The Federal Communications Commission has streamlined its rules of licensing for small satellites. The new rules, which came into effect from August 19, makes the licensing and application procedure easier, faster and less expensive than the current structure under what is known as Part 25 of FCC regulations. The goal is to enable satellites that have shorter missions, less intensive spectrum use, and lower risk of producing orbital debris to be licensed on a streamlined basis, the FCC said.
The move is intended to support and encourage the increasing innovation in the small satellite sector. Earlier in May 19, the US Department of Commerce had released new regulations to improve the licensing process for private satellite remote sensing operations in the country in a move that it sees as helping ensure continued US leadership in a critical commercial space industry.
FCC’s Part 25 satellite licensing rules group satellites into two categories for application processing — geostationary-satellite orbit (GSO) systems and non-geostationary-satellite orbit (NGSO) systems. The same categorization reflects in the Commission’s fee structure. As a result, an application for a single commercial NGSO small satellite with a planned two-year mission is subjected to the same application process and fee as an application for an NGSO communications system consisting of hundreds or more satellites to be replenished on a regular basis.
The new rules, published last month, were developed based on the features and characteristics that typically distinguish small satellite operations from other types of satellite operations, such as shorter orbital lifetime and less intensive frequency use.
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What are the new rules?
Small satellite systems that would qualify for the streamlined rules include those with 10 or lesser number of satellites under a single license. All such individual satellites will have to be 10 cm or larger in its smallest dimension, and weigh less than 180 kg. Maximum in-orbit lifetime of each individual satellite will be six years, including de-orbiting time, and they would have to be deployed under 600 km altitude unless they have the capability to perform collision avoidance and de-orbit maneuvers using propulsion. Each satellite will have a unique telemetry marker for tracking, and will not release any planned debris.
The reduced application fee will be $30,000 for a six-year term, against the current fee of $45,000 for 15-year term under Part 25.
While limiting the number of satellites under a single license to 10, the FCC, however, has not limited the number of applications an entity may file. There were concerns from some companies such as ORBCOMM and SpaceX that no such limits could see applicants unfairly manipulating the process and creating larger satellite constellations. They also argued that failure to limit a single company from obtaining licenses for multiple systems runs the risk of greater collision and interference issues, thereby rendering streamlined treatment inappropriate.
The FCC, however, felt that when viewed in the context of the criteria established for the small satellite licensing process, these concerns were unlikely to be realized in practice. In particular, the small size of these satellites, the six-year orbital lifetime and 600-km maximum altitude criteria all correlated with lower collision risk.
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Further, each streamlined process applicant will have to demonstrate in its application that its proposed operations can co-exist with other operations in the requested frequency band and will not constrain future entrants in the same band. “If a satellite system begins to amass significant and ongoing operations through a series of streamlined applications, there may come a point at which the scope of those operations will start to materially constrain future entrants seeking to use the same frequency bands, or cause issues in sharing with existing operators,” the Commission said, adding that it would not approve the next additional application for satellites that are conducting those types of operations.
A number of companies had also argued that the in-orbit lifetime proposed was too short. However, the FCC clarified that while this may narrow the scope of orbital placement options for certain small satellites or shorten a satellite’s lifetime more than what the satellite is technologically capable of achieving, the goal of this rulemaking was tailor a streamlined licensing process to a subset of satellite operations — those that are of short duration and present a relatively low risk of creating orbital debris.
