This topic covers administrative, legal, and regulatory requirements related to satellite communications, data transmission, and remote sensing. It is essential when planning and executing a small satellite mission to obtain the licenses and approvals from the proper organizations in a timely manner. With multiple agencies requiring licenses, and the approval processes potentially taking months (or years) to complete, it is essential that smallsat team are thorough and diligent in navigating the compliance process.
Resources in this topic area are primarily guidelines for obtaining approval from governing agencies and example licensing applications for smallsat missions.
The licensing process can take over a year - start early!
For NASA launch opportunities, obtaining launch approval from NASA is the first step in the licensing process. Once you have received approval for launch and have defined the spacecraft and ground station communications system, you can submit requests for the remaining licenses that are required.
For smallsat missions, typically it takes a full year to go through the complete licensing process. This includes submitting the initial applications, waiting for responses, correcting submissions, and providing all necessary data and required materials to each governing agency. It is highly recommended to start the licensing process as soon as possible to prevent delays in schedule.
Starting in the early stages of your project lifecycle, establish and maintain communication with the relevant regulatory organizations (e.g., the Federal Communications Commission (FCC) and the International Amateur Radio Union (IARU)).
This resource provides information regarding the data protection strategy for a CubeSat mission. Protecting ... the transmission of data over amateur frequency bands is essential to mission success.
This resource provides an overview of the legal and regulatory issues related to small satellite missions ... and provides useful examples and processes on how to handle them. Section 4 of the document outlines launch services, space insurance, and in-orbit legal and policy issues.
This resource provides an example of the FCC's Experimental Radio Station Construction Permit and License ... completed by ASU. This license permits the ASU licensee to use and operate the radio transmitting facilities detailed in the FCC filing.
An example form sent to the International Amateur Radio Union (IARU) requesting transmission frequencies ... for uplink and downlink of a CubeSat mission.
An example response from the International Amateur Radio Union (IARU) coordinating the frequencies for ... uplink and downlink for a CubeSat mission.
An example application sent to the National Oceanic and Atmospheric Administration (NOAA) for a 3U CubeSat ... mission remote sensing license.
This FCC Fact Sheet details the proposed change to the Commission's part 25 satellite licensing rules ... to create an alternative application process for small satellites. Previously, smallsats were subject to fees and regulatory requirements that were originally developed for expensive, long-lived missions. The requirements for the types of smallsats that would be affected by this change are detailed on the first page of this document.
An example waiver sent to the National Oceanic and Atmospheric Administration (NOAA) requesting earth ... imaging permission for the Phoenix CubeSat. The waiver includes the questions and ASU's answers to obtain earth imaging permission for the cubesat mission.
This document provides advice and insight into frequency licensing from ASU's Phoenix CubeSat team. This ... includes significant detail and specific instructions for navigating the frequency licensing process with the FCC.
This document provides detailed policy information on smallsat compliance. It describes the separation ... of responsibilities between the launch provider and the satellite owner, and it provides the specific policies for various agencies and organizations such as the DoD, FCC, FAA, NASA, etc.
This website holds a variety of useful resources including forms, guides, specs, and examples pertaining ... to NOAA and the United States Department of Commerce. A license application example is provided outlining the information required to obtain a license to operate a remote sensing space system.
This NASA recommended document provides useful guidance on obtaining a license from the Federal Communications ... Commission (FCC). It answers important questions such as; who is eligible, how to apply for a license, and what information is required - including information related to orbital debris mitigation.
This introductory document outlines the basic concepts and processes involved in developing cubesats. ... Chapter 5, titled "Licensing Procedures", specifically discusses which licenses are necessary to obtain for cubesat missions. There are multiple agencies that require specific licenses and this document is a good starting point for an overview on obtaining the correct licenses.
"The Debris Assessment Software (DAS) utility provides data that can verify compliance of a spacecraft, ... upper stage, and/or payload with NASA's requirements for limiting debris generation, spacecraft vulnerability, postmission lifetime, and entry safety. Successful verification of a design in DAS demonstrates compliance with NASA debris mitigation requirements."
In Chapter 3, this handbook provides useful information on the responsibilities of organizations launching ... space missions. Chapters 1 and 2 provide valuable political, legal, policy, and regulatory context regarding these responsibilities. The content in Chapter 3 on licensing, operations, and end-of-life are particularly useful for smallsat developers.
"This guidebook provides basic information to help commercial space organizations, especially emerging ... entrepreneurial firms, considering business in the international market. It is intended to serve as a starting point in the preparation for the export control process." Given the international nature of the smallsat industry and the often complex, expensive, and time consuming nature of export control processes, this guidebook is a valuable resource for any US-based smallsat developer or commercial provider of smallsat products.
"This paper gives an overview of the licensing and authorization regimes in the United States as they ... apply to small satellite operations." The licensing requirements imposed on small satellite developers are constantly changing and this paper provides a thorough but concise description of them as of 2020.
When exporting a satellite outside of the U.S., there are many rules and regulations to follow prior ... to shipping. This resource details the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR) procedures that must be followed to be in accordance with U.S. export regulations.
In this paper, Blake summarizes the primary Governmental regulations and licenses that need to be obtained ... by most satellite developers. From FCC registrations to launch and export licenses required for imaging satellites, this resource provides links and guidance on the processes for transporting and launching satellites.
"This paper explores United States (U.S.) space policies and how they apply to satellite missions that ... may not fit the typical satellite mission mold. The paper presents a “roadmap” for policy compliance for satellites from diverse agencies and identifies areas where further work is underway to address the challenges posed by the evolution of the space industry. The paper lays out a coherent way forward for all small satellites navigating the approval quagmire, and for mission managers of multi-payload rideshares who wish to smooth the path to launch approval."