Dedicating Spectrum for ISAM Sees Resistance
Any spectrum allocation for in-space servicing, assembly and manufacturing (ISAM) operations won't happen without a fight. Numerous space operators and other spectrum interests pushed back in docket 22-271 reply comments this week against any ISAM-specific spectrum allocation. Space operators also disagreed on how far the FCC's authority reaches when it comes to ISAM regulations that don't deal with radiofrequency issues. The FCC's authority was also questioned in initial comments in the ISAM licensing NPRM (see 2404290039).
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Not allocating dedicated spectrum for ISAM communications will undermine the long-term competitiveness of the U.S. ISAM industry, Astroscale said. Also calling for the FCC to move toward dedication of spectrum for ISAM, ClearSpace Today said spectrum license approvals on a case-by-case basis would suffice for now, but longer term fostering of the ISAM sector requires dedicated spectrum. It said sharing is a challenge due to the variable bandwidth requirements of ISAM missions as well as the need for sustained real-time communication during periods of missions.
Numerous operators argued otherwise. Intelsat said specific frequency allocations aren't needed yet. It said if the FCC takes this route, a separate record would be needed, and that any allocations shouldn't come at the cost "of the already-congested frequency bands currently available for the fixed-satellite service." ISAM activities should be able to use a wide array of existing allocations to complete their missions, SpaceX said. Allowing operators to access spectrum for ISAM use across different service allocations would help ensure ISAM space station design and development isn't blocked or delayed by the slow-moving process for establishing allocations internationally, it said.
ISAM-dedicated spectrum should not come from the 7.125-8.4 GHz band, CTIA said. The band is being studied globally for terrestrial wireless broadband, and looking at it for ISAM would undermine the national spectrum strategy's assessment of the 7/8 GHz band and impede studying the band at the 2027 World Radiocommunication Conference, it said. The National Academy of Sciences' Committee on Radio Frequencies urged the FCC to avoid looking at frequencies allocated to earth remote sensing services in the name of protecting research and operations tied to weather prediction and climate studies.
Viasat defended the FCC's authority to license and regulate ISAM operations. Arguments that the FCC can oversee only ISAM's radiofrequency operations "reflect an incomplete and inaccurate understanding of the Commission’s authority" and ignore how the agency's public interest mandate also lets it regulate the operation of physical facilities, it said. SpaceX said the proceeding, to remain within the FCC's authority, should be narrowed to spectrum and radio equipment licensing for ISAM activities.
Iridium said the record supports applying existing orbital debris rules to ISAM operations and the agency taking a case-by-case approach for reviewing ISAM orbital debris plans. It said while some ISAM activities might fall outside current orbital debris rules, a case-by-case review would let the commission address those novel situations.