[Ground-station] FCC Small-Satellite NPRM

Zach Leffke zleffke at vt.edu
Fri Jun 15 19:23:26 EDT 2018


SPACEBEE-1
1 43142U 18004AH  18166.15327463  .00002710  00000-0  11662-3 0  9999
2 43142  97.5349 228.9583 0011111 108.5240 251.7204 15.23458854 23400
SPACEBEE-2
1 43141U 18004AG  18165.89385312  .00002518  00000-0  10875-3 0  9996
2 43141  97.5348 228.6883 0011116 109.0700 251.1741 15.23396885 23371
SPACEBEE-3
1 43140U 18004AF  18165.89660685  .00002409  00000-0  10436-3 0  9996
2 43140  97.5347 228.6832 0011129 108.9142 251.3301 15.23343657 23378
SPACEBEE-4
1 43139U 18004AE  18166.16700625  .00001921  00000-0  84210-4 0  9994
2 43139  97.5347 228.9332 0011117 107.4719 252.7733 15.23190279 23403

TLE source:  Celestrak.com, also on N2YO's webpage.

Not trying to be argumentative here, truly am confused about whats going 
on.....hoping someone in the know can school me.

To me it appears they are reliably tracking all four individually.  
Epochs updated yesterday/today (if I did the Julian conversion right), 
and I've been loosely following this and have never seen 'stale' 
updates.  These TLEs (NORAD IDs) were in the catalog very early in the 
post launch deployment (within first two weeks for sure, I have a TLE 
matching project based off Doppler curves, done for Fox-1D that was on 
the same vehicle, and have the early TLEs saved off on github and the 
individual spacebees are in there!).   This implies that they were 
quickly resolved in the sea of 30+ satellites deployed in 300 seconds 
(or there about).

Not saying they should have been launched without their licensing in 
place, but clearly (to me, could be wrong here) the original grounds for 
the FCC denial was flat out wrong, like Howie said.

So maybe their response would be "sure, we can track /four/....". OK, 
well......what's your upper limit?  A denial of 'sorry we can only 
routinely track 20, and there are currently 20 up there, so you have to 
wait for the technology to improve or something to decay' would really 
suck, but at least it would be clear.........

My take on this issue is that if there is a minimum size requirement 
(maybe orbital altitude is a factor as well here, so maybe 'desired 
altitude + size requirement') from FCC/JSpOC/NASA/Whoever, that is not 
clearly stated in any application requirements, so how were they (or 
anyone else for that matter) to know that would be an issue in the first 
place. We have an interest in the ThinSat design at VT.  We are 
launching ThinSat derived designs on a suborbital sounding rocket very 
soon (not an issue for orbit tracking, but that program is supposed to 
be traceable to orbital spaceflight), I know that a High School in 
Southwest VA is launching some very soon (they got approval), though 
they will be VERY low altitude (one - two week lifetime) and we have 
recently started a possible collaboration with VMI who is intending to 
launch some in the next year or so (haven't begun filing 
process).........so what is the requirement?


So what is the technical challenge here?  I understand that higher 
frequency radars (Ka band I think?) are needed to track these smaller 
objects, and that there are fewer of those.  But the TLEs keep getting 
updated......so is this a question of scheduling and because this is a 
hot topic they have bumped them up in the priority queue?  Is some piece 
of Iridium 33 / COSMOS 2251 not being tracked to make room for these 
guys and they are worried about over burdening the radars?  Again, 
understandable.......but they are not being clear and consistent in the 
requirement, which just causes more confusion......


Again, not trying to defend the company who went against FCC decisions, 
but the fundamental grounds for the denial is at best incomplete, at 
worst, just straight up wrong......


-Zach, KJ4QLP


Research Associate
Aerospace Systems Lab
Ted & Karyn Hume Center for National Security & Technology
Virginia Polytechnic Institute & State University
Work Phone: 540-231-4174
Cell Phone: 540-808-6305

On 6/15/2018 6:21 PM, Bruce Perens via Ground-Station wrote:
> I will note that, but I suspect their answer is going to be "sure, we 
> can track /one"./
> /
> /
> //Thanks
>
>     Bruce
>
> On Fri, Jun 15, 2018 at 12:53 PM, Howie DeFelice 
> <howied231 at hotmail.com <mailto:howied231 at hotmail.com>> wrote:
>
>     The FCC statement about "Trackability" and that Jspoc cannot
>     routinely track objects smaller than 10cm is just not true. $50sat
>     (aka Eagle2) was launched in 2013 into a 700 km sun synchronous
>     orbit. The dimensions of that satellite were 5cm x 5cm x 7.5 cm
>     and updates from Jspoc were routinely published until the
>     satellite re-entered a few weeks ago. This is the satellite
>     referred to in note 25 of the NPRM, comment by Alba Orbital.
>
>       * Howie AB2s
>
>     ------------------------------------------------------------------------
>     *From:* Ground-Station
>     <ground-station-bounces at lists.openresearch.institute> on behalf of
>     Bruce Perens via Ground-Station
>     <ground-station at lists.openresearch.institute>
>     *Sent:* Friday, June 15, 2018 1:20 PM
>     *To:* Michelle Thompson via Ground-Station
>     *Subject:* Re: [Ground-station] FCC Small-Satellite NPRM
>     The Federal Register Information:
>     https://www.federalregister.gov/documents/2018/05/24/2018-10943/streamlining-licensing-procedures-for-small-satellites
>     <https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.federalregister.gov%2Fdocuments%2F2018%2F05%2F24%2F2018-10943%2Fstreamlining-licensing-procedures-for-small-satellites&data=02%7C01%7C%7Cf058b587db7d41bcfbe008d5d2e48724%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636646801311962375&sdata=7DZGLdDMhmsYMCnA5jCAh%2FH8DWnQM6STgH4F5EUJ3YA%3D&reserved=0>
>
>
>     The FCC's document:
>     https://transition.fcc.gov/Daily_Releases/Daily_Business/2018/db0417/FCC-18-44A1.pdf
>     <https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Ftransition.fcc.gov%2FDaily_Releases%2FDaily_Business%2F2018%2Fdb0417%2FFCC-18-44A1.pdf&data=02%7C01%7C%7Cf058b587db7d41bcfbe008d5d2e48724%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636646801311962375&sdata=540n1u7OPvsoGb%2FciS7kQgo%2BnTG2SU2hgyVRAbSqLx4%3D&reserved=0>
>
>     On Fri, Jun 15, 2018 at 10:11 AM, Bruce Perens <bruce at perens.com
>     <mailto:bruce at perens.com>> wrote:
>
>         It says in the Federal Register that we have until July 9 to
>         submit our comment in the small-satellite NPRM. I'm starting
>         to write now. Please send your ideas my way.
>
>             Thanks
>
>             Bruce
>
>         -- 
>         Bruce Perens K6BP - CEO, Legal Engineering
>         Standards committee chair, license review committee member,
>         co-founder, Open Source Initiative
>         President, Open Research Institute; Board Member, Fashion
>         Freedom Initiative.
>
>
>
>
>     -- 
>     Bruce Perens K6BP - CEO, Legal Engineering
>     Standards committee chair, license review committee member,
>     co-founder, Open Source Initiative
>     President, Open Research Institute; Board Member, Fashion Freedom
>     Initiative.
>
>
>
>
> -- 
> Bruce Perens K6BP - CEO, Legal Engineering
> Standards committee chair, license review committee member, 
> co-founder, Open Source Initiative
> President, Open Research Institute; Board Member, Fashion Freedom 
> Initiative.
>
>
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> Ground-Station at lists.openresearch.institute
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