This is, without a doubt, the silliest thing I have ever read on page 38. I can't believe they wrote these things into law. What do you compute the probability of hitting a meteor or space station to be in HEO? But since we only do LEO, we do not need to do anything. ;-)
I have been told incorrect information in the last few days. Rinaldo says we need to license, someone else told me we do not have to license and that we can just wait to see what their reaction is to (say) 3.4 GHz on orbit. But it is clear from the regulations as amended in part E of the document (page 20) we have to notify the F.C.C. of our intentions to radiate in advance of launch and we have to be specific and file this with the international bureau. This is tantamount to a license since they get right of refusal. I suggest we find out very early indeed if there is going to be a problem with 3.4 GHz. Rinaldo claimed to me at the symposium that the F.C.C. is going to tell us absolutely NO WAY. After we coordinate with the IARU, I suggest we make this filing. If we are going to be denied 3.4 GHz, we might as well find out now before we expend a lot of effort. I suggest we say 3.4 GHz for regions 2,3 and 1.2 GHz for region 1 in some loosely worded notification.
Bob
Tom Clark, K3IO wrote:
I'm still in CA and am on a distant sideroad on the information highway.
I find out that the Commission on Oct.10 released a Report & Order that makes lots of changes to the amateur regs.
Of particular interest in section E on page 20, the FCC addresses AMSAT's request for more latitude in filing pre-launch information by reducing the old 17 month window to 3 months. A humorous error appears in footnote 163 where they suggest all satellites are LEOs.
Of much more interest is the detailed wording on pages 37/38 where the Commission in part 97.207 finally defines their view of debris, mitigation plans, etc.
The documents can be found at
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.pdf http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.txt http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.doc
and I have attached the PDF version FYI
73, Tom
Via the Eagle mailing list courtesy of AMSAT-NA [email protected] http://amsat.org/mailman/listinfo/eagle
Page 38, paragraph 97.207(1)(iii) is downright confusing. What in the world is the FCC trying to do?
Dick Jansson --------------------------- [email protected] ---------------------------
-----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of Robert McGwier Sent: Thursday, 12 October, 2006 0547 Cc: AMSAT BoD; AMSAT Eagle; AMSAT Advisors; senior-officers Subject: [eagle] Re: FCC Omnibus R&O
This is, without a doubt, the silliest thing I have ever read on page 38. I can't believe they wrote these things into law. What do you compute the probability of hitting a meteor or space station to be in HEO? But since we only do LEO, we do not need to do anything. ;-)
I have been told incorrect information in the last few days. Rinaldo says we need to license, someone else told me we do not have to license
and that we can just wait to see what their reaction is to (say) 3.4 GHz
on orbit. But it is clear from the regulations as amended in part E of
the document (page 20) we have to notify the F.C.C. of our intentions to
radiate in advance of launch and we have to be specific and file this with the international bureau. This is tantamount to a license since they get right of refusal. I suggest we find out very early indeed if there is going to be a problem with 3.4 GHz. Rinaldo claimed to me at the symposium that the F.C.C. is going to tell us absolutely NO WAY. After we coordinate with the IARU, I suggest we make this filing. If we are going to be denied 3.4 GHz, we might as well find out now before
we expend a lot of effort. I suggest we say 3.4 GHz for regions 2,3 and
1.2 GHz for region 1 in some loosely worded notification.
Bob
Tom Clark, K3IO wrote:
I'm still in CA and am on a distant sideroad on the information highway.
I find out that the Commission on Oct.10 released a Report & Order that makes lots of changes to the amateur regs.
Of particular interest in section E on page 20, the FCC addresses AMSAT's request for more latitude in filing pre-launch information by reducing the old 17 month window to 3 months. A humorous error appears
in footnote 163 where they suggest all satellites are LEOs.
Of much more interest is the detailed wording on pages 37/38 where the Commission in part 97.207 finally defines their view of debris, mitigation plans, etc.
The documents can be found at
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.pdf http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.txt http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.doc
and I have attached the PDF version FYI
73, Tom
--
Via the Eagle mailing list courtesy of AMSAT-NA [email protected] http://amsat.org/mailman/listinfo/eagle
Bob, Dick, et all:
This came out of the orbital debris docket which AMSAT-NA commented on, extensively a few years back.
As you probably know, the whole thing came up as a result of a UN initiative which our government felt bound to adhere-to.
(Ray Soifer joked that Colin told Michael to take care of this one.)
As I said, we filed extensive comments which should be on the Web site.
Obviously, what FCC came up with is completely impractical, especially since their requirement for being the licensee of a space station is that the person must hold at least a Technician license. That's not the words they use, but that's what it amounts to. Thus, some kid who just get his (or her) license so he/she can be the licensee of a cubsat his/her school is building, is supposed to be able to meet the requirements of that paragraph.
I guess, we (AMSAT-NA) should come up with some fancy sounding words which we can provide to schools building cubsats and other small amateur satellites, so they can get by the requirement.
It's also interesting that nothing is said about denying permission to launch. In fact, there is no requirement to obtain permission to launch. As I just said, the satellite itself is not licensed, just any ham who volunteers to take on that responsibility. I'm not even sure, but could be wrong, that the notification even asks who the licensee is. I asks about the spcecraft and its characteristics, its orbit etc. The notification requirement is just that, a notification which the Commission supposedly forwards to the ITU, not a permission.
Maybe the Commission staff folks when they wrote the thing, were on the other side of the looking glass, or maybe it was late at night and they were just tired.
73,
Bill ----- Original Message ----- From: "Dick Jansson-rr" [email protected] To: "'Robert McGwier'" [email protected] Cc: "'AMSAT BoD'" [email protected]; "'AMSAT Eagle'" [email protected]; "'AMSAT Advisors'" [email protected]; "'senior-officers'" [email protected] Sent: Thursday, October 12, 2006 8:02 AM Subject: [eagle] Re: FCC Omnibus R&O
Page 38, paragraph 97.207(1)(iii) is downright confusing. What in the world is the FCC trying to do?
Dick Jansson
[email protected]
-----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of Robert McGwier Sent: Thursday, 12 October, 2006 0547 Cc: AMSAT BoD; AMSAT Eagle; AMSAT Advisors; senior-officers Subject: [eagle] Re: FCC Omnibus R&O
This is, without a doubt, the silliest thing I have ever read on page 38. I can't believe they wrote these things into law. What do you compute the probability of hitting a meteor or space station to be in HEO? But since we only do LEO, we do not need to do anything. ;-)
I have been told incorrect information in the last few days. Rinaldo says we need to license, someone else told me we do not have to license
and that we can just wait to see what their reaction is to (say) 3.4 GHz
on orbit. But it is clear from the regulations as amended in part E of
the document (page 20) we have to notify the F.C.C. of our intentions to
radiate in advance of launch and we have to be specific and file this with the international bureau. This is tantamount to a license since they get right of refusal. I suggest we find out very early indeed if there is going to be a problem with 3.4 GHz. Rinaldo claimed to me at the symposium that the F.C.C. is going to tell us absolutely NO WAY. After we coordinate with the IARU, I suggest we make this filing. If we are going to be denied 3.4 GHz, we might as well find out now before
we expend a lot of effort. I suggest we say 3.4 GHz for regions 2,3 and
1.2 GHz for region 1 in some loosely worded notification.
Bob
Tom Clark, K3IO wrote:
I'm still in CA and am on a distant sideroad on the information highway.
I find out that the Commission on Oct.10 released a Report & Order that makes lots of changes to the amateur regs.
Of particular interest in section E on page 20, the FCC addresses AMSAT's request for more latitude in filing pre-launch information by reducing the old 17 month window to 3 months. A humorous error appears
in footnote 163 where they suggest all satellites are LEOs.
Of much more interest is the detailed wording on pages 37/38 where the Commission in part 97.207 finally defines their view of debris, mitigation plans, etc.
The documents can be found at
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.pdf http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.txt http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.doc
and I have attached the PDF version FYI
73, Tom
--
Via the Eagle mailing list courtesy of AMSAT-NA [email protected] http://amsat.org/mailman/listinfo/eagle
-- AMSAT Director and VP Engineering. Member: ARRL, AMSAT-DL, TAPR, Packrats, NJQRP, QRP ARCI, QCWA, FRC. ARRL SDR WG Chair "You see, wire telegraph is a kind of a very, very long cat. You pull his tail in New York and his head is meowing in Los Angeles. Do you understand this? And radio operates exactly the same way: you send signals here, they receive them there. The only difference is that there is no cat." - Einstein
Via the Eagle mailing list courtesy of AMSAT-NA [email protected] http://amsat.org/mailman/listinfo/eagle
Via the Eagle mailing list courtesy of AMSAT-NA [email protected] http://amsat.org/mailman/listinfo/eagle
Bob,
You said "This is tantamount to a license since they get right of refusal."
I do not believe this is correct. I can find no evidence that this is more than a one-way information dump so the FCC can pass the information on to ITU, per ITU rules.
You said "I suggest we find out very early indeed if there is going to be a problem with 3.4 GHz. Rinaldo claimed to me at the symposium that the F.C.C. is going to tell us absolutely NO WAY."
Because we are planning on using the 3.4 GHz satellite band as an uplink only I can see no possible objection to its use by the FCC or anyone else. I need to have this conversation with Paul to see where he is coming from with that comment. I have left him a message and will talk with him today.
Rick W2GPS AMSAT President
-----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of Robert McGwier Sent: Thursday, October 12, 2006 1:47 AM Cc: AMSAT BoD; AMSAT Eagle; AMSAT Advisors; senior-officers Subject: [eagle] Re: FCC Omnibus R&O
This is, without a doubt, the silliest thing I have ever read on page 38. I can't believe they wrote these things into law. What do you compute the probability of hitting a meteor or space station to be in HEO? But since we only do LEO, we do not need to do anything. ;-)
I have been told incorrect information in the last few days. Rinaldo says we need to license, someone else told me we do not have to license and that we can just wait to see what their reaction is to (say) 3.4 GHz on orbit. But it is clear from the regulations as amended in part E of the document (page 20) we have to notify the F.C.C. of our intentions to radiate in advance of launch and we have to be specific and file this with the international bureau. This is tantamount to a license since they get right of refusal. I suggest we find out very early indeed if there is going to be a problem with 3.4 GHz. Rinaldo claimed to me at the symposium that the F.C.C. is going to tell us absolutely NO WAY. After we coordinate with the IARU, I suggest we make this filing. If we are going to be denied 3.4 GHz, we might as well find out now before we expend a lot of effort. I suggest we say 3.4 GHz for regions 2,3 and 1.2 GHz for region 1 in some loosely worded notification.
Bob
Tom Clark, K3IO wrote:
I'm still in CA and am on a distant sideroad on the information highway.
I find out that the Commission on Oct.10 released a Report & Order that makes lots of changes to the amateur regs.
Of particular interest in section E on page 20, the FCC addresses AMSAT's request for more latitude in filing pre-launch information by reducing the old 17 month window to 3 months. A humorous error appears in footnote 163 where they suggest all satellites are LEOs.
Of much more interest is the detailed wording on pages 37/38 where the Commission in part 97.207 finally defines their view of debris, mitigation plans, etc.
The documents can be found at
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.pdf http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.txt http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.doc
and I have attached the PDF version FYI
73, Tom
Via the Eagle mailing list courtesy of AMSAT-NA [email protected] http://amsat.org/mailman/listinfo/eagle
Bob,
I spoke with Paul Rinaldo today. He is concerned that the wording of our press release, as shown on the main AMSAT Web page, could be misinterpreted to imply that we are encouraging Hams in Region 1 to uplink to Eagle on 3.4 GHz (S2-band).
While I disagree with him on this point I see no problem with adding a footnote or comment to every such engineering and news release that explains that we are providing the alternative L-band uplink for those Region 1 users who do not have Amateur Satellite Service authorization on S2-band.
Paul agreed that this will alleviate his concerns about FCC and ITU reaction to our plans.
I copied Paul on this e-mail to be sure he has a chance to comment if I have misunderstood his comments.
Rick W2GPS AMSAT President
-----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of Rick Hambly (W2GPS) Sent: Thursday, October 12, 2006 11:02 AM To: 'Robert McGwier' Cc: 'AMSAT BoD'; 'AMSAT Eagle'; 'AMSAT Advisors'; 'senior-officers' Subject: [Bod] Re: [eagle] Re: FCC Omnibus R&O
Bob,
You said "This is tantamount to a license since they get right of refusal."
I do not believe this is correct. I can find no evidence that this is more than a one-way information dump so the FCC can pass the information on to ITU, per ITU rules.
You said "I suggest we find out very early indeed if there is going to be a problem with 3.4 GHz. Rinaldo claimed to me at the symposium that the F.C.C. is going to tell us absolutely NO WAY."
Because we are planning on using the 3.4 GHz satellite band as an uplink only I can see no possible objection to its use by the FCC or anyone else. I need to have this conversation with Paul to see where he is coming from with that comment. I have left him a message and will talk with him today.
Rick W2GPS AMSAT President
-----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of Robert McGwier Sent: Thursday, October 12, 2006 1:47 AM Cc: AMSAT BoD; AMSAT Eagle; AMSAT Advisors; senior-officers Subject: [eagle] Re: FCC Omnibus R&O
This is, without a doubt, the silliest thing I have ever read on page 38. I can't believe they wrote these things into law. What do you compute the probability of hitting a meteor or space station to be in HEO? But since we only do LEO, we do not need to do anything. ;-)
I have been told incorrect information in the last few days. Rinaldo says we need to license, someone else told me we do not have to license and that we can just wait to see what their reaction is to (say) 3.4 GHz on orbit. But it is clear from the regulations as amended in part E of the document (page 20) we have to notify the F.C.C. of our intentions to radiate in advance of launch and we have to be specific and file this with the international bureau. This is tantamount to a license since they get right of refusal. I suggest we find out very early indeed if there is going to be a problem with 3.4 GHz. Rinaldo claimed to me at the symposium that the F.C.C. is going to tell us absolutely NO WAY. After we coordinate with the IARU, I suggest we make this filing. If we are going to be denied 3.4 GHz, we might as well find out now before we expend a lot of effort. I suggest we say 3.4 GHz for regions 2,3 and 1.2 GHz for region 1 in some loosely worded notification.
Bob
Tom Clark, K3IO wrote:
I'm still in CA and am on a distant sideroad on the information highway.
I find out that the Commission on Oct.10 released a Report & Order that makes lots of changes to the amateur regs.
Of particular interest in section E on page 20, the FCC addresses AMSAT's request for more latitude in filing pre-launch information by reducing the old 17 month window to 3 months. A humorous error appears in footnote 163 where they suggest all satellites are LEOs.
Of much more interest is the detailed wording on pages 37/38 where the Commission in part 97.207 finally defines their view of debris, mitigation plans, etc.
The documents can be found at
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.pdf http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.txt http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.doc
and I have attached the PDF version FYI
73, Tom
Via the Eagle mailing list courtesy of AMSAT-NA [email protected] http://amsat.org/mailman/listinfo/eagle
Great news. Thanks for handling this. Paul asked me into the hall during the symposium to express his concerns. His worries turned out to be reasonable. I received a private note from I8CVS wondering why we would be encouraging Region 1 hams to break the law. If the extra language mitigates this, I think that we should modify our public statements to carefully point out our intentions. May I still suggest that we should attempt to go through the IARU coordination and FCC notification as early as is practicable since we do not wish to build an entire program around a wish and a prayer. If we were going to do that we would fly L band up only.
Bob N4HY
Rick Hambly (W2GPS) wrote:
Bob,
I spoke with Paul Rinaldo today. He is concerned that the wording of our press release, as shown on the main AMSAT Web page, could be misinterpreted to imply that we are encouraging Hams in Region 1 to uplink to Eagle on 3.4 GHz (S2-band).
While I disagree with him on this point I see no problem with adding a footnote or comment to every such engineering and news release that explains that we are providing the alternative L-band uplink for those Region 1 users who do not have Amateur Satellite Service authorization on S2-band.
Paul agreed that this will alleviate his concerns about FCC and ITU reaction to our plans.
I copied Paul on this e-mail to be sure he has a chance to comment if I have misunderstood his comments.
Rick W2GPS AMSAT President
Guys: Like Rick, I think our original announcement was sufficient.
Re-reading it from Paul's perspective, however, and I can see room for improvement. I'll get a sentence added to the L-band paragraph ASAP. 73, Jim [email protected]
Robert McGwier wrote:
Great news. Thanks for handling this. Paul asked me into the hall during the symposium to express his concerns. His worries turned out to be reasonable. I received a private note from I8CVS wondering why we would be encouraging Region 1 hams to break the law. If the extra language mitigates this, I think that we should modify our public statements to carefully point out our intentions. May I still suggest that we should attempt to go through the IARU coordination and FCC notification as early as is practicable since we do not wish to build an entire program around a wish and a prayer. If we were going to do that we would fly L band up only.
Bob N4HY
Rick Hambly (W2GPS) wrote:
Bob,
I spoke with Paul Rinaldo today. He is concerned that the wording of our press release, as shown on the main AMSAT Web page, could be misinterpreted to imply that we are encouraging Hams in Region 1 to uplink to Eagle on 3.4 GHz (S2-band). While I disagree with him on this point I see no problem with adding a footnote or comment to every such engineering and news release that explains that we are providing the alternative L-band uplink for those Region 1 users who do not have Amateur Satellite Service authorization on S2-band.
Paul agreed that this will alleviate his concerns about FCC and ITU reaction to our plans.
I copied Paul on this e-mail to be sure he has a chance to comment if I have misunderstood his comments.
Rick W2GPS AMSAT President
participants (6)
-
Bill Tynan -
Dick Jansson-rr -
Jim Sanford -
Rick Hambly (W2GPS) -
Robert McGwier -
Tom Clark, K3IO