The Federal Communications Commission has proposed adding an innovative regulatory regime to Part 25 of its rules to enable deployment of small satellite systems. The proposal is aimed at NGSO-like small satellite systems engaged in small-scale operations using spacecraft with short life expectancies. Eligible satellite systems could elect to use a new streamlined small satellite authorization process aimed at easier approvals and reduced regulatory burdens.

Traditional large commercial Fixed Satellite Service, Mobile Satellite Service and SDARS would not be eligible for these streamlined procedures.

Highlights of the FCC’s Proposed Rules

General Licensing Terms

The proposed rules would:

• Establish a 5 year license term, to begin when the first satellite is placed into orbit

• Require deorbiting of all satellites in a system within the 5 year license period, with no license extensions possible

• Not require replacement satellites

Spacecraft Characteristics and Certifications

The proposed rules would: 

• Limit the size of spacecraft to no larger than a maximum mass of 180 kg
• Require a showing that deployment and maneuverability strategies would protect the International Space Station
• Not allow the release of operational debris
• Require that spacecraft are assessed for the possibility of accidental explosions
• Set the probability of a risk of collision with large objects at less than 0.001
• Require spacecraft to be no smaller than 10x10x10 cm, to ensure trackability as space objects
• Require spacecraft disposal via atmospheric re-entry, as well as certification that assessment indicates a casualty risk of zero
• Require the ability of spacecraft to cease radio transmissions as a result of a command

Application Processing

The proposed rules would:

• Exempt small sats from traditional processing round procedures
  • Coexistence with both current and existing traditional operators must be certified to demonstrate that the interference footprint is not inconsistent with any existing or planned services
• Require use of application Form 312 and Schedule S
  • Certifications would replace most narrative statements
• Establish an application fee of $30,000
  • Defers determination of annual regulatory fees to the next regulatory fee proceeding
• Require a surety bond only if use of a license is postponed for more than one year after license grant

Technical Rules

The proposal:

• Seeks comment on the ability of small sats to share satellite frequency allocations
• Seeks comment on frequencies and bandwidth required
• Seeks comment on sharing frequencies with federal users
• Suggests use of specific frequency bands (137-138 and 148-150.05 MHz, 1610.6-1613.8 MHz)
• Tentatively concludes that inter-satellite links be allowed on MSS frequencies (1.6 and 2.4 MHz)

The Commission also seeks comment about the applicability of the streamlined procedures to commercial lunar missions, and other non-earth orbiting missions, rather than limiting the procedures to earth-orbiting satellites.

Due dates for public comments on the proposed rules will be established soon.

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