Published: Nov. 19, 2019
Small satellite

An interdisciplinary team led by the Samuelson-Glushko Technology Law and Policy Clinic (TLPC) at the University of Colorado Law School, in partnership with Dr. Scott E. Palo and CU Boulder’s College of Engineering and Applied Science, had a role in influencing groundbreaking national policy for small satellites at the Federal Communications Commission (FCC).

Working under the supervision of Associate Clinical Professor Blake E. Reid, TLPC student attorneys Jake Stephens ('21), Galen Pospisil ('19), and Megan Chavez ('19), along with Stefan Tschimben, a PhD candidate in the Technology, Cybersecurity, and Policy (TCP) program, represented Palo, a professor in the Smead Aerospace Engineering Sciences program, to comment on the FCC’s rulemaking process for small satellite licensing.

In collaboration with Palo and a coalition of other small satellite researchers at the University of Florida, the Massachusetts Institute of Technology, the University of Michigan, and others, the TLPC in August 2018 filed comments before the FCC on a variety of issues in the commission’s proposed new streamlined process for small satellites. The team offered thoughtful commentary on a variety of complex issues, including satellite deployment heights, propulsion requirements, application fees, and wireless spectrum requirements.

Small satellites are frequently used by university researchers and their students to serve the public interest, but the licensing processes overseen by the FCC and other agencies can be complex and expensive. In April 2018, the FCC recognized the need for streamlining its existing rules and sought comments from the public on how to best do so, Reid explained.

In its August order, the FCC cited CU’s comments in its decision to significantly lower deployment height, ensuring university researchers would maintain a range of small satellite licensing options. For example, the comment successfully argued that the FCC’s proposed deployment rules would hinder university researchers from conducting important climate and space weather research.

"It’s critical that university researchers can launch critical scientific and other public interest missions that take advantage of the decreased size and cost of the small satellite form factor. It’s a privilege for the clinic to work with Dr. Palo and his colleagues to ensure the ability for university researchers to have access to space for their important work," Reid said.

"This project was a great example of how a collaboration between the College of Engineering and law school can be impactful while educating students. As subject matter experts, the engineers provided specific details about the technical challenges and the law students used this information to create a convincing argument," Palo said. "The TLPC took the lead on creating the filing and ensured the documents were succinct and professional."

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Photo credit: NASA