|OPERATIONS of PSAT2 and BRICsat2 IN THE AMATEUR SATELLITE SERVICE       
|                                 20 July 2015
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|                                                         
|
|This paper addresses the licensing of BRICsat in the Amateur Satellite
|Service.  It extracts the pertinent sections of the IARU (International
|Amateur Radio Union) guildelines for INFORMATION FOR PROSPECTIVE OWNERS
|AND OPERATORS OF SATELLITES UTILIZING FREQUENCIES ALLOCATED TO THE
|AMATEUR-SATELLITE SERVICE  which helps assure compliance with the ITU
|rules.   This document may be viewed in its entirety at:
|http://www.iaru.org/satellite/prospective.html
|
|RULES:
|  "Amateur-Satellite Service: A radiocommunication service using space
|  stations on earth satellites for the same purposes as those of the 
|  amateur service." [RR S1.57]
|
|  "Amateur Service: A radiocommunication service for the purpose of 
|   self-training, intercommunication and technical investigations 
|   carried out by amateurs, that is, by duly authorised persons 
|   interested in radio technique solely with a personal aim and without 
|   pecuniary interest." [RR S1.56]
|
|BRICsat, PSAT, USS Langley COMMENT:
|
|Sponsoring Organization:     US Naval Academy
|Operating Organization:      Volunteer Licensed Amateur Radio Operators
|Satellite Station Licensee:  Todd Bruner, WA1HAI
|
|Dr. Kang KB3UKS is a professor and Bob Bruninga, WB4APR is an engineer in 
|the Naval Academy Aerospace Student project lab who gives engineering 
|guidance to student satellite projects.
|
|Todd Bruner, WB1HAI is an active friend of the Academy, a past Division 
|of Engineering Director at USNA and a retired US Naval Officer.  He is an 
|unpaid volunteer with NO PECUNIARY association with the US Naval Academy, 
|NRO, NASA nor any other Organization involved in this project.
|
|RULES:
|
|  "VI. OPERATIONAL GUIDELINES. The following operational guidelines, based
|   on interpretations by IARU of the Radio Regulations and good amateur
|   practice, are intended to help in planning the missions, management, and
|   control of satellites planned to operate in the amateur-satellite service.
|
|   Organisations building satellites should compare their mission plans to
|   the requirements of the amateur-satellite service. Then, they should
|   determine if it is possible to comply with the requirements of the
|   amateur-satellite service or if licensing and operation should be in some
|   other radio service which is more consistent with the nature and
|   requirements of the mission.
|
|   A. The purposes of an amateur satellite should be:
|
|      (1) To provide communication resources for the general amateur radio
|          community and/or
|      (2) To conduct technical investigations in all respects consistent with
|          the Radio Regulations. [See RR S1.56 and RR S1.57.]
|
|   Technical investigations carried out using frequencies allocated to the
|   amateur-satellite service should be relevant to the development of "radio
|   technique," that is, have a reasonable possibility of application to the
|   development of radio communication systems.  [See RR S1.56 and RR S1.57.]
|
|   Examples of such technical investigations include: propagation studies,
|   operational analysis of protocols used for digital voice and data
|   communication, development of attitude determination methods, development
|   of command and control procedures, studies of radiation effects on various
|   electronic components, studies of meteor trail reflection, and measurement
|   of the orbital environment useful in designing future amateur satellites.
|
|   While many other types of technical investigations are conceivable, those
|   not having a reasonable possibility of application to radio communication
|   systems are probably not in accordance with the treaty requirements. An
|   administration can reject whatever it decides is inappropriate use of the
|   amateur-satellite service or questions may be raised by other
|   administrations.
|
|BRICsat2 and PSAT2 Comment A(1):  These projects are fully in compliance.  
|The communications payloads PSAT2 and BRICSAT2 serve as bent-pipe relays for 
|Amateur Radio Operators worldwide identical to, and supportive of, the data 
|transponders still flying on the first USNA satellite PCSAT launched in 2001 
|and via the amateur radio on the Internatinoal Space Station on 145.825 MHz.
|
|BRICsat2 and PSAT2 COMMENT A(2):  These projects are fully in compliance.  
|BRICsat contains a electric propulsion system, which like other fundamental 
|systems are needed on spacecraft for normal operation.  Technical 
|investigations in improving the state-of the art on such systems for small 
|amateur spacecraft is consistent with the rules noted above. Specifically:
|
| "To conduct technical investigations... consistent with the radio regulations
| "..that have a reasonable possibility of application to the development of
| "[satellite] radio communications systems [which] include: ... development of
| "attitude determination methods... command and control procedures...and
| "measurement of the orbital environment useful in designing future amateur
| "satellites."
|
|By having the primary payload of PSAT and BRICSAT be the amateur radio two-way
|relay transponder for worldwide use, the spacecraft are in good faith 
|fulfilling the primary purpose (1) of the ITU Amateur Satellite Service.
|
|
|RULES:
|
|   B. Station Control.
|
|   All stations operating in the amateur service and the amateur satellite
|   service, including space and Earth stations, must be controlled by "duly
|   authorised persons," that is, licensed amateur radio operators who must be
|   acting "solely with a personal aim and without pecuniary interest." [See
|   RR S1.56 and RR S1.57.]
|
|   Even with these limitations, organisations and amateurs have common
|   interests and work together for their mutual benefit. (For this
|   discussion, an organisation can be a university, research institute,
|   for-profit or not-for-profit corporation, association, club, or other
|   similar entity.)
|
|   AMSAT-NA, for example, is an organisation which owns and builds space
|   stations to operate in the amateur-satellite service. But, because it is
|   an organisation and not an individually licensed radio amateur, it may not
|   control an amateur station. Licenses under which AMSAT-NA owned amateur
|   stations are operated are issued either in the name of an individually
|   licensed amateur radio operator or an amateur radio club (in this case,
|   AMSAT-NA itself) where a licensed amateur radio operator is named on the
|   license as trustee (the person responsible)  for the club station.
|
|   In every case, an individual licensed amateur radio operator, who is
|   neither employed nor paid by AMSAT-NA, is legally responsible for the
|   operation of every amateur station or amateur-satellite station.|
|
|   Commonly, the licensee is an unpaid member of the organisation which owns
|   the amateur station equipment or is a volunteer acting in close
|   association with it. In these cases, the owner's interest and the
|   licensee's "personal interest" are usually the same.
|
|   Of course, it is theoretically possible (although to the best of our
|   knowledge, it has never occurred in practice) that the licensee or trustee
|   of an amateur station or amateur-satellite station may determine that
|   something he or she has been requested to do is not in accordance with the
|   rules and regulations of his/her administration. If this happens, the
|   licensee would inform the organisation and, if possible, they would work
|   out a solution that satisfies and protects both.
|
|   Thus, the individual responsibility of the licensed amateur radio
|   operator, effectively imposed by the Radio Regulations, works as a kind of
|   legal safety check for the organisation and the amateur to protect both of
|   their interests as well as that of the amateur satellite service itself.
|
|NOTE:  The FCC does not issue specific licenses for specific Amateur Satellites
|because they are operated under the existing license of the individual that
|has volunteered to use his license and to be responsible for the proper
|design and operation of the spacecraft within the ITU, IARU and FCC rules.
|See FCC Public Notice: http://aprs.org/psat/FCC Public Notice-clarified-a.doc
|
|BRICsat2 and PSAT2 COMMENT:  These projects are fully in compliance.
|Their organizational structure and operators are compliant with these rules.  
|The operating organization are those volunteer operators around the world 
|that operate as users on the satellite and who collect daily telemetry and 
|send commands as needed to maintain the proper operation of the spacecraft 
|and communication payloads. The Licensee of the spacecraft transmitter is a 
|local volunteer with his own home ground station only blocks from the Naval 
|Academy who is responsible for proper operation of the spacecraft within the 
|FCC and ITU rules.
|
|The interest of these individuals is in the operation of the satellite for 
|personal training and intercommunications with other satellite experimenters 
|in the amateur satellite service and without pecuniary remuneration for such 
|interest.  The Naval Academy volunteers, Dr Jin Kang, KB3UKS and Bob Bruninga,
|WB4APR have decades of non-pecuniary history with the Amateur Satellite 
|Service, are the authors of dozens of related papers in AMSAT and other 
|Amateur Radio publications, and the instigator of Packet Radio experiments on
|numerous other spacecraft such as SAREX, MIR, ARISS, SUNSAT, SAPPHIRE, PCSAT,
|PCSAT2, ANDE, RAFT, and DRAGONS for purely personal aims of learning about
|radio and promoting the Amateur Satellite Service.
|
|
|RULES:
|   D. Plain Language. The amateur-satellite service, by its nature, involves
|   stations of more than one country. International communi- cation between
|   amateur stations in different countries must be in plain language. [See RR
|   S25.2.] The plain language requirement includes telemetry and data
|   exchanged between users.
|
|   To meet the plain language requirement, technical descriptions of all
|   emissions, codes, and formats must be made publicly available.  No system
|   intended to conceal the meaning of a transmission may be used.
|
|   NOTE: Space telecommand transmissions for critical spacecraft functions
|   are generally accepted as exempt from the requirement to use plain
|   language.
|
|BRICsat2 and PSAT2 COMMENT:  These projects are fully in compliance.
|The design, telemetry, data and all aspects of these spacecraft are
|in plain language (AX.25 protocol) and all details are published and in the
|public domain.  They will be maintained for easy access on a web page such
|as those maintained for our earlier spacecraft:
|maintained current on the following WEB page:
|http://aprs.org/pcsat.html and aprs.org/pcsat2.html
|
|RULES:
|   E. Open Access. All telecommunication facilities, except telecommand,
|   operating in amateur-satellite service allocations should be open for use
|   by amateur radio operators world-wide. All experiments utilising
|   frequencies allocated to the amateur-satellite service should be freely
|   available for use by radio amateurs world-wide and for reception by
|   students and educators.
|
|BRICsa2 and PSAT2 COMMENT:  These projects are fully in compliance.
|All user communications modes (except command codes) and all telemetry
|will be available to all amateur radio operators worldwide in accordance 
|with the published user operating recommendations.    There is no other
|usage of these communications transponders, nor circuits beyond what has
|been described here for use in the Amateur Satellite Service.  There may
|be periods when the transponders are commanded off for the purpose of
|saving power, or keeping temperatures under control, or to avoid interference
|with other Amateur Radio experiments, but such OFF times will apply to all users
|equally.  When communications modes are activated, they are open to all
|radio amateurs worldwide who adhere to the recommended user station 
|requirements and uplink parameters.
|
|COMMAND AND CONTROL COMMENT: As noted under rules (E) the communications 
|between the command station and the spacecraft are not open for obvious
|reasons.  The command and control and attitude control system including
|the propulsion system and its monitoring camera are similarly protected
|links and not open to others woldwide.
|
|
|Bob Bruninga, WB4APR
|Trustee,
|US Naval Academy Amateur Radio Club
|410-293-6417
|
|Dr. Jin Kang, KB3UKS
|Student Mentor
|US Naval Academy, Aerospace Dept
|410-293-6411
|
|Todd Bruner, WB1HAI
|Licensee, BRICsat2 and PSAT2
|Cell: 202-689-5471
|Home: 410-280-2460