ISAM Interests: FCC Should Consider Blanket Licensing for Nascent Industry

Pointing to the NPRM seeming to advocate needing FCC review and approval of each discrete servicing activity, the Consortium for Execution of Rendezvous and Servicing Operations said that could create significant burdens for industry. Instead, it said the FCC should create an ISAM process that authorizes spectrum use for an array of activities complying with certain bounds. Also advocating for a suite-of-activities licensing regime, Lockheed Martin said such blanket authorization would let commercial ISAM operators perform any activity that falls within a defined scope. Backing a single blanket license, the Aerospace Industries Association said the FCC could receive notification of additional client satellites when they are added. It said a full modification of an ISAM license should be needed only if a proposed servicing activity goes beyond the operating parameters of the existing ISAM license, such as using frequency bands not previously authorized.

While it's fine to require ISAM operators to notify the FCC of client space stations that will be serviced, the agency must allow that notification after the ISAM mission launches, said Turion Space. It said most ISAM satellites will have a lifespan of three or more years and are available during that time to service multiple satellites. Meanwhile, ISAM operators might have just several days' notice about the client satellite they will service, it said. Astroscale also backed letting one ISAM application cover multiple orbits and satellites, reflecting that servicing providers might want to authorize multiple geostationary orbit servicing vehicles simultaneously, or one GSO satellite to conduct multiple servicing activities at specified orbital locations.

TechFreedom disputed whether the FCC can regulate noncommunications activities in outer space. It said the commission should focus on frequency interference regulations that would benefit ISAM activities by making all space service spectrum available for ISAM, and look at ways non-space frequencies could be used for ISAM without raising concerns about terrestrial interference. Similarly, SpaceX said the FCC should adhere to its statutory authority and apply its licensing framework to radio equipment supporting ISAM activities, rather than trying to license the underlying spacecraft conducting the ISAM activities. Letting ISAM missions use an extended selection of spectrum bands, including unlicensed, would quicken ISAM deployment through readily available, off-the-shelf equipment, it said. It also urged a shot clock for processing ISAM applications. Astroscale urged an allocation for primary fixed satellite service in the 7.125-8.4 GHz band for ISAM.

The best way the FCC can nurture the nascent ISAM industry is through streamlining and simplifying licensing processes and ensuring sufficient spectrum for the commercial space industry as it grows, the Commercial Spaceflight Federation said. It said it "remains concerned" that the FCC’s read of its statutory authority "is overly broad and distracts from the FCC’s core spectrum-licensing responsibilities."

The FCC doesn't need to create an entire ISAM application category when it can make the same improvements by exceptions or conditions added to its Part 25 satellite license framework, Blue Origin said. Many ISAM missions' spectrum use will look more like earth exploration satellite service, and the FCC should "think broadly about the services in which ISAM operations could be licensed if it truly desires to facilitate developments," said Varda Space Industries. Urging the FCC to speed up efforts to ID spectrum for ISAM missions, Varda said increased ISAM spectrum demand "inevitably will increase pressure on bands allocated for other uses."

Warning that the FCC proposal could inadvertently also cover upper-stage launch vehicles, United Launch Alliance said they should be explicitly excluded. Habitable space station company Sierra Space said the multipurpose nature of those space stations could exclude them from the NPRM's ISAM definition, and the agency should make sure the definition is broad enough that it covers all intended activities.