Proposed FCC Rule Could Effectively Stop Many University CubeSat Launches
Streamlining Licensing Procedures for Small Satellites, FCC
“In this document, the Federal Communications Commission proposes to streamline its rules to facilitate the deployment of a class of satellites known as small satellites, which have relatively short duration missions.”
New federal policy would hike student spacecraft costs, threatening technology education, The Conversation
“In a move that threatens U.S. education in science, technology, engineering and math, and could have repercussions throughout the country’s aerospace industry, the FCC is proposing regulations that may license some educational satellite programs as commercial enterprises. That could force schools to pay a US$135,350 annual fee – plus a $30,000 application fee for the first year – to get the federal license required for a U.S. organization to operate satellite communications.”
Update: Brian Weeden of the Secure World Foundation states in a comment that “the new proposed NGSO license is for constellations of commercial smallsats that did not fit into any of the existing license categories. All of the existing educational cubesats were able to get FCC licenses via the amateur or experimental process, and those processes remain unchanged.”
Here’s a link to an article on how small companies are dealing with similar issues with the FCC regarding small satellites.
The FCC has been acting bizarrely inconsistent. That is driving the small sat community to seek foreign launching of small satellites or through NASA that uses the National Telecommunication and Information Administration (NTIA) rather than the FCC. The FCC then retaliates- as the linked article gives examples.
In my opinion, when you see this kind of inconsistent enforcement coupled with other avenues to accomplish the launch – and the FCC retaliating – there is something political going on. There is a lot of lobbying of the FCC and it’s quite apparent they are at a minimum inept or more likely corrupt.
https://spectrum.ieee.org/t…
It is just part of a typical government turf war. The head of the FCC wanted to be part of the NSC and be given control of space debris.
Thomas, I don’t see any evidence to support this claim. My sense is the reason the FCC Chair is not part of the NSpC is that the FCC is technically supposed to be an independent federal agency and is not part of the Cabinet like all the other NSpC members. The FCC still participates in the lower level interagency meetings and processes, as they always have.
The FCC has legal authorities given to it by Congress to regulate spectrum for satellites. If you want to blame anyone for a “fragmented” licensing process, blame Congress.
And this was not a snap decision made in the wake of SwarmSat. These draft NGSO rules have been in work for at least 18 months prior to Swarm being in the news.
After a few days’ thinking about that comment, I’m concluding that government agencies are duty bound to assess new territory when it appears, lest they be accused of malfeasance of one sort or another.
There’s a less forgiving view, I think, and perhaps one tempered by a certain anti-governmental predilection, that sees power-grabbing around every corner. And perhaps not entirely wrongly.
Just to be a pain about terminology, since I seem to be the one who always does so… I think you mean misfeasance, not malfeasance. The former is about a public official failing to do his job (e.g. due to laziness or incompetence) while the later is about a public official using his authority in an inappropriate manner (e.g. imposing a regulation which benefits a personal friend.)
This is what happens under incompetent governments. In November we must start cleaning House and Senate.
While I agree with you, wholeheartedly, it’s easy to see the frustration on the part of the other side.
The author of this op-ed is wrong. The new proposed NGSO license is for constellations of commercial smallsats that did not fit into any of the existing license categories. All of the existing educational cubesats were able to get FCC licenses via the amateur or experimental process, and those processes remain unchanged.
It’s not just the author of the op-ed. It is a number of professors from multiple universities, many with very active satellite programs. The question is whether the new rules will preclude licenses via the Part 5 experimental process that most universities currently use. Absent specific text permitting continued use by universities for Part 5 for small satellites, interpretation could be left to at whim decisions by regulators or the courts.
I was at a workshop about CubeSats earlier this week, and this subject came up. One speaker was promoting resource sharing by various CubeSat operators. Currently, it’s common for each operator to have their own ground station and only use it for the fraction of an hour per day their CubeSat is overhead. The speaker wanted to set up a network where a couple dozen operators could share stations and get a much greater amount of coverage. Licensing came up because this might not be allowed under an amateur license. It was an international meeting, so I’m not sure what applies to which country, but someone (from France) mentioned a requirement for the operator to be within 50 meters of the transmitting antenna. The speaker said that was not true for a commercial license, and he (or his company) could help with the paperwork for that. I suppose this new licensing scheme would make that far more expensive.
Hmm. Maybe we envision something different?
My amateur radio license, Advanced Class, allows me to work any ham satellite; and lots of others are doing the same thing, at the same time.
I’m not sure what’s needed for a ‘ground station’ in this context. These days, very advanced radios that operate in the appropriate spectrum are quite inexpensive and have stunning performance. And given the frequencies, antennas are (relatively) simple to make, or adapt from other services.
The rule about being close to the transmitter is a fact and easily defensible. But FCC is very up to date on stuff like this. For instance, for decades we’ve had remote repeaters all around the country; with certain safeguards they are operated by anyone wit the right gear. Most of these are VHF (2M and up); but a few are on 10M FM, giving world-wide coverage under the right conditions. What’s the difference between a repeater on a mountain, or tall building, and one on orbit? (Answer: the one on orbit is a bitch to snag).
I don’t find links that show the kinds of data that are transmitted, the frequencies, or modulation they use (some kind of FSK or similar I imagine, or even a packet-kind of system?)
I’m afraid I’m not enough of a telecommunications person to really answer that. But the spec sheets for a common CubeSat radio says FSK/GMSK and 130 to 450 MHz. I also know packetized data is relatively common.
As far as ground stations goes, no, they don’t involve all that much compared the ones supporting larger (or planetary) spacecraft. But it’s more than just using the CubeSat as a relay. It’s sending up commands (e.g. stop relaying and start transmitting engineering diagnostics, or point the camera at the fire in southern California) and receiving data (e.g. the images of that fire.) I guess that’s the distinction between using the spacecraft as a relay and operating it.
Good points. I was this that CubeSats are relating “dumb” in the sense that they chiefly find Earth and then send sensor data at programmed times autonomously. An over simplification no doubt.
Talking to a bird in LEO is dead simple, especially if hundreds of others arent overloading the front end at the same time! But Mars-bound?!
Just some fun wondering : I suppose Doppler is a simpler calculation. I wonder wha sort of gain is needed on the earth station antenna. And what sort of pointing accuracy? Maybe a satellite traveling to Mars presents essentially a single point target, at least for short term.
Fun! And here is some wild speculation: I bet it’s suitable station could be assembled for less than $10,000 in and some scavenging and some elbow grease. Maybe less. Maybe a lot less.
Or, I could be completely wrong! But what a fun project
The expensive part is the dish and positioner. A 3m dish and positioner to point to a fraction of a degree is a $50k kind of thing.
The electronics, yeah, $10k is in the ballpark.
Except in educational settings (a class building a first spacecraft), modern cubesats are MUCH more sophisticated in terms of sensors and operations than can easily be supported by a low rate UHF link. They *are* comparable to planetary spacecraft, except usually, it’s just one sensor – not a platform with dozens.
The cubesat world is moving away from 9600 bps GMSK (G3RUH) sorts of modems and from UHF – there’s just not enough spectrum. S-band (2 GHz) is also difficult to get spectrum approval for, since it’s heavily used, and shared with other services.
There’s also a need for much higher rates – 9600 bps is *barely* adequate for uplink commanding, and doesn’t allow for inflight software uploads. 100kbps is better, but Mbps would be best. And downlink rates need to be well into the Mbps, if not Gbps. You’re just not going to run a 10 Mbps downlink in UHF, and probably not in S-band either
There is a lot of X-band infrastructure (8.2-8.4 GHz downlinks) in the Earth Exploration allocation, and components for radios are readily available and inexpensive. But spectrum is precious there as well.
So there’s interest in moving up to Ka-band (32-35 GHz) where there’s plenty of spectrum. The problem is that components, and more particularly test equipment, are more expensive. A small “radio company” can develop UHF and S-band radios with inexpensive test equipment and eval boards from the mfr (many current cube-sat radios are basically the eval board design with a different interface and package). When you get above 18GHz, everything gets more expensive.
As for modulation – various forms of PSK at megabit rates using Turbo or LDPC coding. DVB-S2 is popular, since there’s a lot of receivers available off the shelf.
Cassini did multiple flight software updates at a range of over 9 AU and an uplink rate under 1000 bps. 9600 bps should be plenty for a CubeSat. Downlink is a different matter. But if 9600 bps isn’t enough for a full flight software update, I suspect someone isn’t making efficient use of those bits.
In the battle of Greed vs Education, greed will win every time. What exactly is the “government” doing with those fees? They need to show and trace every dollar acquired and then spent (and by whom), and there will be many questions and possibly waste if not even blatant corruption. Or dont collect fees at all.
Well, in the case of radio frequencies, the FCC does an incredibly good job of keeping the airwaves a sane place. And with fees that are minuscule.
Selling off spectrum, on the other hand, was one dumb move by Congress, but that’s another story.
Part of the difficulty is that all government departments are being encouraged to stop asking for tax dollars (taxes=bad) and instead support entire government agencies through user fees (user fees=good). The problem is even worse at FDA. Why do you think drug prices are so high? You can’t even call it corruption, because it is legal. He who pays the piper calls the tune. If the taxpayers are not willing to pay the regulatory agencies, someone else will, but they won’t be responsible to us.
Do you have a source? Your statement says that DoD, NASA, DOE, etc (“all government departments”) are included and that is not possible. Can you correct your comment?
Just because the lobbyists and gov regulators are so easily bought off under the guise of altruistic Orwellian double speak and even “legal” because they influenced the law making it legal still doesn’t mean it’s not corrupt. It might not be illegal corruption because the lobbying influenced the law making. Unfortunately i’ve Been privy to many meetings with various gov agencies in the small sat area. I’ve even led the negotiations of small sat international agreements thru the state department and various gov agencies and contractors. Suffice it to say their are many factions with their own agendas using the laws and using the fcc to exert power, control, and financial benefits to their agenda. Of course the agenda is hidden through Orwellian altruistic double speak. Just because many in the gov agencies are easily bought off and it’s cloaked in altruistic sounding language doesn’t mean it’s not corrupt.
The fcc retaliation tactics agains organizations using other legal means is most telling. The fcc is being used as an avenue for power/money/control. The fcc otherwise would seek to advocate the legal aspects rather than retaliate against law abiding other means. The real agenda is to shut down certain universities and gov agencies and small companies doing innovative small sat research that not under the control of certain other gov factions and organizations while allowing other favored organizations to pursue it. Like many gov agencies, the fcc selectively picks and chooses who they want to pick on for not following all the laws while others don’t have to comply. The fcc goes so far as to even pick on certain organizations who simply get connected to other legal means to launch their small sat. The laws are simply being used as a means to restrict and control competition by selective enforcement and passing inconsistent laws on purpose.
A similar thing occurs in the adaptive optics commute tried using the intelligence community and national secrecy laws to control who got funded for certain research. Unfortunately it wasn’t always the best and brightest who were the chosen ones. The result was foreign countries who can fund their best and brightest, if they want, did an end run. Then the adaptive optics area was opened up to allowing the best and brightest in America to do the research they were blocked from. That led to companies going so far as to refuse gov research to avoid bring controlled like this. Hughes Medical is one such example. Crony capitalism like this can have devestating effects on national security in the long run. This backdoor small sat control through the fcc likewise will similarly have adverse effect on the United States R&D. This isn’t merely incompetence or turf battles.