FCC is unwarranted.
The proposed orbital debris language is not now in effect, for the reasons discussed in my earlier e-mail. It is AMSAT's position, as stated in our recon petition, that FCC does not have the authority to adopt or enforce it.
The ITU notification process provided for in the R&O is just that, notification, and is not in any sense a scheme for licensing space stations in advance. FCC's position on that is very clear, and stated in Sec. 97.207: any amateur station may be a space station. Full stop. We may not like that for whatever reason, but as the shady mutual-fund operator Bernie Cornfeld once said about the SEC, "they may be schmucks but they're the government."
The way things will work in practice is that when we file our notification with FCC, they will in due course inform the ITU Radiocommunication Bureau. The Bureau will, in turn, inform member states, any of which may object. If they do, it is up to them and FCC to work it out. In such a case, our response would be very simple: "Our uplink causes no interference, harmful or otherwise. If you don't like it, just tell your country's amateur licensees not to use it."
In the meantime, the fewer waves made, the better.
My 3 cents worth (before tax, that is).
73,
Ray