News from the ITU Symposium on Small Satellite Regulation

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Ignoring U.N. Space Registry

The United Nations Outer Space Treaty’s Article 6 includes a Registration Convention mandating that every nation putting something into space register it with the U.N. Office of Outer Space Affairs (OOSA).

Niklas Hedman OOSA
Niklas Hedman, chief of OOSA’s committee on policy and legal affairs. Credit: ITU

“The Registration Convention provisions are binding,” said Niklas Hedman, chief of OOSA’s committee on policy and legal affairs, in a March 2 address to the ITU conference on small-satellite regulation in Prague.

The problem is that not many governments appear to care a fig about the Registration Convention. They do not register their satellites. Government and industry officials interviewed here said many of the largest spacefaring nations, including the United States, fail to register their satellites.

It is not just military satellites that are not there. Even some of the best-known commercial telecommunications and Earth observation spacecraft are not in the registry.
“This has always been the case; no one does it,” one government official said. “We have gotten used to it.”

Hedman, in his address, said, “We see positive trends” in recent years, with more nations listing their satellites.


Financial Incentive To Cheat

Memo from small-satellite owners to national and international regulators: If you want us all to play by the rules, please adjust them to account for our financial resources. The alternative is to watch cheating develop into an art form, or to strangle a promising young industry.

Exhibit A: licensing fees. Most nations have them — the United Kingdom is an exception, but the British system has costs elsewhere that others do not. In the United States, the Federal Communications Commission has three categories of satellites: amateur, experimental and professional or operational.

Amateur is free, experimental is $60 and operational is $430,000. Now guess which two categories are the most popular among owners of small satellites.

“You can see why so many projects misuse the system,” said one operator of a commercial constellation of small satellites. “We have private-sector financial backing and we file as operational satellites. But I do commiserate with those projects that try to get in under other categories.”

The International Telecommunication Union, which is the global regulator of wireless radio frequencies and orbital slots, thinks “amateur” should be reserved for those serving members of the Radio Amateur Satellite Corp., Amsat. The ITU questions whether any satellite is “experimental” in the regulatory sense unless it can prove that it shuts down whenever it is not beaming — experimentally — over its national territory.


Orbital Debris Object Lesson

Earth orbital debris
Earth orbital debris. Credit: NASA

Orbital debris experts say they view small-satellite owners as motorcyclists weaving through traffic, flouting the rules of the road everyone else must follow.

Here is one reason why. Cubesat owner X, who will not be named here, was only able to get a launch into an 800-kilometer orbit because as a piggyback payload, as are most small satellites, his was subject to the demands of the main payload. The organization is on a tight university-type budget and put no propulsion on the satellite.

But as the satellite moved into critical design review, the national government began adopting rules about orbital debris and the use of “best practices” in space, including a requirement that low-orbit satellites remove themselves from orbit within 25 years of retirement.

“We were able to get grandfathered so that our satellite was exempted from the rules,” said a program manager, whose satellite is working well and is the pride of the technical team that built it.
How long will it remain in orbit? “Possibly around 700 years,” he said.


ITU Vocabulary Lesson

The International Telecommunication Union (ITU) is asking small-satellite owners, and the national governments that make regulatory filings on their behalf, to stop saying their satellites will use ISM frequencies.

“The ISM band is not allocated to any space service,” said Yvon Henri, head of the ITU’s space services department, referring to terrestrial frequencies reserved for industrial, scientific and medical purposes. “If you say you do not know your frequency plan, well, how do you establish a link budget? You need to submit the frequencies that, to your best knowledge, will be used.”

The ITU also would like smallsat owners to stop saying satellites are “experimental” as they use low Earth orbit to beam all over Earth well beyond their national territories.

Henri told the ITU Symposium on Small Satellite Regulation March 2 in Prague that “experimental” frequencies are for terrestrial sources beaming over limited territory authorized by a national government. It is not experimental, he said, if it is crossing national borders dozens of times per day, as satellites in low Earth orbit tend to do.

ITU does allow satellites, including amateur radio spacecraft, to be labeled “amateur” and thereby escape the filing fee of 7,600 Swiss francs ($7,700) in ITU cost recovery fees. But here, too, the agency is finding too many satellite system owners trying to fit clearly precommercial or fully commercial systems into the “amateur” category.

The result is adults trying to fit into children’s clothing, and as the number of small-satellite networks increases, the agency will be more vigilant in separating the amateurs from the rest.


GomX-2 satellite GomSpace
GomX-2 satellite. Credit: GomSpace

Surviving Antares Blast

Last October’s on-pad failure of an Orbital ATK Antares rocket carrying cargo for the international space station produced a telegenic fireball from which nothing, it seemed, could survive.
But something did.

GomX-2, an apparently plucky cubesat — ironically equipped with is own deorbit experiment — came out of the fire and crash of the Cygnus payload module without a scratch, according to program managers at GomSpace Apps of Aalborg, Denmark.

GomSpace Chief Technology Officer Jacob Molbach Nissen, speaking at the ITU Symposium on Small Satellite Regulation, said NASA found GomX-2 inside its Nanoracks deployer and returned it to the company.

GomSpace said the week of March 9 that it had not yet conducted sufficient testing to determine whether the satellite’s functionalities survived to the same degree as its outer appearance.
One industry official said GomX-2 was not the only satellite to have survived, but that for some reason the other owners are operating under a gag order of unclear origin.

Dulles, Virginia-based Orbital ATK did not respond to a request for information on whether other satellites emerged OK.

Nissen said GomSpace, formed in 2007, has exported small-satellite commercial, off-the-shelf components to 45 nations. Its first satellite, GomX-1, was launched in 2013 aboard a Russian-Ukrainian Dnepr rocket.

The next, GomX-3, is scheduled for launch in June to the International Space Station, where it will be deployed next fall.

Nissen said GomX is following the industry trend, which started some years ago with universities launching satellites of limited functionality into space, with the goal being more concerned with launching something than with the satellite’s performance.

The second phase permitted the use of cubesats for noncritical science missions. The current phase, he said, includes advances in cubesat components that allow their use by national security agencies for communications and border surveillance, and commercial applications.