The Federal Communications Commission has issued a Public Notice to help commercial space companies obtain use of communications frequencies for launch, operations, and reentry. Unfortunately, the FCC requirements don’t seem to meet the needs of high-rate launch operations that are expected in the near future.

Currently, commercial space operations use radio frequencies allocated exclusively for federal government use. The FCC can authorize use of those frequencies on a temporary, non-interference basis through its Experimental Authorization process. The Public Notice provides guidance on how to obtain an Experimental Authorization for communications associated with for commercial space operations, including spacecraft, ground stations, and ground-test facilities.

Experimental Authorizations are valid for a six-month period from the date of grant and are renewable. Applicants must obtain a new authorization for each launch and must apply 90 days in advance. It does not appear that the FCC has thought this through. This approach may work well for SpaceX cargo launches to the International Space Station, but it does not meet the needs of suborbital launch providers who expect to fly several times per day and schedule launches as needed, on very short notice. (Imagine what would happen if the airlines had to request a new radio license for each flight.)

FCC Chairman Julius Genachowski said, “Our actions today are designed to accelerate the growth of a new American industry with major growth potential, commercial space launches. Companies can’t launch or operate space vehicles without spectrum, and today the U.S. is leading the way in developing rules of the road for commercial space launches. Our measures to streamline processes and increase predictability will help boost U.S. leadership in the commercial space industry.”

Written by Astro1 on March 16th, 2013 , Commercial Space (General), Space Policy and Management

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COMMENTS
    Ed Wilson commented

    Who said it would be American?

    It goes to the one that gives what is needed. If the FCC screws the pooch, well perhaps it is the Brits or Auz.

    Ed

    Reply
    March 16, 2013 at 12:29 pm
      admin commented

      International law does not permit the Brits or Aussies to allocate US radio frequencies.

      Reply
      March 16, 2013 at 1:45 pm
    seriously? commented

    This is absolutely stupid. As if the FCC is into predicting the distant future and needs to accommodate all possibilities today. When is the time frame for several times a day – is this happening tomorrow, or in 3 days, or a month? Give me a break! This article makes this site look like an absolute joke.

    Reply
    March 16, 2013 at 4:26 pm
      admin commented

      We are not talking about the distant future. This will happen with the next 12-18 months.

      There are more things in heaven and earth, Horatio, than are dreamt of in your philosophy.

      Reply
      March 16, 2013 at 4:52 pm
      alex wilson commented

      you make a very valid point. if the people wishing to operate these supposed multi-times-a-day suborbital mission feel the proposed FCC rules too onerous, they can always make that point in their comments. complaining about interference to an operation that isn’t even operating goes well beyond ‘putting the cart before the horse’.

      Reply
      March 20, 2013 at 9:15 am
        admin commented

        So, you want the FCC to create rules that make rapid operations impossible? And no one is allowed to complain about the rules until rapid operations have begun? That’s called a “Catch 22″ situation.

        You and Joe still haven’t explained what your objection is. Do you think spacecraft radios will somehow interfere with your Ham radio, cause satellites to blow up, or… what? (None of those things are likely to happen for technical, as well as regulatory reasons.) What is it you’re afraid of?

        Reply
        March 20, 2013 at 12:06 pm
          Joe commented

          I’ll be quick. There’s two issues. Comms are clearly important – so important, at least portions of Industry hasn’t bothered to apply for spectrum allotment from the FCC, *or* looked at the issue globally to clear frequency space for tracking, telemetry, and earth-to-orbit communications in the more-than-a-decade in preparation for *all* these missions approaching in the next 12-18 months that are being claimed. When the FCC says, “That’s ok–we’ve got you covered: all you have to do is give us advanced notice and some information about the emissions you plan on doing, and we’ll roll you into the government’s freqs,” you complain that the FCC isn’t sensitive to your needs.

          On this point, the 5-P’s apply. The FCC *could* have told you to go pound sand, that you can’t transmit a thing unless and until you clear freqs through the normal regulatory processes–instead, they gave Industry an out until they can solve the cranial-anal inversion and get it right.

          The second issue is the presumptuousness of the sentiment being expressed, which seems to me to be, “Bollocks the Rules, we’re Commercial Space Flight.”

          It’s not just a “bunch of radio guys holding up progress” – it’s the processes that every other industry that utilizes spectrum has to go through, and so does the commercial space flight industry. You think NASA or the Military get special dispensation? –they don’t, and neither does Industry.

          ..you asked. :-)

          Reply
          March 20, 2013 at 1:58 pm
            admin commented

            Joe, it appears you are being deliberately obtuse, or else trolling.

            Insisting on 90-day notice for missions that might not be planned more than a day in advance is not saying “we’ve got you covered,” by any reasonable definition.

            No industry has to apply for a separate license for every mission 90 days in advance. Not aviation, not trucking, not shipping, not emergency services. No matter how many times you claim otherwise.

            Nor do NASA or the military. Do you think the Army plans every combat mission 90 days in advance? Seriously, Joe?

            No one is saying there should be no regulation. You’re setting up a strawman argument. We’re saying there should be reasonable regulation. Regulations similar to those that are already work for other industries, the military, NASA, etc. in the real world.

            You insist that regulations for commercial space should be much more burdensome than those for any other industry — or even your amateur radio hobby. Ham radio operators get a blanket license for operation on specified frequencies, at specified powers, etc., for a specified duration. They are not required to request a separate license for each transmission, 90 days in advance.

            Your attitude is not “we’ve got you covered” but “I’ve got mine, Jack.” You’ve got your Ham radio frequencies but, for some reason, you object to commercial space vehicles being allowed to use other frequencies under reasonable regulations that prevent them from interfering with your operations. You insist that commercial space companies should be forced to abide by rules that are far more restrictive than those for any other industry or even amateur radio operators who use radio spectrum purely for their own recreational purposes. And you won’t explain why.

            Once again, Joe, what are you afraid of? Do you think that commercial spacecraft will somehow interfere with Ham radios? Or damage or destroy satellites, as you previously stated? If so, explain how you think that would happen. What is the basis of your objection?

            March 20, 2013 at 3:06 pm
            Joe commented

            I’m afraid of nothing: I *welcome* Commercial Space to the airwaves.

            The difference you are missing is that taxi drivers, airlines, wireless telecom providers, amateur radio operators, terrestrial microwave, wifi device manufacturers, AM/FM/SW radio, the military, NASA, satellite providers, and *every* other spectrum user have *all*, without exception, gone through the process of getting spectrum allocations. Commercial Space Operations clearly has not. Each one of those industries is governed under rules set-up in conjunction with the FCC based on a balance between needs of the users and the requirements of the regulatory agency. So, for instance, there are requirements one must meet before being granted an FM Radio station license; those rules are different than the rules to buy a cell phone.

            At this point, *if* we’re reading this correctly (and, as I’ve pointed out before, I don’t believe we *are* reading this correctly at all), Commercial Space Operations doesn’t have a spectrum allocation. The rules that eventually come out of asking for (and ultimately receiving) a spectrum allocation are likely to look *vastly* different than the terms of the Experimental Grant–specifically because Industry can advocate for their users, and negotiate with the regulatory agency to address the issues and provide for what will work for all concerned going forward.

            But none of this has been done yet, correct? Correct. So, again…*if* we’re reading this right, as I mentioned in the very first post I made: this Experimental Grant is *temporary* until Industry can get their own spectrum allocation and work with the FCC and–I imagine–the ITU to carve out your slot and the rules under which Industry’s users operate. My guess is that when that occurs, there will be no 9-month-prior notification required, specifically because it *is* a huge imposition–as we both agree.

            March 20, 2013 at 4:03 pm
            admin commented

            We are missing nothing. Your repeated references to spectrum allocation are a red herring. No one is requesting a new spectrum allocation. The FCC is talking about allowing commercial users to share existing spectrum, which the FCC has already allocated for space communications, with existing government users.

            For some reason, you seem to have decided that should not be allowed and commercial users should “get their own spectrum allocation.” You have not explained why that is necessary.

            No, “every other user” has not gone through that process. When a new taxi, airline, police department, etc. begins operation, it doesn’t go to the ITU and FCC to request new spectrum. It uses the bands already allocated for that purpose. Requesting a new band is a big, hairy deal. The only time someone goes to that trouble is when it’s impossible to share the existing bands for some reason.

            The FCC has already allocated spectrum for space communications. Allocating additional spectrum for the same purpose seems foolish unless the existing spectrum is overused. Do you have any evidence that is the case?

            March 20, 2013 at 6:33 pm
            Joe commented

            I mis-typed: 90-day-prior (not 9-month prior)…*or* any of the other impositions of the Experimental Grant that are overly burdensome.

            March 20, 2013 at 4:22 pm
    Joe commented

    I originally saw this article on slashdot (http://goo.gl/qSmrB) – so I figured I’d come to the source. My original comments on the slashdot article can be found at the link above – Comment entitled, “Everybody Wants a Piece of Pie”. Same disclaimer applies: although I work in the satellite communications industry and am a licensed Amateur Radio operator, my opinions are my own and ought not be construed as speaking on behalf of anyone but my self.

    A brief summary of my points from the slashdot comments section:

    a] the FCC doesn’t make spectrum allocations for the whole world – they do so solely for the United States; further, they do not make their allocations in a vacuum: their actions are coordinated with various international groups – particularly the ITU.
    b] some areas of spectrum have been high-demand areas – just look at the HF Spectrum Chart published by NIST. historically, part of the issue with spectrum set-asides has been that those designated users have either under-utilized or not utilized their allocations at all. the effect has been to crowd other allocations and users, and over-inflate the value of remaining spectrum. set-asides for occasional use are a *proven* bad idea.
    c] the concept that the airwaves belong to the public, so the public should have unfettered access at will is both ridiculous as well as dangerous; and also ignores more than 200 years of case and Constitutional law in the US. on this argument, the Federal Government is well within it’s rights to govern and allocate spectrum – any argument to the contrary is ill-informed.

    All this being said, there seems to be at least two issues here: first, the claim that the FCC is not being “forward-thinking” enough for some in the Commercial / Civilian Space industry, in how they’re dealing with said Industry in terms of spectrum allocation.
    Nonsense. The FCC has not forbidden commercial space operations from using spectrum, and in the “Guidance” Public Notice dated 15MAR13, provide their current policy based on current demand. To say, one day later, that this is not sufficient seems to be putting the cart before the horse. Has anyone’s launch schedule, in the 24 hours since this guidance was published, been impacted? Or, now that the FCC has come down with clear guidance, does a 90-days out, 6-months at a time (renewable) policy create an issue with currently-scheduled operations in the near future? I seriously doubt it. In fact, any commercial venture that deals with ISS or NASA projects will probably use allocations given to NASA, for interoperability purposes. I’m willing to bet good money SpaceX’s ISS re-supply mission did exactly this. For those that aren’t, there’s a process with clear guidance, and given the current state of the industry, it’s not entirely clear to me *how* this is, exactly, insufficient. FCC’s guidance isn’t carved in stone. As the industry grows, the issue can be re-addressed and adjusted as needed.

    The second issue seems to be “there’s no guarantee of protection from interference.” News Flash: neither is anyone else, anywhere in the spectrum! Satellite Providers have dozens of spacecraft in orbit, spend millions each year – and I can tell you from first-hand experience that one “Big Player” in the industry has been plagued by interference on multiple satellites for *years* –which no-doubt effects their bottom line. There are methods to mitigate interference, and this helps – but ultimately no one gets a guarantee of interference-free use of spectrum.

    The bigger picture here is that Space Ops spectrum allocations need to be coordinated at the *international* level – not in one country; and the ITU is really the more appropriate authority to coordinate such activities. What is *really* needed here is for the commercial space industry to first designate frequency managers within their organizations, and the several company’s frequency managers put together a working group that can address the issue and propose solutions both within their Countries of Origin, as well as to build support at the ITU for a comprehensive solution set.
    What’s more, there *is* precedent for this model, and indications of it’s success, upon application. One need only look at the role of the HFCC (High-Frequency Coordinating Committee) and the positive impact they’ve had on the Shortwave broadcasting industry in frequency distribution and de-confliction, as an example.

    –Joe (N0LSD)

    Reply
    March 17, 2013 at 7:01 am
      admin commented

      “Has anyone’s launch schedule, in the 24 hours since this guidance was published, been impacted? Or, now that the FCC has come down with clear guidance, does a 90-days out, 6-months at a time (renewable) policy create an issue with currently-scheduled operations in the near future? I seriously doubt it.”

      The fact that you doubt something doesn’t mean it isn’t true.

      The DC-X demonstrated 24-hour turnaround between flights. That was back in the 1990′s. XCOR plans to fly the Lynx Mk 1 up to four times a day. Commercial space is not just SpaceX carrying cargo to ISS a few times a year.

      Basing regulations on “current demand” assumes the future will look like the past. It never does. If a pilot had to request a license 90 days in advance for every airplane flight, we would have few if any airplanes.

      Would you bother with ham radio, if you had to request a new license, 90 days in advance, for each transmission?

      Reply
      March 17, 2013 at 12:18 pm
        Joe commented

        I think your comparing apples and oranges, my friend. There’s thousands of terrestrial flights daily, the industry pre-dates the Communications Act of 1934. Amateur radio also pre-dates the Act of 1934, and there’s millions of Hams worldwide. By contrast, commercial, non-military space flight has been a reality for far, far less time–and the requirement for spectrum is *very* recent, *and* there’s a handful of participants–not thousands or millions.
        There are licensing requirements for nearly all spectrum allocations-including Amateurs…technical knowledge of the station operator or engineer, equipment requirements, power limits, frequency allocation limits, and (in the case of non-COTS equipment) equipment engineering standards that must be met to ensure inter-operability with existing equipment, as well as interference mitigation.

        Please don’t misunderstand–I’m not saying, “back’o’the line for you.” What I am saying, at the risk of reiterating myself, is that simply identifying a desire for a spectrum allocation doesn’t equal obtaining a spectrum allocation. I think the FCC was absolutely right in what they did: first, they didn’t forbid Industry from the spectrum; second, they put in place a protocol to address immediate needs; and third, they absolutely left the door open to future actions as Industry grows.
        I understand that, right now, it’s a hoop through which Industry must jump. Roger–got it. However, Industry is also, essentially, getting *free* spectrum on an as-needed basis during their ramp-up-free from the burden of cost (ask the telecom companies how much they spent on the spectrum auctions for their cell networks, ask satellite providers how much they have to pay for the ability to home earth terminals in the US: it isn’t cheap), and since no technical specifications are listed in the Notice, Industry is also freed from the cost of Regulation and Compliance – the idea, I suppose, is that type-accepted equipment, with controlled power levels, in specifically-designated spectrum slots meets the FCC’s requirements in the short-term–at least for what they control–which is spectrum within the territory of the US. The price for this: prior planning. Seems pretty reasonable to me.

        I also mentioned that this is not a US-centric issue, and that it’s not enough to get buy-in from the FCC–that the FCC is mandated to work within the framework of the ITU when it comes to international communications matters–which Industry absolutely falls within. So, again–what the FCC has done is pretty fair: they’ve said, “hey, until this can be addressed internationally, we’ll fold your requirements into allocations on the Government side, and we’ll give you top-cover–all we want is advanced notice and an idea of what you’re going to be emitting, where, and at what power levels so we can de-conflict with any potential other users and know who to call if there’s an interference issue.” Again, seems pretty fair as an interim solution.

        This provides Industry with a solution for the time being, and also gives Industry an opportunity to do exactly as I suggested–and what every other world-wide user of spectrum has had to do: put together a working group, petition the effected nations individually, and work the issue through the ITU so the issue can be de-conflicted at that level, as well.

        My question is simply this: is there something special about *this* particular industry, that necessitates or demands the long-established rules of the road be discarded?

        Reply
        March 17, 2013 at 1:35 pm
          Joe commented

          The flip side of this issue is I have literally no idea what was contained in the original allocation request – so admittedly I’m flying a bit blind on this.

          For instance, it makes a huge difference if there was a proposal made for a slot that was shot-down, or if Industry proposed utilization of already-allocated Aeronautical allocations and that was denied. I don’t like assuming any of this – I’d much rather see what the original proposal was for comparison purposes.

          –Joe

          Reply
          March 17, 2013 at 2:10 pm
            admin commented

            This is not a response to an allocation request. It’s regulatory guidance on how to submit a request. Like the instructions on how to apply for your Ham radio license.

            March 17, 2013 at 2:43 pm
            Andrew B commented

            I think this Public Notice was clearly written to address SpaceX or perhaps Orbital Sciences CRS flights to ISS. (Orbital Sciences actually makes more sense, because they are going to fly in the coming months; SpaceX has already flown) They even define a “spacecraft” as – “by “spacecraft,” we are referring to a cargo delivery vehicle that is used in the context of an FAA-licensed launch and/or re-entry.”

            I don’t believe this was intended to address suborbital flights.

            I do think that as the different spectra slots have been parceled out over the last 100 years, the barrier to entry for new uses has increased to what is probably an overly burdensome level. There are only a handful of companies progressing to doing suborbital flights on a regular (several times a week) level, and expecting them to “form a working group” (when they are all trying to maintain a competitive advantage over each other, and the launch sites are geographically distributed such that not all operations will be conducted in the same area anyway) to solve a problem that is only a small part of what their business is focused on is….silly.

            I guess if the radio folks want to squash that handful of small companies because heaven forbid anyone actually use a natural resource that belongs to everyone as part of developing a new technology… So be it.

            Not everyone is a multibillion dollar company.

            March 17, 2013 at 2:45 pm
          admin commented

          No, Joe, there’s nothing “special” about this industry. No other industry follows the “rules of the road” you want to impose on space transportation.

          The FCC does not require pilots to request a separate radio license, 90 days in advance, for each flight. It does not require boat owners to request a separate radio license, 90 days in advance, for each cruise. It does not require taxis and UPS trucks to request a separate license, 90 days in advance, for each trip.

          Even in the amateur radio arena, the FCC does not require mobile operators to obtain a separate license, 90 days in advance, of each trip. I can’t imagine why you think these are “long-established rules of the road” when they have never applied to any road.

          There is no case in which the FCC insists that a transportation operator obtain multiple licenses for routine, repetitive operations that are performed hundreds or thousands of times per year, rather than granting a blanket license.

          Comparing satellites and ground stations to launch operations is completely misleading. You aren’t comparing apples to oranges, you’re comparing apples to blue. Satellites and ground stations are facilities that are built once and operate for years. Launches are events that happen on a periodic basis. Satellites and ground stations are licensed once, at the time they are built. They do not require a separate license for each operation (transmission).

          Reusable spacecraft will fly multiple times per week, sometimes multiple times per day. There will not be a “handful” of flight operations, as you persist in misbelieving. There be thousands.

          Do you expect the FCC to hire enough staff to handle thousands of radio applications every year, from each vehicle operator? Do you think that’s a good use of the taxpayers’ money, when 99% of the applications will be completely identical, except for the date and time of launch?

          What about missions that are planned less than 90 days in advance? What happens when an experiment fails and the experimenter wants to refly it the next day? Or if there’s a sudden solar flare, or a weather system, and a scientist wants to go up and get data on it? Do you expect the sun and the weather will wait 90 days?

          Or do you expect the operator to fly without radios, because there isn’t time to get an FCC license?

          This isn’t amateur radio. This is safety critical.

          Does this actually make sense to you?

          Reply
          March 17, 2013 at 2:37 pm
            Joe commented

            No, mate–believe me, I get that this is a limiting factor for Industry going forward over the short-term.

            The difference I see is that in both of the “other examples” we’re talking about here–terrestrial aeronautical and Amateur–both of these have a few things in common: the spectrum allocations are (more or less) established, there has been coordination both internally (read: FCC for the US, Industrie Canada for Canada, etc) and externally (read: ITU). so, no–there’s no need for me as a radio amateur to get a separate license for, say, mobile versus my home station…that issue has been raised in the past, and has been adjudicated. when, however, i wanted to use my amateur equipment in kuwait, i *did* have to apply separately with the proper authorities in kuwait, present my credentials from the US, register my equipment, and wait for the kuwaiti government to adjudicate my request. there is a Reciprocal License Agreement between Kuwait and the US, so I was able to do that. In Afghanistan, where I am now, there is no such agreement–so I’d have to present my credentials and be separately licensed in Afghanistan if I wanted to operate here.
            Also, the rules of the road to which I alluded *are*, in point of fact, the standards by which these things are coordinated and de-conflicted. Two examples: in the area of internetworking, the decision between the competing OSI Model and the TCP/IP Model. At one time, these two were competing theories as to how, precisely, to allow for internetworking, right? who was the deciding authority? the ITU. similarly, look at the example of the friction between SW Broadcasters and the Amateur Community over the 40m band. SW Broadcasters were doing their thing, legally, in one ITU Region (the 40m band is broken down into geographical regions, and slightly different freqs are used in each)–but interfering with legal users in other regions. who decided that issue? the ITU.

            The difference I see is that Commercial Space Ops is not like these other stake-holders that have a long history, relatively established spectrum allocations, a world-wide infrastructure of governance. There’s *none* of that existing right now when it comes to Commercial Space. There’s no baseline for anything–how much spectrum do you need, what frequencies do you want to use, what power levels are going to be needed to meet your requirements, who else is using frequencies in the same area of spectrum and for what purpose; has there been coordination with any other governing bodies–and what freqs, etc are being proposed there…none of this is addressed anywhere that I can see right now.

            We agree, however, that this is not like issuing a permit for a low-power FM community radio station. Depending on the freqs being requested (UHF, SHF, EHF would be the first that come to my mind), there are some pretty significant–and expensive–assets already on-orbit that could be damaged or destroyed by lack of close consideration. I’m with you that this has a potential to limit activities in the short term–but because I’m not read-on to the specifics of any company’s plans for upcoming activities, again…I’m flying blind.

            But the article says the FCC has come up short for Industry–and what I want to know is, specifically, how? I know what the Notice says, what I don’t know is what was requested–and therefore what falls into the gap that would demonstrate a shortfall. I know you’ve said this is just application guidance–so am I to understand that no request has been made for spectrum allocation? It does not make sense to me that *all* these stake-holders didn’t at *some* point say, “what freqs are we going to use to talk on, how are we going to pass telemetry from earth to ground, etc.”

            I’m not a SME in this area–it has some practical bearing on my job and hobby, so I know a bit–and I can’t believe these companies would leave something *that* mission-critical to chance at the last minute. Doesn’t pass the common-sense test.

            –Joe

            March 17, 2013 at 4:04 pm
            admin commented

            A lot of hollering about nothing.

            If you read the public notice, you’d see the frequencies they’re talking about are already used by the Federal government for similar purposes. The FCC is merely allowing commercial companies to use the same frequencies, for the same purposes.

            There is no reason to involve the ITU or Industrie Canada or Kuwait. We aren’t talking about Ham radio or low-power FM community radio or TCP/IP. Let’s try to keep this on topic, shall we?

            All of those horrible insoluble problems you foresee were solved a long time ago by government users. Otherwise, they wouldn’t be able to use these frequencies. All the commercial users need to do is ask. The radios in the Space Shuttle didn’t damage or destroy satellites. Why do you assume that similar radios in commercial vehicles will damage satellites?

            And if the radios did damage satellites, the proper thing for the FCC to do would not be to require a separate license for each launch but to deny the application entirely. That’s what “non-interference basis” means.

            But the article says the FCC has come up short for Industry–and what I want to know is, specifically, how?

            This question has been answered, twice, but let’s try one last time:

            Reusable spacecraft will fly several times a day, sometimes several times a week. Some of those flights will be planned only days or hours in advance. It is not possible to file a separate request for each flight three months in advance, because that would require sending information backward in time. Which, I’m sure you know, is not currently allowed by any communication system licensed by the ITU or FCC. :-)

            March 17, 2013 at 6:43 pm
            Joe commented

            Andrew:

            I agree with you–and I think I mentioned this early in my comments–that the model (especially in the HF spectrum, but it extends past that) by which frequency allocations have been statically-assigned is outdated: and this crowds other users and also over-inflates the value of limited bandwidth. Some would say, “just open it up completely” –and I strongly disagree with that notion. I do, however, believe that a more efficient use of available spectrum could be achieved by clustering similar-use allocations, as well as eliminating some of the allocations that clearly are *not* ever used. There have been efficiencies, for instance, in a number of areas of communications–so it may be possible to re-allocate some spectrum based on those efficiencies – in fact, this was done in the US recently with the television spectrum.

            To say that “these companies compete with each other, and their operations span the globe” doesn’t decrease the need for coordination–in fact, it *increases* it.

            Just because all the movers and shakers in the 1970′s were competing with each other in the world of early computers, they still saw the need for their disparate systems to be able to talk to each other, right? Same applies here. Yes, you have vendor-specific routing protocols–EIGRP in Cisco devices, as an example. But the vast majority of what goes on is not the vendor-specific stuff, but rather the vendor-agnostic protocols like OSPF, BGP.

            So, cool these folks compete with each other. That doesn’t mean that can’t come together and coordinate on basics that effect all of them. That’s just silly – of course they can, and companies do this all the time.

            March 17, 2013 at 5:52 pm
    Joe commented

    Their house, their rules. The rulebook for the Experimental License Service is here: http://www.gpo.gov/fdsys/pkg/CFR-2002-title47-vol1/pdf/CFR-2002-title47-vol1-part5.pdf and the *whole* rulebook is here: http://www.gpo.gov/fdsys/pkg/CFR-2002-title47-vol1/content-detail.html . License period for stations in the ELS is 2-5 years, renewable. In my mind, that provides a window of opportunity to gauge whether, in practice (and not just as a thought exercise) the rules they’ve brought Industry in under are too burdensome, or not.

    If you feel their rules are too much of a burden, petition for a separate allocation: then you can work with them to craft rules that are more closely aligned with Industry users. That’s the solution I propose as more useful for Industry. But while you’re under their roof, using their freqs, either follow their rules or don’t talk. It really is that simple. I don’t make the rules, mate: I just have to follow them, like everyone else.

    Reply
    March 21, 2013 at 5:31 am
      admin commented

      No, Joe, you don’t follow the same rules you want to impose on the commercial space industry. Quite the contrary. As you just admitted, the usual rulebook calls for the FCC to issue licenses per station, not per mission.

      We have asked you repeatedly to give a technical reason for requiring a separate license for every mission. You can’t or won’t. Instead, you just keep saying that someone at the FCC made this rule, and rules must be obeyed (argument by authority).

      But you forgot this rulebook.

      It isn’t “their house.” The FCC is not sovereign. We, the people, are. The Constitution guarantees the right of citizens to petition the government for redress of grievances. If the government makes a bad rule, we have the right to ask the government to change it.

      In fact, the Amateur Radio Relay League has lobbied the government for rule changes on numerous occasions. Your hobby would not even exist if the ARRL never challenged the rules.

      As for requesting a new spectrum allocation, radio spectrum is a scarce resource. Allocating a new block has an economic cost. No one wants to do that unless there’s good reason for it. The FCC hasn’t suggested there is any reason for it, nor have the users. You’re the only one suggesting that but, again, you haven’t given any good reason for it.

      Reply
      March 21, 2013 at 12:09 pm
        Joe commented

        The technical reason is because that’s the rule decision the FCC made. Ask them to revise it if you don’t like it; request a separate allocation if they won’t change their decision. You’re very correct that a separate allocation has an economic cost. However, it seems you want to have your cake and eat it, too: you’re more than willing to camp on the Government’s frequencies–evading the cost burden involved in the usual allocation process for the Commercial world, but you don’t want to operate under their rules. So, ask them to change their decision–if they won’t, do the legwork and bear the economic cost involved in obtaining a separate allocation, and you’ll likely have a much freer hand to craft rules that meet your needs.

        And, yes–we all know quite good and well about the Constitution. That being said–and as I mentioned in my very first post–the FCC is well within their rights as a governmental agency to make rules and requirements, as well as impose penalties for infractions. I would certainly not encourage anyone to challenge this basic premise, as the down-side in terms of penalties can be rather substantial.

        Yes: the ARRL has many functions–one of which is lobbying on behalf of the Amateur radio community. There are many, many differences, however, between the Amateur Radio Service and the spectrum allocation that has been given that Service, and *any* Commercial use of spectrum. For one, Amateurs cannot use their License privileges for profit in any way.

        My whole point in posting, lastly, was and is not to troll this site. In fact, I was quite willing to agree to disagree after the weekends’ discussions. You said the application process doesn’t meet what you see as Industry’s requirements–and I agreed. I still believe the solution lies in an discrete Commercial Space allocation, instead of relying upon an Experimental License Service grant utilizing Government freqs. I would certainly support any effort to obtain such an allocation–precisely because I believe Industry should *not* be subject to either the 90-day-prior notification clause or requiring a separate license for each and every mission.

        The reason I believe those two requirements *are* being imposed is primarily to ensure Industry activities with their Experimental License Grant do not interfere with other spectrum users that have already gone through the process–and borne the cost–of obtaining their own allocations, and on behalf of their customers. The FCC has a responsibility to those folks and their customers, and that takes priority over the Commercial Space–they’ve paid to play, and Commercial Space has not. Experimental License Grants are typically not a long-term solution–which is what leads me to believe it’s a stop-gap measure. In the end, as I said before, I believe Industry will have their own allocation–and, as I also said before, I support that precisely because I *do* believe the two major issues named above are *so* limiting on Industry.

        In summary, we both want the same thing: Industry to have a freer hand in deciding who and how spectrum is utilized. Where we differ, I believe, is how to get there: your solution is to petition the Government to change their position on how they want Industry to utilize *their* frequencies, while I believe the solution is Industry’s own allocation.

        Reply
        March 21, 2013 at 1:17 pm
          admin commented

          “The technical reason is because that’s the rule decision the FCC made.”

          No, Joe, that is not a “technical” reason. It is a bureaucratic reason.

          You have not offered a single technical argument to support your position. You want people to “do legwork and bear the economic cost” for no apparent reason, except that you want them to. That’s not a good reason for spending many millions of dollars.

          Reply
          March 21, 2013 at 2:02 pm
            Joe commented

            I’ve emailed the POCs in the Notice for their thoughts: I’ll let you know what I find out.

            March 21, 2013 at 2:41 pm
            Joe commented

            ADMIN– Shoot me an email. I received a response from the FCC POC, but I did not ask permission to repost his comments–but I will share what I learned with you.

            –Joe

            April 2, 2013 at 3:46 am