Kall Morris: FCC Should Cut 100 Object-Years Approach to 25-50

Given the expected growth in low earth orbit traffic, the FCC's pending 100 object-years metric proposal (see 2405290074), while a good idea, should be reduced to 25 to 50 years, Kall Morris said in docket 18-313 Thursday. It also urged data collection that it said would improve rulemaking. The data would include planned and actual total derelict time on orbit for failed and planned disposals for each object launched and tracked by the operator. It said the FCC also could play a role in fostering collaboration between insurance companies and in-orbit servicing, assembly and manufacturing operators. Operators' premiums could pay for ISAM services if relocation of a satellite is needed owing to damage or if it exceeded object-year time frames, it added.