An FCC Report and Order (R&O) released August 2 in the so-called 'small satellite' rulemaking proceeding, IB Docket 18-86, failed to address concerns expressed by ARRL and AMSAT.
Both organizations filed comments on the FCC Notice of Proposed Rulemaking (NPRM) in the proceeding last year, seeking changes in the FCCs interpretations and procedures affecting satellites operating on Amateur Satellite Service frequencies.
“These comments address topics outside the scope of this proceeding, and we decline to adopt any of the requested rule modifications or updates at this time,” the FCC said in the R&O. The FCC did mention amateur satellites in its 2018 NPRM, explaining what they are and describing the documentation and authorization process, but it did not solicit comments.
“The Commission did not seek comment in the NPRM on any modifications or updates to the rules governing Experimental or amateur satellite licensing. The streamlined Part 25 small satellite process adopted in the Order is an alternative to existing license processes and does not replace or modify the authorization procedures for satellites currently contained in Parts 5, 25, or 97 of the Commission’s rules,” the FCC explained.
“Nevertheless, we received a number of comments in response to the NPRM, particularly regarding the rules applicable to amateur satellite operations, suggesting that aspects of those rules be im- proved or clarified.”
In its 2018 NPRM, the FCC had said, “Because the type of operations that qualify as amateur [is] narrowly defined, an amateur satellite authorization will not be appropriate for many small satellite operations.”
In its 2018 comments, ARRL said it wanted the FCC to preclude exploitation of amateur spectrum by commercial small-satellite users authorized under Part 5 Experimental rules and suggested that the FCC adopt a “a bright line test” to define and distinguish satellites that should be permitted to operate under Amateur Satellite rules.
ARRL’s position was to support and encourage college and university Amateur Radio experiments where the sponsor of the experiment is a licensed radio amateur and all operation in amateur spectrum is compliant with Part 97. Part 5 Experimental authorizations for satellites intended to operate in amateur allocations by non-amateur sponsors should be discouraged, absent a compelling show of need, ARRL told the FCC.
The International Amateur Radio Union (IARU) announced in 2017 that it would no longer coordinate non-amateur satellite operations unless directed to do so by the national administration, and it adopted new satellite frequency coordination guidelines that require educational and university satellites to have an identified amateur component.
AMSAT’s comments reflected many of the same concerns that ARRL had expressed.