I think Mike is asking about my comments on how the reorganization is expected to affect amateur satellite matters. And yes, that can be made public, thank you for asking. Anything in the below also can be used publicly except for the two highlighted sentences.

Yesterday in the same email I noted increasing criticism of the FCC for not requiring environmental evaluations for satellites and satellite constellations. The General Accounting Office (GAO) just released a report in which it recommends that the FCC re-evaluate its current exclusion. The report appears to be limited to the large constellations of commercial satellites that are now being launched, and with a quick review does not appear to address amateur radio and other single satellites. Nevertheless, we must keep current on any future FCC actions to be sure that small amateur satellites are not swept into environmental review requirements unless there are justifiable reasons for doing so. Environmental reviews generally require very significant work. The full report and additional information is at this link: https://www.gao.gov/products/gao-23-105005.

The GAO’s summary insofar as relevant to our purposes follows.

GAO found that FCC has not sufficiently documented its decision to apply its categorical exclusion when licensing large constellations of satellites. In 1986, FCC created a categorical exclusion for all actions except those meeting specific conditions. These conditions are largely focused on environmental effects on the Earth's surface, such as the construction of facilities to be located in an officially designated wildlife preserve. FCC officials told GAO that the agency invokes its categorical exclusion when licensing large constellations of satellites. The Council on Environmental Quality, which oversees agencies' implementation of the National Environmental Policy Act, recommends that agencies periodically review categorical exclusions to ensure they remain current.

FCC has made changes to the categorical exclusion. However, FCC has never reviewed and documented whether it should apply to large constellations of satellites. GAO also found that FCC does not have a process or timeline for periodically reviewing its categorical exclusion and publishing the information on its website. Further, FCC has not identified and made public factors it considers in determining whether extraordinary circumstances are present. Taking these actions would better position FCC to ensure that its decisions to apply its categorical exclusion are current and transparent when licensing large constellations of satellites.

73,

Dave K3ZJ

David R. Siddall

Managing Partner

DS Law, PLLC

1629 K St. NW, Ste 300

Washington, DC 20006

direct: +1 202 559 4690

Unauthorized Disclosure Prohibited. This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you.

From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> on behalf of "Jairam, Ria, N2RJ (Dir, HD)" <n2rj@arrl.org>
Date: Friday, November 4, 2022 at 11:40 AM
To: arrl-odv <arrl-odv-bounces@reflector.arrl.org>, "Ritz, Mike, W7VO, (Dir, NW)" <w7vo@comcast.net>
Subject: [arrl-odv:34231] Re: FCC Plans to Reorganize International Bureau

I would imagine that as a FCC public press release that it is.

From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> on behalf of Michael Ritz <w7vo@comcast.net>
Sent: Thursday, November 3, 2022 5:47:19 PM
To: arrl-odv <arrl-odv-bounces@reflector.arrl.org>
Subject: [arrl-odv:34229] Re: FCC Plans to Reorganize International Bureau

Thanks, David. A question though: Are excerpts of this shareable?

73;

Mike

W7VO

On 11/03/2022 11:14 AM david davidsiddall-law.com <david@davidsiddall-law.com> wrote:

ODV,

FYI, this morning FCC Chairwoman Rosenworcel announced plans to reorganize the Commission’s International Bureau into a new Space Bureau and a separate Office of International Affairs. Reorganizations of this nature require various approvals and consents, so implementation likely is a few months away.

What will this re-organization mean for amateur radio?

World Radio Conference preparations will move to the new Office of International Affairs.

Satellite licensing not done under Experimental Licensing (which is in the Office of Engineering and Technology [OET]) will be handled in the newly reorganized Satellite Bureau.

Satellite rules – of consequence generally for amateur satellites – will be the responsibility of the Satellite Bureau.

IARU amateur satellite coordination will continue to be done working with the new Satellite Bureau and/or OET, as appropriate.

I also want to note that there has been increasing criticism of the FCC for not requiring environmental evaluations for satellites and satellite constellations. This is not an inconsequential matter if the Commission begins to require evaluations by individual satellites (rather than only to constellations of a minimum size).

Let me know if any questions

73, Dave K3ZJ

David R. Siddall

Managing Partner

DS Law, PLLC

1629 K St. NW, Ste 300

Washington, DC 20006

direct: +1 202 559 4690

Unauthorized Disclosure Prohibited. This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you.

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