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FCC EYING NEW POLICY ON DE-ORBITING SATELLITES

FCC could issue Notice of Proposed Rulemaking (NPRM) leading to policy on satellite de-orbiting “in the next month,” said Karl Kensinger, special adviser in International Bureau’s Satellite Div. Commission earlier looked at de- orbiting objectives in 2 GHz processing rounds in Aug. when it issued 8 Mobile Satellite Services (MSS) licenses in 2 GHz spectrum, and still is working on that plan, he told us: “It’s good when U.S.-licensed systems are doing the best they can and are at the forefront of international practice… There are some ambiguities in what the best practices should be, but some sort of disposal process is appropriate.”

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There’s “no magic number” that Commission has linked to distance out-of-service satellite would have to travel outside its in-service orbit, although recommendations by organizations such as NASA, ITU and Inter-Agency Space Debris Coordination Committee (IADC) “deserve consideration,” Kensinger said: “I don’t think we're wedded to any particular number.” Distance may be determined on case-by- case basis, depending on characteristic of spacecraft, he said. In some instances, de-orbiting maneuver could be dangerous and could even result in explosion, he said. “In a trouble-free world, it would be sensible to target a specific number,” he said. People need to exercise sense and remember what ultimate goal is, Kensinger said: “We don’t want to pursue something that is counterproductive.”

NASA’s safety standards indicate that historical practice of abandoning spacecraft and upper stages at end of mission life has allowed roughly 2 million kg of debris to accumulate in orbit. If practice continues, NASA said, collisions between those objects would, within next 50 years, become major source of small debris, “posing a threat to space operations that is virtually impossible to control.” There are regions of space where, for immediate future, disposal of systems could be made without creating significant risk to future users, standards say. Low Earth orbit (LEO) systems such as Iridium, Orbcomm and Globalstar and proposed Teledesic network don’t represent unique debris problems, NASA said. Many LEO systems are being deployed in ways designed to minimize orbital debris generation and often upper stages and spacecraft are or will be placed in lower altitude orbits after their missions have been completed to accelerate their fall back to Earth. NASA lists its postmission disposal options as: (1) Direct retrieval and deorbit. (2) Maneuver to orbit for which atmospheric drag will remove structure within 25 years. (3) Maneuver to one of set of disposal regions in which structures won’t interfere with future space operations.

Current policy of self-policing is working for industry, Satellite Industry Assn. Pres. Richard Dalbello said. There have been no collisions to date, and all companies in industry have developed plans for “graveyard orbits” that work, he said: “We don’t want excessive regulation… U.S. industry has an excellent de-orbit history.” Many U.S. companies operating GEO satellites already adhere to about same standard (300 km above geosynchronous orbit) as do govt. and NASA, Dalbello said: “It’s not standard in the industry… Some are at 300 km and some are less.” PanAmSat is “broadly in the same group as everyone else,” spokesman said. Commercial satellite operators have important need to make sure satellites are de-orbited properly, but govt.’s arbitrarily picking number “isn’t the best way to go,” he said. Spokesman also said problem was more at international level than it was with U.S. companies.

International agencies are focusing attention on debris mitigation and implementing policies. Any company from abroad seeking a license to operate in U.S. would be “in same position as any U.S. licensee,” Kensinger said.

Life span of satellites could be shortened if new FCC policy extended distance that satellite must move during de- orbit process beyond current industry norms, according to industry sources. Same thrusters that maintain satellite’s position in its assigned slot are used to de-orbit, and moving greater distances means using more fuel. Dalbello said it was difficult for SIA to take stance on Bureau’s potential new policies because he “doesn’t know where they're going with it.” Still, Kensinger insisted Commission wasn’t necessarily thinking about any particular distance standard, but was willing to listen to what industry had to say. “[The FCC] will let [the satellite industry] disclose what it is planning to do… and then we'll go from there,” he said. In 2 GHz proceeding, Kensinger said, one of the 2 GEO satellites in orbit told Commission it would “clear geostationary orbit by 100 km on all sides” at end of satellite’s life, and other didn’t indicate any distance, Kensinger said. In each instance, FCC simply asked companies for additional information, he said.

Issue of debris mitigation arose because Iridium didn’t de-orbit its satellites after it went bankrupt, and FCC was afraid of facing that issue again, industry attorney said: “That was a unique situation… so [the FCC] wants to be careful about overreacting. [De-orbiting] has never been an issue before.” FCC did learn “a bit” about debris mitigation issues as result of Iridium bankruptcy and did consider decommissioning company’s entire satellite constellation, Kensinger said: “Those events focused our attention” on issue.

Steps are being taken now are to ensure there’s not serious problem in 100 years and beyond, Kensinger said. Debris has accumulated in orbit since people started putting things into space, he said, but current risks still are “extremely low.” He said “practices today make it reasonably likely that it will continue to be the case for a very long time.”