ARLA/CLUSTER: ARRL alerta para a existência de satélites de não amadores nas bandas de amador

[João Costa > CT1FBF]

 ARRL urges regulatory regime to keep non-amateur satellites off amateur
spectrum

ARRL wants the FCC to facilitate bona fide Amateur Satellite
experimentation by educational institutions under Part 97 Amateur Service
rules, while precluding the exploitation of amateur spectrum by commercial,
small-satellite users authorized under Part 5 Experimental rules.

In comments filed on July 9 in an FCC proceeding to streamline licensing
procedures for small satellites, ARRL suggested that the FCC adopt a
"bright line test" to define and distinguish satellites that should be
permitted to operate under Amateur-Satellite rules, as opposed to
non-amateur satellites that could be authorized under Part 5 Experimental
rules.

"Specifically, it is possible to clarify which types of satellite
operations are properly considered amateur experiments conducted pursuant
to a Part 97 Amateur Radio license, and [those] which should be considered
experimental, non-amateur facilities, properly authorized by a Part 5
authorization."

ARRL said it views as "incorrect and overly strict" the standard the FCC
has applied since 2013 to define what constitutes an Amateur Satellite,
forcing academic projects that once would have been operated in the Amateur
Satellite Service to apply for a Part 5 Experimental authorization instead.
This approach was based, ARRL said, on "the false rational" that a
satellite launched by an educational institution must be "non-amateur"
because instructors were being compensated and would thus have a "pecuniary
interest" in the satellite project. ARRL said well-established Commission
jurisprudence contradicts this view.

ARRL told the FCC that justification exists to expand the category of
satellite experiments conducted under an Amateur Radio license, "especially
those in which a college, university, or secondary school teacher is a
sponsor." But, ARRL continued, a compelling need exists to discourage Part
5 Experimental authorizations for satellites intended to operate in amateur
allocations by non-amateur sponsors, "absent compelling showings of need."

"There is no doubt but that Amateur Radio should be protected against
exploitation by commercial entities, and there should be a compelling
justification for a Part 5 Experimental license issued for a satellite
experiment to be conducted in amateur spectrum,"

ARRL said. "A defining criterion for this latter category should be that
there is no other spectrum practically available in lieu of Amateur Radio
allocations."

ARRL noted that International Amateur Radio Union (IARU) policy regarding
satellites operated in Amateur Radio spectrum is only to coordinate
satellites where licensees and control operators are radio amateurs and
having a "mission and operation" consistent with the International
Telecommunication Union (ITU) Radio Regulations' definitions of the Amateur
and Amateur-Satellite services.

Resolution 659, adopted at World Radiocommunication Conference (WRC) 2015,
included protective language against non-amateur satellites operating in
Amateur-Satellite spectrum, and the exclusion of any amateur bands from
spectrum that might be considered at a future WRC for allocation to the
Space Operation Service.

IARU announced in 2017 that it would no longer coordinate non-amateur
satellite operations and adopted new satellite frequency coordination
guidelines. Under that policy, educational and university satellites may be
coordinated only when an identified amateur component exists, and the
mission is to teach and train students in satellite communication and
building and launching satellites. The individual responsible for the
satellite's communications must be an Amateur Radio licensee. IARU will
also continue to coordinate space stations operating under an amateur
license and having "a clear amateur mission," as well as satellites where a
licensing administration directs the use of an amateur band.

ARRL asserted that incorporating Amateur Radio in experiential learning
using small satellites - e.g., CubeSats - is good for Amateur Radio, for
students, and for the advancement of technology, and it urged the FCC to
adopt a regulatory paradigm that encourages this approach.

AMSAT-NA also filed comments in the proceeding. The AMSAT remarks reflect
several of the same concerns expressed by ARRL, including the suitability
of authorizing certain satellites built by universities and non-profit
organizations in the Amateur Satellite Service, and expressing opposition
to satellites licensed as experimental under FCC Part 5 rules operating in
the Amateur Satellite bands. Interested parties may file reply comments in
the proceeding, IB Docket No. 18-86, by August 7, 2018.

The American Radio Relay League <http://www.arrl.org/>
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