Post-Mission Disposal (PMD) Validation of FCC's Ka-band NGSO Processing Round Participants

The Federal Communications Commission (FCC) defines regulations that ensure satellite communications systems seeking access to the U.S. market will properly implement post-mission disposal (PMD) plans to reduce the risk of creating orbital debris. In March 2020, the FCC initiated a processing round for additional applications and petitions for non-geostationary orbit (NGSO) fixed-satellite service (FSS) operations in the 10.7 - 12.7 GHz, 12.75 - 13.25 GHz, 13.8 - 14.5 GHz, 17.7 - 18.6 GHz, 18.8 - 20.2 GHz, and 27.5 - 30 GHz bands. Ten NGSO FSS communications systems operators (EOS Defense Systems, Kepler Communications, Kuiper, Mangata, New Spectrum Satellite, O3b, OneWeb, SpaceX, Telesat, and Viasat) submitted applications. In Part 25 of the Commission's rules, particularly 47 C.F.R. ? 25.114(d)(14), the FCC defines key requirements to limit debris, including guidelines for post-mission disposal and the limitation of accidental explosions. Prior to approving an application for access to the U.S. market, the FCC assesses the compliance of each applicant's system with the Commission's Part 25.114(d)(14) rules. This paper analyzes and validates the PMD and orbital debris mitigation strategies of the ten NGSO FSS communication systems that filed applications in the FCC's March 2020 Processing Round in order to guarantee that adequate plans are in place to prevent the creation of orbital debris, and thus prevent harm to other spacecraft and humans. The methodology includes obtaining relevant information regarding the orbits and operational strategies of the systems from their submitted Technical Narratives and Schedule S reports, and performing PMD analysis validation using NASA's Debris Assessment Software (DAS) to confirm pertinent information such as deorbit duration and required delta-v (Δv) for deorbiting maneuvers. Nine of the ten systems provided statements on their orbital debris mitigation strategies, including identifying the agency or government's orbital debris guidelines with which their system will comply (NASA, UK, Canada, etc.), Several systems under the jurisdiction of foreign administrations, including One Web and 03b, did not provide orbital debris mitigation information as they stated they will follow their administration's orbital debris guidelines rather than the FCC's Part 25 rules pertaining to technical orbital debris showings. Three of the systems (EOS Defense Systems, O3b, Mangata) either stated that they will use a graveyard orbit or expect based on orbital altitude that they will not re-enter, whereas seven systems (Kepler, Kuiper, OneWeb, New Spectrum Satellites, SpaceX, Telesat and Viasat) either stated that they will perform deorbit and re-entry maneuvers or it is expected the spacecraft will naturally deorbit based on the low earth orbit (LEO) configuration. The analysis and validation of the PMD for each system is discussed in detail in this work, with the ultimate goal of aiding the FCC in evaluating the legitimacy of each applicant's approach and maintaining a sustainable space environment for the future.