Smallsat Authorization Streamlining Sees Disparate Views on Maneuvering, Lifespans

FCC's proposed streamlining of authorizations for small-satellite operators also hasn't received clear consensus on what constitutes a smallsat (see 1807100014). A five-year cap restricts launch opportunities and could make the streamlined process "commercially impracticable," the Commercial Smallsat Spectrum Management Association (CSSMA) said. It said on-orbit lifetime limits should apply on a satellite-by-satellite basis and not cover all satellites on a given license because of launch delays and launch spacing. But SES/O3b said the cap, starting when the satellite is in its authorized orbit, will create incentives to limit constellation sizes only to what's necessary. And Iridium said a cap, paired with rules letting the FCC terminate authorizations due to in-orbit satellite failures, could help ensure there won't be "a mushrooming accumulation" of space debris. Audacy criticized the proposed five-year on-orbit lifetime and said the agency should allow three-year extensions atop that. Multiple parties argued against excluding from the streamlined process applicants without propulsion capability that want to deploy higher than the International Space Station. SpaceX said there could be new smallsat maneuvering strategies or technology changes that make propulsion more commonplace. But Iridium said the fact some smallsats will deploy maneuvering techniques that don't rely on propulsion doesn't mean all of them will. Multiple parties also agreed propulsion shouldn't be a requirement for going through the streamlined process, with CSSMA saying there are other issues beyond altitude -- such as spatial density and relative velocity -- that also define the risk of a constellation. There was also lack of agreement on limits on the number of applications an individual entity can file under the streamlined process, with multiple parties backing the idea of no limit, but Orbcomm said that in turn raises risk of collision or harmful interference that makes the streamlined treatment inappropriate. Audacy backed limiting the number of satellites under the streamlined process to 10 per license, which the Commercial Spaceflight Federation opposed (see here). Audacy also said small satellites should be exempt from processing round procedures and bond requirements for streamlined process applicants, but SES/O3b disagreed with eliminating the bond requirement. And Iridium argued against allowing smallsat uplinks in the 1616-1626.5 MHz band, which it uses for service links. The Radio Amateur Satellite Corp. said evaluating authorization of an amateur radio service mission shouldn't need to look at issues like ownership or mission funding sources.