ISAM Operators Likely to Seek Spectrum, Part 25 Rules Changes From FCC
If the FCC asks the in-space servicing, assembly and manufacturing (ISAM) universe about how to help it along, the agency should expect to hear about spectrum needs and suggested Part 25 rules changes, space operators told us. The space industry expects an ISAM notice of inquiry and a draft order for opening the 17 GHz band to geostationary orbit (GSO) fixed satellite service downlinks (see 2207150063) to be readily adopted at the FCC commissioners' August meeting Friday.
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Space Logistics' first-generation mission extension vehicles use the C and Ku bands for their telemetry, tracking and control operations, and clients of those MEVs use those bands as well, so once docked the MEVs operate within the customers' spectrum. But the second-generation emission extension pods Space Logistics is working on now might go among multiple clients' satellites in a given year, making it tougher for them to operate on the same spectrum as the clients, said Joseph Anderson, vice president-operations and business development for the Northrop Grumman subsidiary. All that points to the need for a spectrum allocation for docking services, he said.
Anderson said FCC rules should allow or even encourage use of servicing when there's an operational anomaly. He said the commission should consider MEVs as an alternative to requiring satellite operators to have adequate fuel reserves when decommissioning a satellite.
Sections of the agency's Part 25 rules, which govern GSO and non-geostationary orbit satellite systems, "don't really work" with ISAM missions, said Astroscale regulatory lawyer Laura Cummings. The FCC's Part 25 rules assume something being either GSO or NGSO, but ISAM missions could change from one to the other, she said, citing a hypothetical Astroscale Life Extension In-Orbit vehicle moving a satellite from NGSO to GSO orbit and then doing station keeping. The FCC's evaluation of orbital debris mitigation plans also doesn't square neatly with ISAM missions, so there are questions about how to best evaluate risk, she said.
About 20 ISAM missions have been approved by the FCC or are pending, most of them noncommercial, receiving special temporary authority licensing, Cummings said. Many more applications will be coming, seeking Part 25 approval, she said. ISAM operations will likely play a notable role in NASA's lunar Artemis program, making more clarity about the rules and procedures for licensing that architecture imperative, she said.
The FCC ISAM NOI follows the White House's Office of Science and Technology Policy's release of an ISAM strategy in April. That strategy set a series of strategic goals, including pushing ISAM R&D, accelerating commercial ISAM and promoting international collaboration and cooperation toward ISAM goals. The strategy also identified a set of hurdles facing ISAM: the need for better coordination and collaboration with the U.S. government and among the government academia, industry and international partners; the need for "a clear and consistent demand signal" that would stimulate investment, mitigate risk and address investor confidence; and creation of ISAM standards to help promote growth. The FCC was part of an OSTP interagency working group that devised the strategy.
FCC opening the 17 GHz band would go with broader satellite industry efforts overall, a satellite company lawyer told us, noting 2023 World Radiocommunication Conference agenda item 1.19 on making the 17.3-17.7 GHz band available in Region 2, which covers the Americas. The lawyer said there's sizable GSO interest in the band. CTIA, which opposed the proposed allocation, didn't comment.
Amazon lobbied for also opening the 17 GHz band to NGSOs, in a meeting with Commissioner Nathan Simington, per a docket 20-330 ex parte filing Monday. That allocation of satellite service would promote more efficient spectrum use, line up with FCC practice and precedent in other frequency bands and "ensure consistency" with the WRC-23 item the U.S. backs, Amazon said.