[Ground-station] FCC NPRM on Satellites

Bruce Perens bruce at perens.com
Wed May 2 22:19:43 PDT 2018


I'll be writing a comment on the FCC NPRM on satellites.
https://transition.fcc.gov/Daily_Releases/Daily_Business/2018/db0417/FCC-18-44A1.pdf
Major points (so far) are:

Fees being asked for Part 25 licenses are willing to push universities into
the Amateur Service. This could endanger us (we don't want the same fees,
$100,000 per year, which are supposedly for satellite debris management as
part of licensing, and we don't want amateur-run satellite efforts to be
pushed out of our spectrum by the university ones) and this means we will
be building partnerships with universities as they may need us to license
and operate their satellites.

We need a better definition of what should / should not be in the Amateur
Satellite Service. It's clear that the experiment should be disclosed and
the data copyable by hams. I would also push for a quid-pro-quo in that
universities include a benefit to hams in general such as a repeater that
can be activated during or after their mission.

ITU/FCC/IARU are currently interpreting the ITU definition of the Amateur
service being without pecuniary interest meaning that salaried staff can
not be satellite licensees or operators. At the same time, there will be
increased pressure on us to do emergency maneuvers and to be able to cut
off transmitters on short notice. IMO, a 501(c)3 like ORI should be able to
carry out its charitable activities using employees, just as W1AW has a
paid operator. Ultimately we will need to bring this up with ITU.

-- 
Bruce Perens K6BP - CEO, Legal Engineering
Standards committee chair, license review committee member, co-founder,
Open Source Initiative
President, Open Research Institute
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