[arrl-odv:34232] Reply to W7VO and Further Information re Environmental Review of Satellites
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. _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv
My two questions. 1. Is this going to delay the backlog of Amateur Radio issues? 2. Did the Chairwoman respond to Sen. Wicker's letter by Oct 28? Carl K9LA ________________________________ From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> on behalf of david davidsiddall-law.com <david@davidsiddall-law.com> Sent: Friday, November 4, 2022 12:32 PM To: arrl-odv <arrl-odv-bounces@reflector.arrl.org> Cc: Jairam, Ria, N2RJ (Dir, HD) <n2rj@arrl.org> Subject: [arrl-odv:34232] Reply to W7VO and Further Information re Environmental Review of Satellites 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. _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv
Carl I defer to David Siddall on the "delay" issue. However, we confirmed yesterday that Sen. Wicker's staff reported that Chairwoman Rosenworcel has NOT responded to Sen. Wicker's request for a timeline for resolution of Amateur Radio pending matters. _______________________________________ John Robert Stratton N5AUS Director West Gulf Division Office:512-445-6262 Cell:512-426-2028 P.O. Box 2232 Austin, Texas 78768-2232 *_______________________________________*** ** On 11/5/22 5:19 AM, Luetzelschwab, Carl, K9LA (Dir, CD) wrote:
My two questions.
1. Is this going to delay the backlog of Amateur Radio issues? 2. Did the Chairwoman respond to Sen. Wicker's letter by Oct 28?
Carl K9LA ------------------------------------------------------------------------ *From:* arrl-odv <arrl-odv-bounces@reflector.arrl.org> on behalf of david davidsiddall-law.com <david@davidsiddall-law.com> *Sent:* Friday, November 4, 2022 12:32 PM *To:* arrl-odv <arrl-odv-bounces@reflector.arrl.org> *Cc:* Jairam, Ria, N2RJ (Dir, HD) <n2rj@arrl.org> *Subject:* [arrl-odv:34232] Reply to W7VO and Further Information re Environmental Review of Satellites
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*
Default Line
*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*
Default Line
*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.
_______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv
_______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv
Carl, With regard to the reorganization, it will not affect the delayed Part 97 amateur items that have been the focus of discussion. The bureaus and their staffs are completely separate. We deal with the affected International Bureau in two major areas: rules and processes that are specific to the Amateur Satellite Service or of general application and therefore affect all satellites, including amateur; and matters concerning the World Radio Conferences (WRCs), on which Jon Siverling WB3ERA has the lead responsibility. 73, Dave K3ZJ From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> on behalf of John Robert Stratton <N5AUS@n5aus.com> Date: Saturday, November 5, 2022 at 9:39 AM To: "arrl-odv@reflector.arrl.org" <arrl-odv@reflector.arrl.org>, Luetzelschwab Carl <k9la@arrl.org> Subject: [arrl-odv:34234] Re: Reply to W7VO and Further Information re Environmental Review of Satellites — Impact on Pending Amateur Radio Issues & Sen. Wicker Deadline Carl I defer to David Siddall on the "delay" issue. However, we confirmed yesterday that Sen. Wicker's staff reported that Chairwoman Rosenworcel has NOT responded to Sen. Wicker's request for a timeline for resolution of Amateur Radio pending matters. _______________________________________ John Robert Stratton N5AUS Director West Gulf Division Office: 512-445-6262 Cell: 512-426-2028 P.O. Box 2232 Austin, Texas 78768-2232 _______________________________________ On 11/5/22 5:19 AM, Luetzelschwab, Carl, K9LA (Dir, CD) wrote: My two questions. 1. Is this going to delay the backlog of Amateur Radio issues? 2. Did the Chairwoman respond to Sen. Wicker's letter by Oct 28? Carl K9LA ________________________________ From: arrl-odv <arrl-odv-bounces@reflector.arrl.org><mailto:arrl-odv-bounces@reflector.arrl.org> on behalf of david davidsiddall-law.com <david@davidsiddall-law.com><mailto:david@davidsiddall-law.com> Sent: Friday, November 4, 2022 12:32 PM To: arrl-odv <arrl-odv-bounces@reflector.arrl.org><mailto:arrl-odv-bounces@reflector.arrl.org> Cc: Jairam, Ria, N2RJ (Dir, HD) <n2rj@arrl.org><mailto:n2rj@arrl.org> Subject: [arrl-odv:34232] Reply to W7VO and Further Information re Environmental Review of Satellites 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><mailto:arrl-odv-bounces@reflector.arrl.org> on behalf of "Jairam, Ria, N2RJ (Dir, HD)" <n2rj@arrl.org><mailto:n2rj@arrl.org> Date: Friday, November 4, 2022 at 11:40 AM To: arrl-odv <arrl-odv-bounces@reflector.arrl.org><mailto:arrl-odv-bounces@reflector.arrl.org>, "Ritz, Mike, W7VO, (Dir, NW)" <w7vo@comcast.net><mailto: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><mailto:arrl-odv-bounces@reflector.arrl.org> on behalf of Michael Ritz <w7vo@comcast.net><mailto:w7vo@comcast.net> Sent: Thursday, November 3, 2022 5:47:19 PM To: arrl-odv <arrl-odv-bounces@reflector.arrl.org><mailto: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><mailto: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. _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/mailman/listinfo/arrl-odv _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/mailman/listinfo/arrl-odv
Thanks, David. That was the gist of my question. I am preparing my next Division newsletter, and all FCC matters related to amateur radio are of interest to my members. Even news like this show that ARRL "is on top of it". ;-) 73; Mike W7VO
On 11/05/2022 8:00 AM david davidsiddall-law.com <david@davidsiddall-law.com> wrote:
Carl,
With regard to the reorganization, it will not affect the delayed Part 97 amateur items that have been the focus of discussion. The bureaus and their staffs are completely separate. We deal with the affected International Bureau in two major areas: rules and processes that are specific to the Amateur Satellite Service or of general application and therefore affect all satellites, including amateur; and matters concerning the World Radio Conferences (WRCs), on which Jon Siverling WB3ERA has the lead responsibility.
73,
Dave K3ZJ
From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> on behalf of John Robert Stratton <N5AUS@n5aus.com> Date: Saturday, November 5, 2022 at 9:39 AM To: "arrl-odv@reflector.arrl.org" <arrl-odv@reflector.arrl.org>, Luetzelschwab Carl <k9la@arrl.org> Subject: [arrl-odv:34234] Re: Reply to W7VO and Further Information re Environmental Review of Satellites — Impact on Pending Amateur Radio Issues & Sen. Wicker Deadline
Carl
I defer to David Siddall on the "delay" issue.
However, we confirmed yesterday that Sen. Wicker's staff reported that Chairwoman Rosenworcel has NOT responded to Sen. Wicker's request for a timeline for resolution of Amateur Radio pending matters.
_______________________________________
John Robert Stratton
N5AUS
Director
West Gulf Division
Office: 512-445-6262
Cell: 512-426-2028
P.O. Box 2232
Austin, Texas 78768-2232
_______________________________________
On 11/5/22 5:19 AM, Luetzelschwab, Carl, K9LA (Dir, CD) wrote:
> >
My two questions.
1. Is this going to delay the backlog of Amateur Radio issues? 2. Did the Chairwoman respond to Sen. Wicker's letter by Oct 28?
Carl K9LA
---------------------------------------------
From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> mailto:arrl-odv-bounces@reflector.arrl.org on behalf of david davidsiddall-law.com <david@davidsiddall-law.com> mailto:david@davidsiddall-law.com Sent: Friday, November 4, 2022 12:32 PM To: arrl-odv <arrl-odv-bounces@reflector.arrl.org> mailto:arrl-odv-bounces@reflector.arrl.org Cc: Jairam, Ria, N2RJ (Dir, HD) <n2rj@arrl.org> mailto:n2rj@arrl.org Subject: [arrl-odv:34232] Reply to W7VO and Further Information re Environmental Review of Satellites
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 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
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From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> mailto:arrl-odv-bounces@reflector.arrl.org on behalf of "Jairam, Ria, N2RJ (Dir, HD)" <n2rj@arrl.org> mailto:n2rj@arrl.org Date: Friday, November 4, 2022 at 11:40 AM To: arrl-odv <arrl-odv-bounces@reflector.arrl.org> mailto:arrl-odv-bounces@reflector.arrl.org , "Ritz, Mike, W7VO, (Dir, NW)" <w7vo@comcast.net> mailto: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.
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From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> mailto:arrl-odv-bounces@reflector.arrl.org on behalf of Michael Ritz <w7vo@comcast.net> mailto:w7vo@comcast.net Sent: Thursday, November 3, 2022 5:47:19 PM To: arrl-odv <arrl-odv-bounces@reflector.arrl.org> mailto: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> mailto: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
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participants (4)
-
david davidsiddall-law.com -
John Robert Stratton -
Luetzelschwab, Carl, K9LA (Dir, CD) -
Michael Ritz