Part 25 Smallsat Rules Shouldn't Replace Other Authorization Routes, FCC Told
The FCC satellite licensing streamlining NPRM should be an addition to, and not a replacement for, existing Part 5 and Part 97 routes for getting small satellite authorizations, representatives of the University of Colorado and its Samuelson-Glushko Technology Law &…
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Policy Clinic told International Bureau staff, recounted a docket 18-86 filing Thursday. They said lowering the $30,000 application fee to perhaps be on par with Part 5 experimental license fees would be helpful to scientific or educational applicants with limited budgets. They argued against requiring propulsion capabilities for Part 25 streamlined eligibility as that could preclude many smallsat missions from using the streamlined process, saying other options are available to guarantee safe deorbiting, such as passive deorbiting acceleration. They suggested more flexibility on requiring satellite trackability for streamlined eligibility other than minimum dimensions, and "remain open-minded" about size requirement waivers.