 New
orbital debris mitigation rules will apply to ham sats
New FCC Amateur Radio space station rules will impose requirements
to mitigate orbital debris.
The FCC adopted a Second Report and Order (R&O) in IB
Docket 02-54 on June 9. The new rules, appearing September 9 in the Federal
Register, affect Parts 5 (Experimental Service), 25 (Satellite Communications)
and 97 (Amateur Service) of the FCC's rules and regulations.
In general, they require submission of an "orbital debris mitigation
plan" to the FCC with each license application.
AMSAT-NA - the Radio Amateur Satellite Corporation - had wanted Amateur
Radio exempted from any orbital debris mitigation requirements that went
beyond what the FCC initially proposed for Part 97 in 2002. AMSAT-NA President
Robin Haighton, VE3FRH, said the organization is discussing the implications
of the R&O but has no formal position yet.
"While AMSAT does not like to be restricted - we are free enterprise
people - we do acknowledge that even space is not limitless," Haighton
told ARRL. "The more debris there is, particularly in lower orbits,
the more danger there is of collisions and eventually the greater the
difficulty in
defining launch windows."
Haighton said that between now and the AMSAT-NA Symposium and Annual
Meeting in October, the AMSAT Board of Directors "will have a chance
to evaluate the FCC position and try to develop our own guidelines and
requirements for building AMSAT satellites."
The AMSAT-NA president said that while he personally agrees with the
notion of limiting space debris, "the application of this principle
may be a problem."
In its formal comments in 2002, AMSAT-NA commended the FCC for initiating
the proceeding and agreed that the growing quantity of space debris "presents
a potential problem to all who wish to use space" and that "methods
of controlling and reducing it are called for."
The new rules the FCC has ordered will significantly expand §97.207(g)
in the Amateur Service rules governing space stations. The additional
provisions will require "a description of the design and operational
strategies the space station will use to mitigate orbital debris"
that include statements covering several specific areas. Space station
license
grantees will have to state, among other things, that they have "assessed
and limited the amount of debris released in a planned manner during normal
operations" as well as the probability that the space station itself
could become a source of debris through collisions with other debris or
meteoroids.
In its comments, AMSAT took "strong exception when it comes to meteors."
Those launching satellites, AMSAT said, can assess the orbital parameters
of known objects but "no such information is available for meteors."
Satellite licensees also must state that they have assessed and limited
the probability of accidental explosions during and after completion of
mission operations. "This statement must include a demonstration
that debris generation will not result from the conversion of energy sources
on board the spacecraft into energy that fragments the spacecraft,"
a new
97.207(g)(1)(ii) rule section specifies.
Such a scenario occurred in the case of AO-40, which apparently suffered
a catastrophic onboard event not long after it went into orbit in 2000.
AO-40 went silent earlier this year. AMSAT has commented that as a practical
matter, the objective of minimizing debris from accidental explosions
"is unlikely to be met by additional failure-mode analysis."
The demonstration would have to address whether "stored energy"
would be removed at the end of the spacecraft's life "by leaving
all fuel line valves open, venting any pressurized system, leaving all
batteries in a permanent discharged state and removing any remaining source
of stored energy."
Satellite licensees will have to include a statement disclosing the "accuracy - if
any - with which orbital parameters of non-geostationary satellite orbit
space stations will be maintained." AMSAT has asserted that "state-of-the-art
practices do not allow specification of the
Keplerian orbital elements of spacecraft with sufficient accuracy to predict
or avoid the collision of two space objects."
AMSAT pointed out that many smaller satellites of the type most likely
to be launched for Amateur Satellite use lack propulsion systems to maintain
a certain orbital tolerance or to deorbit the spacecraft when its mission
is over. Most, AMSAT told the FCC, would burn up in the atmosphere.
AMSAT had suggested in its reply comments that the issue of orbital debris
needed more study and broader participation by stakeholders, "because
of the complexity of the matter and the economic impact regulations might
have on future satellites."
The FCC has not yet announced an effective date for the new Part 97 rules.
Source: ARRL Letter - courtesy of The
American Radio Relay League
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