The FCC Moves to Accommodate Small Satellites

Photo courtesy of NASA Goddard Space Flight Center via the Creative Commons License.

Satellites - even small ones - need radio spectrum. Without radios to communicate, a satellite is just a hunk of metal and plastic in the sky.

The first man-made satellite, the Russian Sputnik in 1957, carried nothing but a radio transmitter. It sent a sequence of beeps that said: I am here.

Early communications satellites soon followed. These too are basically just radios in orbit; receivers to pick up signals from the ground and transmitters to send the same signals to somewhere else on the ground. With commercialization looming, the FCC allocated hundreds of megahertz of prime spectrum and set up licensing regimes for both satellite space stations and earth stations. Satellite launches needed an A-OK from the FCC.

The next few decades saw communications satellites grow in both physical size and transmission capacity. Some were the size of a school bus and weighed 6 tons. Joining them were satellites that photographed the ground from orbit and sent pictures down by radio: for espionage, weather forecasting, crop management, and checking out your house on Google Earth. Some of these applications needed a lot of spectrum and the FCC kept allocating more and more of it.

But even as the commercial satellites got bigger, a countertrend appeared. Hobbyists, researchers, and amateur radio operators saw value in much smaller satellites that could launch inexpensively by piggy-backing on the rockets that lifted the big ones. The smallest of these in regular use are CubeSats: standardized cubes measuring inches on a side. (A company recently got in trouble for launching something smaller, after the FCC told them not to.) Some satellites take the form of two, three, or six CubeSats piled on top of each other, like cubical Lego blocks.

It has been relatively easy to license small satellites for experimental or amateur-radio use. But innovators who wanted to try commercial applications have been stymied. All commercial satellites, even the really small ones, are subject to the same licensing regime, which includes a lot of sophisticated paperwork. The application filing fees run well into six figures. The FCC uses a "processing round" procedure that adds complexity and delay. A successful applicant must post a seven-figure surety bond to ensure that its satellites actually launch and become operational within specified timeframes. These rules work for large commercial satellites, and for large fleets of small satellites expected to function for years. But they effectively rule out small commercial satellites in smaller numbers, and those designed for short lives in orbit.

The FCC now proposes a separate, streamlined licensing scheme for small satellites, tentatively defined as those weighing 180 kg or less. By comparison, a one-unit CubeSat weighs about a kilogram so the proposals would cover some pretty big "small satellites." A single license would authorize no more than ten satellites, and their planned in-orbit lifetimes would have to be five years or less. The license term would likewise be five years, starting when the first satellite reaches its authorized orbit and could not be extended or renewed. To lower the risk of collision with the International Space Station, anything launched into an orbit higher than the ISS needs a propulsion system so that it can maneuver if needed. Other requirements for streamlined licensing include:

• The risk of human casualty on the ground from a satellite re-entering the atmosphere must be zero (most small satellites completely burn up on re-entry);
• The risk of collision with large objects must be less than 0.001;
• The satellite must not release debris while in orbit and must have a low risk of exploding in orbit;
• The size must be no smaller than a 4 x 4 x 4 inch CubeSat, to ensure it can be tracked from the ground;
• It must be possible to shut off the satellites' radios from the ground; and
• In a throwback to that first Sputnik, each satellite must include a unique telemetry marker to distinguish it from other objects in space.

Because the satellite will have to share spectrum with other users, systems that require full-time, uninterrupted availability of assigned spectrum would not eligible for streamlined processing.

As to the surety bond, the FCC proposes a one-year grace period to start 30 days after the license is granted. A licensee that has not deployed 50 percent of its satellites by that time will have three options: it can post the bond, amend the license to reflect the number of satellites then in orbit, or surrender the license.

The Notice of Proposed Rulemaking also includes a lot of information on frequency usage - too much and too detailed to summarize here, but you can find it all at this link.

Comment and reply dates are not yet available. But we're betting the FCC will get a lot of enthusiastic responses. Let us know if you have any questions. Contact us if you have questions.