FCC's Role in Promoting ISAM Questioned
FCC efforts to foster nascent in-space servicing, assembly and manufacturing (ISAM) activities face a challenge because doing so falls outside the agency's job docket, said space operators and others Tuesday in docket 22-271. There also were multiple calls in the ISAM docket comments for identification of spectrum for ISAM activities. A number of commenters pushed for a licensing regime involving a license for a category of services, rather than trying to make emissions fit into the traditional non-geostationary or geostationary framework. The commissioners adopted its ISAM notice of inquiry in August (see 2208050023). Replies are due Nov. 28.
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The FCC's desire to promote U.S. ISAM leadership is commendable, but the agency will need more authority than it has now under the Communications Act, SpaceX said. "Congress did not intend for an agency with its expertise in communications to become the backstop authority for all commercial space activities simply because space stations must communicate," it said. SpaceX said the FCC instead should work with and support Commerce's Office of Space Commerce, which is the lead agency for ISAM activity. It said the FCC could be more flexible in its spectrum licensing to help ISAM activity, such as crafting licenses that allow satellite servicing missions to happen in different orbits and spectrum.
The FCC's role in the ISAM ecosystem "is far narrower" than the NOI portrays, TechFreedom said. It said the commission doesn't have the expertise to regulate operations in space, "and the FCC risks widespread discord if it proceeds without interagency coordination." It said the agency should look at allowing reuse in space on a noninterference basis spectrum currently licensed for terrestrial use.
The commission should be the lead agency specifically on ISAM communications and interoperability issues, but other agencies such as the FAA, Commerce and NASA will have roles in coming up with overall consistent and well-crafted ISAM policies, United Launch Alliance said.
The FCC's Part 25 rules are often a poor fit for ISAM missions, said Astroscale, with gaps including challenges in identifying what orbital regime to license in, unclear application of regulations on mutually exclusive applications and the inability to license multiple geostationary orbit servicers at one time. It urged the FCC to open an NPRM on ISAM regulations. OneWeb said the commission should review applications for deploying assisted disposal and removal and in-orbit servicing missions case by case under its existing rules while it gets more experience with ISAM missions.
There won't be a standardized approach for ISAM communications due to how the missions vary, so the FCC shouldn't bar ISAM missions from using any standard bands, said the Consortium for the Execution of Rendezvous and Servicing Operations. The agency should encourage development of an industry standard space-to-space proximity communications system, CONFERS said.
ISAM activities, including on the Moon, will require access to a variety of bands including routine use of the UHF, S, C, X and Ka bands, said Lockheed Martin. It urged the agency not to delay adjudication of pending applications for lunar communications services while undertaking a rulemaking on a communications architecture for lunar missions, but instead consider issuing licenses that are conditioned on compliance with future rules. Blue Origin said the FCC should allow nonfederal use of parts of the S band for commercial rendezvous and proximity operations missions. It sought allocations for ISAM missions, using spectrum that would allow at least 100 MHz of bandwidth. It said the agency should look at bands that would allow omnidirectional use at power levels that would allow initial connections at about 100 km. Those requirements rule out bands higher than the Ka or V bands, it said.
There needs to be study and analysis of additional spectrum bands that could be allocated to particular ISAM activities such as satellite servicing or aspects of ISAM activities as those services become more routine, said the Aerospace Industries Association. It also backed licensing ISAM missions under a single license that's updated with notifications for activities within the scope of the license, rather than requiring multiple licenses. It said the FCC shouldn't involve itself with reviewing planetary protection plans, but should support interagency discussions on the planetary protections process.
Citing its work with SpaceLogistics and that company's mission extension vehicles, Intelsat said letting SpaceLogistics' MEV-1 "piggyback" on the license of Intelsat 901 limited the regulatory fee liability for MEV-1 and let MEV-1 provide telemetry, tracking and control consistent with 901's licensed frequencies. That approach promotes operator-to-operator coordination for spectrum access for novel missions and helps make the economics of the life-extension mission work, it said. Citing worries about the threat of orbital debris re-entering the atmosphere, the Air Line Pilots Association urged the commission to require that any debris generated be small enough to burn up when falling back to earth or that controlled deorbits be over uninhabited ocean areas.