[arrl-odv:30204] Commission Acts on Satellite Debris
ODV, Following up on the Joint ARRL-AMSAT filing of April 9, today the FCC adopted significant changes to its satellite rules that govern orbital debris. AMSAT and ARRL’s main concerns with the FCC staff proposals related to indemnification and maneuverability requirements that in the context of amateur satellites would have presented barriers to the Amateur Satellite Service in particular. An unusually large number of other affected parties expressed multiple concerns with the staff proposals on a large number of issues. At its meeting this morning, the Commission moved a number of proposed decisions from the Report and Order to an accompanying Further Notice of Proposed Rulemaking, including the two identified by AMSAT that would have affected the amateur satellites negatively. The net effect is that the Commission will take further comment on modified proposals on these issues of concern to amateur satellite enthusiasts. Regards Dave 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: "david@davidsiddall-law.com" <david@davidsiddall-law.com> Date: Thursday, April 9, 2020 at 5:00 PM To: ODV <arrl-odv@arrl.org> Subject: ARRL and AMSAT Joint Filing re Satellite Debris ODV, Last Thursday the FCC released a draft Report and Order addressing satellite debris, and the item will be on the FCC’s April 23 meeting. A year ago we filed comments with the FCC in support of AMSAT’s positions on the issues raised. AMSAT has several issues with the proposed rules changes. Their representative, Paul Stoetzer (N8HM), and I had a good (virtual) discussion with the relevant FCC staff yesterday afternoon and filed the attached ex parte letter today. Let me know if any questions. 73, Dave 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.
Dave, Do you envision that the ARRL needs file additional comments on the “Further Notice of Proposed Rulemaking”? Many thanks! 73, Tom – W3TOM From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> On Behalf Of david davidsiddall-law.com Sent: Thursday, April 23, 2020 12:34 PM To: ODV <arrl-odv@arrl.org> Subject: [arrl-odv:30204] Commission Acts on Satellite Debris ODV, Following up on the Joint ARRL-AMSAT filing of April 9, today the FCC adopted significant changes to its satellite rules that govern orbital debris. AMSAT and ARRL’s main concerns with the FCC staff proposals related to indemnification and maneuverability requirements that in the context of amateur satellites would have presented barriers to the Amateur Satellite Service in particular. An unusually large number of other affected parties expressed multiple concerns with the staff proposals on a large number of issues. At its meeting this morning, the Commission moved a number of proposed decisions from the Report and Order to an accompanying Further Notice of Proposed Rulemaking, including the two identified by AMSAT that would have affected the amateur satellites negatively. The net effect is that the Commission will take further comment on modified proposals on these issues of concern to amateur satellite enthusiasts. Regards Dave 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: "david@davidsiddall-law.com <mailto:david@davidsiddall-law.com> " <david@davidsiddall-law.com <mailto:david@davidsiddall-law.com> > Date: Thursday, April 9, 2020 at 5:00 PM To: ODV <arrl-odv@arrl.org <mailto:arrl-odv@arrl.org> > Subject: ARRL and AMSAT Joint Filing re Satellite Debris ODV, Last Thursday the FCC released a draft Report and Order addressing satellite debris, and the item will be on the FCC’s April 23 meeting. A year ago we filed comments with the FCC in support of AMSAT’s positions on the issues raised. AMSAT has several issues with the proposed rules changes. Their representative, Paul Stoetzer (N8HM), and I had a good (virtual) discussion with the relevant FCC staff yesterday afternoon and filed the attached ex parte letter today. Let me know if any questions. 73, Dave 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.
Hi Ton, Yes. AMSAT’s main issues were taken out of the decision and put into the Further Notice, although the new Notice does include our “ask” for satellite owners, as well as licensees, to be eligible to provide whatever indemnification statement that maybe required. So this time we are starting with that seemingly agreed. But yes, new comment will be submitted by AMSAT and I assume by ARRL. 73, Dave K3ZJ From: "w3tom@verizon.net" <w3tom@verizon.net> Date: Saturday, April 25, 2020 at 11:48 AM To: "david@davidsiddall-law.com" <david@davidsiddall-law.com>, 'ODV' <arrl-odv@arrl.org> Subject: RE: [arrl-odv:30204] Commission Acts on Satellite Debris Dave, Do you envision that the ARRL needs file additional comments on the “Further Notice of Proposed Rulemaking”? Many thanks! 73, Tom – W3TOM From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> On Behalf Of david davidsiddall-law.com Sent: Thursday, April 23, 2020 12:34 PM To: ODV <arrl-odv@arrl.org> Subject: [arrl-odv:30204] Commission Acts on Satellite Debris ODV, Following up on the Joint ARRL-AMSAT filing of April 9, today the FCC adopted significant changes to its satellite rules that govern orbital debris. AMSAT and ARRL’s main concerns with the FCC staff proposals related to indemnification and maneuverability requirements that in the context of amateur satellites would have presented barriers to the Amateur Satellite Service in particular. An unusually large number of other affected parties expressed multiple concerns with the staff proposals on a large number of issues. At its meeting this morning, the Commission moved a number of proposed decisions from the Report and Order to an accompanying Further Notice of Proposed Rulemaking, including the two identified by AMSAT that would have affected the amateur satellites negatively. The net effect is that the Commission will take further comment on modified proposals on these issues of concern to amateur satellite enthusiasts. Regards Dave 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: "david@davidsiddall-law.com<mailto:david@davidsiddall-law.com>" <david@davidsiddall-law.com<mailto:david@davidsiddall-law.com>> Date: Thursday, April 9, 2020 at 5:00 PM To: ODV <arrl-odv@arrl.org<mailto:arrl-odv@arrl.org>> Subject: ARRL and AMSAT Joint Filing re Satellite Debris ODV, Last Thursday the FCC released a draft Report and Order addressing satellite debris, and the item will be on the FCC’s April 23 meeting. A year ago we filed comments with the FCC in support of AMSAT’s positions on the issues raised. AMSAT has several issues with the proposed rules changes. Their representative, Paul Stoetzer (N8HM), and I had a good (virtual) discussion with the relevant FCC staff yesterday afternoon and filed the attached ex parte letter today. Let me know if any questions. 73, Dave 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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w3tom＠verizon.net