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Actual FCC filing: https://www.fcc.gov/ecfs/search/search-filings/filing/10629403013960 https://www.fcc.gov/ecfs/search/search-filings/filing/106294... Some in
by adolph 3y ago
Actual FCC filing:
https://www.fcc.gov/ecfs/search/search-filings/filing/10629403013960 https://www.fcc.gov/ecfs/search/search-filings/filing/106294...
Some interesting quotes:
As an initial matter, if the Commission updates its rules, it should adopt operational information sharing requirements that would enhance space situational awareness and collision avoidance for all satellite systems. For example, the Commission should require operators to register themselves and publish contact information on Space-Track.org to ensure that other operators can reach them in the event of a potential conjunction. The Commission should also require all operators to publish their ephemerides and reasonable covariance data...
Evenly applying requirements across operators would also curtail the regulatory gamesmanship that is unfortunately rampant in the Commission’s satellite dockets. This gamesmanship is encouraged when interested parties believe that they can force burdensome or restrictive conditions on their competitors while avoiding having these conditions applied to their own operations.
Unlike an effective performance-based metric, applying aggregate collision probability would arbitrarily and needlessly cap the size and capacity of responsible systems to the detriment of American consumers with no corresponding benefit for sustainability. These arbitrary caps would further drive satellite operators to license overseas while punishing U.S.-licensed operators and limiting their ability to effectively compete.