[Ground-station] Draft text for FCC comment, on the minimum satellite size issue

Bruce Perens bruce at perens.com
Sun Jun 17 13:29:07 EDT 2018

 1 Minimum Allowed Size of Small Satellites


   We suspect that many of the commenters will not understand why NORAD can
   catalog astonishingly tiny debris, including what may be a wire-tie dropped
   by a spacewalking astronaut (1998-67NS [43498]), while FCC must insist on
   a much larger minimum size for small satellites. However, there is an
   excellent reason.


   For the security of North America, it is essential that foreign powers
   remain unaware of fine details of the capability of NORAD, the United
   States, and Canada to track small or *unreflective* objects in orbit.
   “Stealth”, technology for reducing radar reflections, allows larger objects
   to given the radar-reflective profiles of un-stealthed smaller ones. The
   minimum radar-reflective profile capable of being tracked by NORAD should
   remain unknown. Thus, no object should be licensed for launch if its
   radar-reflective profile in any orientation is close – within a classified
   amount - to the minimum tracking capability of NORAD, the U.S., or Canada.
   We suspect that the 100mm2 standard minimum cubesat size far exceeds
   this minimum capability, perhaps by an order of magnitude. As technical
   capabilities improve, the minimum licensable size should be reduced,
   however the size allowed must always be some classified amount larger than
   the actual minimum radar profile that can be reliably tracked.

   That said, ORI is interested in launching constellations of many very
   small satellites into LEO, where their orbits would decay to re-entry
   within a few years and they could not be expected to be a long-term
   collision hazard. We urge FCC to allow licensing of such things as soon
   as this is possible within the constraints of national and North American

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
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