AMSAT has told the FCC that several proposed rule changes related to the mitigation of orbital debris would have an extremely detrimental effect on both the Amateur Satellite Service and AMSAT’s ability to launch and operate new satellites, including AMSAT’s upcoming GOLF satellites. AMSAT filed comments on April 5 on an FCC Notice of Proposed Rule Making (NPRM) in IB Docket 18-313. AMSAT argues that amateur satellites often have longer mission lifespans than other small satellites and that the FCC should take a mission duration of 5 to 10 years into account when determining whether or not an amateur satellite will meet the orbital debris regulations, either by transferring to a parking orbit or re-entering the atmosphere within 25 years of mission completion. Current practice is to assume a “zero-year” mission and to require that amateur satellites meet the debris regulations.
AMSAT also urged the Commission to consider alternatives to a proposed rule that would restrict to altitudes of 650 kilometers or less satellites in low-Earth orbit that plan to meet the orbital debris mitigation guidelines through atmospheric re-entry. AMSAT noted that, had this rule been in place, it would not have been permissible to deploy AO-85 and AO-91 in their current elliptical orbits with apogees of approximately 800 kilometers, even though both will re-enter within 25 years due to their low perigees.