27 August 2015

NASA Spectrum Management Program

Spectrum Guidance for NASA

Small Satellite Missions

Version 1.0 (2015.08.27)

Effective Date: 27 August 2015

Expiration Date: 26 August 2017

Abstract

The NASA Spectrum Management Program provides the overall planning, policy, coordination and 

implementation necessary to ensure adequate access to and protection of electromagnetic (EM) spectrum 

in support of NASA’s present and future programmatic goals. With these responsibilities, the NASA 

Spectrum Management Program maintains NASA Policy Directives, NASA Procedural Requirements, 

Spectrum Guidance documents, and other documents as needed.

This Spectrum Guidance, applicable to all NASA small satellite missions (orbiting systems < 180 kg), 

provides spectrum policy and process guidance for NASA small satellite missions requiring the use of the 

electromagnetic spectrum for transmission, reception, or both.
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Contents

Contents ....................................................................................................................... i

1. Purpose & Overview............................................................................................................. 1

1.1. Purpose of the Spectrum Guidance for NASA Small Satellite Missions ..................... 1

1.2. Overview ..................................................................................................................... 1

2. Documents ...................................................................................................................... 2

2.1. Authority Documents................................................................................................... 2

2.2. Applicable Documents ................................................................................................ 2

2.3. Reference Documents & Information Sources............................................................ 2

3. Policy Overview .................................................................................................................... 1

4. Process for Certification, Authorization, and Licensing................................................... 2

4.1. Establish Contact with NASA Spectrum Management ............................................... 2

4.2. Status: Federal/Non-Federal....................................................................................... 2

4.3. Federal System: NTIA Certification and Frequency Authorization.............................. 4

4.4. Non-Federal System: FCC Licensing ......................................................................... 6

4.5. International Satellite Notification and Coordination ................................................... 6

4.5.1 Satellite Notification for NASA Missions ....................................................... 7

4.5.2 Satellite Notification for Non-NASA (Non-Federal) Systems ........................ 7

5. Provisions for Contracts, Grants, and Other Agreements and Announcements ......... 10

5.1. Contracts/Agreements: Require Spectrum Authorization ......................................... 10

5.2. Contracts/Agreements: Indicate Ownership & Operator (Effective Control)............. 10

6. Launch and Deployment Related Requirements: Launch Services and ISS ................ 11

6.1. Launch Requirements: Expendable Launch Vehicles (ELVs) .................................. 11

6.2. ISS Deployment Requirements................................................................................. 12

7. Processes Affiliated with Spectrum Authorization.......................................................... 13

7.1. Orbital Debris Mitigation............................................................................................ 13

7.2. Private Remote Sensing Space System Licensing................................................... 13

Appendix A. Acronyms and Definitions................................................................................ 14

Appendix B. Spectrum-Related Provisions for Contracts and Other Agreements........... 15

B.1 Language for Spectrum Authorization/Frequency Licensing..................................... 15

B.2 Language for Ownership and Operation (Effective Control)...................................... 16

Appendix C. Design Considerations and Potential Frequency Bands .............................. 18

C.1 Mission Operations Planning..................................................................................... 18

C.2 Network Support and Spaceflight Hardware Availability ........................................... 19

C.3 Operational Considerations....................................................................................... 19

C.4 Frequency Band Selection & Technical Parameter Constraints ............................... 21
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1. Purpose & Overview

The NASA Spectrum Management Program provides the overall planning, policy, coordination and 

implementation necessary to ensure adequate access to and protection of electromagnetic (EM) spectrum 

in support of NASA’s present and future programmatic goals. With these responsibilities, the NASA 

Spectrum Management Program maintains NASA Policy Directives, NASA Procedural Requirements, 

Spectrum Guidance documents, and other documents as needed.

1.1. Purpose of the Spectrum Guidance for NASA Small Satellite Missions

This Spectrum Guidance, applicable to all NASA small satellite missions (orbiting systems < 180 kg), 

provides spectrum policy and process guidance for NASA small satellite missions requiring the use of the

electromagnetic spectrum for transmission, reception, or both.

1.2. Overview

Per NASA Policy Directive (NPD) 2570.5E, it is NASA policy that all NASA satellite missions, 

including any small satellite missions (orbiting systems < 180 kg), whether directly developed and 

operated by NASA or those supported through contracts or other financial agreements, that require the 

use of the electromagnetic spectrum shall follow the United States spectrum regulatory rules and 

processes as referenced in the documents listed in “Authority Documents” as well as all applicable 

international spectrum regulations.

All missions and projects requiring the use of the electromagnetic spectrum should contact the associated 

Center/Facility Spectrum Manager (SM) as early in the mission development process as possible to 

discuss the electromagnetic spectrum operations concept and the necessary system certification and 

frequency authorization (licensing) requirements. Please note that all uses of the radio frequency 

spectrum require an authorization either from the National Telecommunications and Information 

Administration (NTIA) if it is a Federal Government system or a license from the Federal 

Communications Commission (FCC) if it is a Non-Federal Government system (discussed in detail in

subsequent sections). If access to or use of specific areas of spectrum is a critical component of a 

mission, then the Spectrum Manager should be contacted during the pre-proposal and proposal phase. As 

part of the spectrum authorization and licensing process, a mission must work with NASA spectrum 

management to determine the Federal or Non-Federal status of the system since the status defines which 

regulatory agency and rules are involved for frequency authorization. A variety of technical rules also 

apply to small satellites regarding launches, orbital debris, frequency selection, and other matters. This 

guidance document provides a starting point for small satellite missions to understand and follow 

spectrum and related regulatory requirements.
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2. Documents

As defined by NASA procedures, there are three types of documents referenced in this Guidance: 

authority documents, applicable documents, and reference documents. 

2.1. Authority Documents

The authority documents listed in Table 1 identify the higher level documents that inform the guidance 

contained in this document.

Table 1: Authority Documents

Number Title Date

NPD 2570.5E NASA Electromagnetic Spectrum Management 11 July 2011

NPR 2570.1C NASA Radio Frequency Spectrum Management Manual 22 Sep 2014

47 U.S.C. Communications Act of 1934, as amended

47 C.F.R. pt. 300

Manual Of Regulations And Procedures For Federal Radio

Frequency Management, U.S. Department Of Commerce

National Telecommunications and Information Administration

2014

2.2. Applicable Documents

Applicable documents, Table 2, are cited in the body of this document and contain provisions or other 

pertinent requirements directly related to the performance of the activities referenced by this document.

Table 2: Applicable Documents

Number Title Date

NPR 8715.6A NASA Procedural Requirements for Limiting Orbital Debris 14 May 2009

DA: 13-445 FCC Guidance On Obtaining Licenses For Small Satellites

http://www.fcc.gov/document/guidance-obtaining-licenses-small-satellites

15 March 2013

2.3. Reference Documents & Information Sources

The reference documents and information sources in Table 3 provide information referenced in this 

guidance document.

Table 3: Reference Documents & Information Sources

Number Title Date

U.S. Government Orbital Debris Mitigation Standard Practices February 2001

NASA information on orbital debris including standards, 

analysis software, processes, etc. 

http://orbitaldebris.jsc.nasa.gov/index.html

LSP-REQ-317.0

Launch Services Program Program Level Poly-Picosatellite 

Orbital Deployer (PPOD) and CubeSat Requirements 

Document

13 October 2011

AFSPCMAN 91-

710

Range Safety User Requirements Manual Volume 3 – Launch 

Vehicle, Payloads, and Ground Support Systems Requirements 1 July 2004
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3. Policy Overview

Per NASA Policy Directive (NPD) 2570.5E, it is NASA policy that any NASA small satellite mission 

(orbiting systems < 180 kg), whether directly developed and operated by NASA or those supported 

through contracts or other financial agreements, that require the use of the electromagnetic spectrum for 

transmission, reception, or both shall follow the United States and international spectrum regulatory rules 

and processes as referenced in the documents listed in “Authority Documents” as well as all applicable 

international spectrum regulations. 

The following are policy directives from NPD 2570 that directly affect small satellite projects:

• NASA programs shall use frequency bands that are properly allocated for their intended use unless 

permission to operate in another band is granted by the Director of Spectrum Policy and Planning;

• All spacecraft shall be equipped with mechanisms to remotely cease EM emissions unless there is a 

human presence with this direct capability. If the spacecraft has an automatic capability to cease 

transmissions, a waiver of this requirement may be granted by the Director of Spectrum Policy and 

Planning, through the applicable Center Spectrum Manager;

• Non-Federal entities placed in control of NASA transmitters operating in Federal bands (e.g., 2200-

2290 MHz) shall have sufficient contractual constraints to ensure those transmissions are operated in 

accordance with NASA direction; and,

• No frequency assignments for NASA space missions shall be approved for devices which are 

designed or intended to transmit in exclusive passive radio frequency (RF) bands allocated, either 

nationally or internationally, to the radio astronomy service, the Earth exploration- satellite service 

(passive), or the space research service (passive);

• Frequency selection for NASA missions requiring use of 2025-2110 MHz or 2200-2290 MHz shall 

be made by the Goddard Space Flight Center (GSFC) Spectrum Manager in working with the 

respective mission Center's Spectrum Manager;

• Frequency selection for NASA deep space missions shall be made by the Jet Propulsion Laboratory 

(JPL) Spectrum Manager in working with the respective mission Center's Spectrum Manager;

• The Center Directors and the JPL Director shall ensure that all federal RF-related procurements are 

made with the approval of the applicable Center Spectrum Manager and are in compliance with 

NASA and Federal regulatory policies.
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4. Process for Certification, Authorization, and Licensing

All NASA small satellite missions requiring the use of the electromagnetic spectrum for transmission, 

reception, or both should follow the basic process outlined by this Section.

4.1. Establish Contact with NASA Spectrum Management

As a first step, all missions and projects requiring the use of the electromagnetic spectrum should contact 

the associated Center/Facility/Program Spectrum Manager to discuss the electromagnetic spectrum

operations concept and the necessary system certification and frequency authorization (licensing) 

requirements. If no clear NASA Center is involved, the mission or project should contact the NASA 

National Spectrum Program Manager who will designate a responsible Center Spectrum Manager or will 

take the lead role for the project spectrum management function depending upon the circumstances. The 

NASA HQ office of Spectrum Policy and Planning can also assist. The current NASA Center Spectrum 

Managers, NASA National Spectrum Program Manager, and other points of contact are provided on 

NASA’s spectrum website: 

http://www.nasa.gov/directorates/heo/scan/spectrum/txt_NASA_Spectrum_Personnel.html.

The Center/Facility Spectrum Manager or NASA National Spectrum Program Manager will provide 

assistance during all phases of a mission or project from conceptual, pre-proposal efforts through 

formulation and implementation. The Spectrum Manager will support the project at each review in the 

project life cycle and assist with design and spectrum considerations such as frequency selection, 

conformance to regulatory constraints (e.g., emission masks, power flux density (pfd) limits, etc.), and 

other electromagnetic spectrum parameters. A key element of this support is assisting with or preparing 

inputs for spectrum certification as early in the acquisition and procurement cycles as possible, the subject 

of the next sub-sections.1 Appendix C provides additional information concerning frequency selection 

and technical spectrum considerations.

In addition, the Center Spectrum Manager or NASA National Spectrum Program Manager can assist, in 

consultation with NASA and Center contract personnel, with the inclusion of appropriate provisions in 

contracts or other agreements that note the requirement for a small satellite system to obtain frequency 

authorization. Additional information concerning contract and other agreement provisions can be found 

in Section 5 of this Guidance.

4.2. Status: Federal/Non-Federal

The next step in the spectrum authorization and licensing process is the determination of the federal or 

non-federal status of the system since the status defines which regulatory agency and rules are involved 

for frequency authorization, see Figure 1. For stations that “belongs to and operated by” (e.g., effectively

controlled) by a federal agency (e.g., NASA), the use of radio frequencies is authorized by the National 

Telecommunications and Information Administration (NTIA), and if a non-federal frequency is involved, 

NTIA coordinates with the Federal Communications Commission (FCC). For all other situations (i.e., 

non-federal), stations are licensed by the FCC, and if a federal frequency is involved, the FCC coordinates 

with NTIA. The determination of the regulatory status is based on the NASA program or NASA Center 

arrangement including any contractual or other agreement with the system developer and operator. The 

NTIA Manual, see Table 4, provides guidance for the federal/non-federal status. Table 5 outlines a two 

criteria model that may also assist in defining the regulatory case. The Center Spectrum Manager and 

National Spectrum Program Manager, in consultation with the project/mission, should make a 

recommendation on the federal or non-federal status. Additional guidance for contract and agreement 

language is provided in Section 5.

 

1 Although the NASA Center Spectrum Managers can assist all NASA sponsored projects, the NASA Center 

Spectrum Managers can only speak on behalf of NASA and cannot directly represent non-federal (non-NASA) 

systems (see Section 4.2) in FCC proceedings.
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Figure 1: Project/Mission Determination of Spectrum Regulatory Status & Process

Table 4: NTIA Manual: Federal Status Determination

8.2.17 Determining Whether a Station is a Federal Station

1. The following guidelines are to assist in the determination of whether or not a station belongs to and 

is operated by the United States as specified in Section 305(a) of the Communications Act of 1934:

a. The department or agency concerned should be able to exercise effective control over the radio 

equipment and its operation; and

b. The department or agency concerned assumes responsibility for contractor compliance with 

Executive Branch, departmental, or agency instructions and limitations regarding use of the equipment 

and ensures that such instructions and limitations are met when operating under the authority of an 

Executive Branch frequency authorization to the department or agency; and

c. The station should be operated by an employee of the department or agency or by a person who 

operates under the control of the department or agency on a contractual or cooperative agreement basis, 

and who is under supervision of the department or agency sufficient to ensure that Executive Branch, 

departmental, or agency instructions and limitations are met.

2. It is recognized that a federal agency may make a contract arrangement for maintenance or operation 

of a radio station under its control without diminishing the effective control of, or responsibility for, 

such station, provided the appropriate limitations or requirements are specified.

3. Since the foregoing may not cover every case, or where there may be doubt, the determination will 

be made by the department or agency concerned after consultation with the NTIA/FCC as appropriate.

Contact Center/Facility Spectrum Manager

Provide electromagnetic spectrum concept of 

operations and determine regulatory status 

Project/Mission 

Concept & 

Requirements

Federal 

Government 

Station?

No

NTIA Authorization 

Required 

FCC Licensing 

Required 

See NTIA Manual Section 8.2.17 

Criteria such as the following may 

assist in the determination:

- Belongs to (e.g., ownership)

- Operated by (e.g., effective control 

including contractual provisions)

Yes

Follow NTIA 

Process

(see Figure 2)

If system requires NTIA Authorization, 

then it is the responsibility of the NASA 

project/mission to work with the Center 

Spectrum Manager to complete the 

NTIA Process

Follow FCC 

Process

(see Figure 3)

If system requires FCC licensing, then it is the 

responsibility of the non-NASA owner/operator to 

follow the FCC process

(See FCC Document DA: 13-445 Guidance On 

Obtaining Licenses For Small Satellites)
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Table 5: System Status & Spectrum Authorization-Licensing: Two Criteria Model Approach*

Case Belongs To 

(e.g., ownership)

Operated By

(e.g., effective 

control**)

Regulatory 

Agency Frequency Bands & Notes

1 Federal 

(NASA)

Federal 

(NASA) NTIA

Government and Shared frequency bands are 

appropriate

If a non-government or shared frequency is involved, 

NTIA coordinates with the FCC—such use by NASA 

missions is discouraged

2 Federal 

(NASA) Non-Federal FCC

Non-government and Shared frequency bands are 

appropriate

If a government or shared frequency is involved, FCC 

coordinates with the NTIA—such use by NASA 

sponsored missions is highly discouraged

Proof of FCC Authorization provided to NTIA

3 Non-Federal Federal 

(NASA) FCC

Non-government and Shared frequency bands are 

appropriate

If a government or shared frequency is involved, FCC 

coordinates with the NTIA—such use by NASA 

missions is highly discouraged

Such a scenario is uncommon

4 Non-Federal Non-Federal FCC

Non-government and Shared frequency bands are 

appropriate

If a government or shared frequency is involved, FCC 

coordinates with the NTIA—such use by NASA 

missions is highly discouraged

* This approach may assist in defining the regulatory case, but should not be viewed as an explicit definition.

** Effective control may be exercised directly by NASA personnel or through contractual provisions.

In addition, the regulatory status affects the selection of frequencies used since, in the United States, 

frequency bands are designated as federal, non-federal, or shared. Although systems operating under 

certain circumstances, such as experimental, may utilize any frequency, the NTIA and FCC must approve 

and coordinate the frequency selection especially if a system operates under one status (i.e., federal or 

non-federal) but uses frequencies of the other status. It should also be noted that for federal systems, the 

command and control communications link must operate on a protected frequency so that cessation of 

transmissions can be assured. See Appendix C for additional information about frequency status of 

potential bands.

4.3. Federal System: NTIA Certification and Frequency Authorization

For a federal (e.g., NASA) system, the frequency authorization process is well defined by the NTIA 

Manual, and the small satellite project should work directly with the Center Spectrum Manager to pursue 

system spectrum certification and frequency authorization. All small satellite systems, regardless of their 

classification and use of the formal NASA life-cycle process and reviews (e.g., NPR 7120.5, NPR 7123, 

etc.), must obtain certification of spectrum support and frequency authorization for each frequency used.

Figure 2 illustrates the NTIA spectrum process as an overlay to the NASA life-cycle process highlighting 

milestones, such as Stage 2 and Stage 4 certification, that are required at various project milestones 

regardless of NASA system classification. NPR 2570 provides additional information concerning the 

NTIA regulatory process.
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Figure 2: Spectrum Certification Process Overlay on NASA Life-Cycle Process

Frequency 

Authorization

NTIA Process

Notify Center Spectrum Manager of EM spectrum use concept

Stage 1

(if necessary)

Stage 2

(Experimental)

Center/Facility 

Spectrum 

Manager

Is 

Stage 1 

needed

? Yes

Collaboration:

Project - Center/Facility Spectrum Manager

Prepare 

Stage 2 

Request

NPR 2570.5

MCR

NASA Life-Cycle Phases

Project Life-CyclePhasesAgency Reviews

Formulation Implementation Approval for Formulation

Pre-Phase A:Concept Studies

Phase A:Concept and Technology Development

Approval for 

Implementation

Phase B:Preliminary Design & Technology Complementation 

Phase C:Final Design & Fabrication

Phase D:System Assembly, Integration & Test, Launch & Checkout

Phase E:Operations & Sustainment

Phase F:Closeout

SRR CDR/

PRR

SIR/

SAR

ORR/

FRR

Launch CERR DR/

DRR

PFAR

Preliminary assessment of spectrum requirements;Concurrence spectrum needs identified

Design and requisite data submitted for preparation of request for certification of Stage 2 spectrum support;Concurrence project provided requisite EM spectrum data

EM spectrum needs addressed including requisite data for possible Stage 1 Certification;Concurrence project provided requisite EM spectrum data

CDR 

- 60 days

Stage 3

(if necessary)

Is 

Stage 3 

needed

? Yes

Provide measured/as designed parameter updates for request for certification of Stage 4 spectrum support

Stage 4

(Operational)

Prepare 

Stage 4 

Request

Received Stage 2 system certification signed by NTIA

Received Stage 4 system certification signed by NTIA

IRAC/FAS

All requisite radio frequency authorizations are in place

Submit 

frequency 

authorization 

request

Notify the responsible Center Spectrum Manager

Critical event requirements including spectrum considerations identified

Project/Spectrum Manager engineering collaboration

(e.g., frequency selection, emission & pfd limits, etc.)

PDR 

- 60 days

PDR
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4.4. Non-Federal System: FCC Licensing

For non-Federal designated systems affiliated with or supported by NASA, a non-Federal entity with 

ultimate control of the satellite and EM spectrum systems must obtain authorization through the 

appropriate FCC process. FCC Document DA: 13-445, Guidance On Obtaining Licenses For Small 

Satellites (see http://www.fcc.gov/document/guidance-obtaining-licenses-small-satellites), provides 

guidance for following the FCC process, and Figure 3 illustrates the basic options associated with that 

process. For many small satellite missions, a Special Temporary Authority (STA) (lifespans < six (6) 

months) or an experimental license (lifespans < five (5) years) is appropriate; however, other FCC 

licensing mechanisms may be appropriate.

For experimental operations (Part 5), there are no specific bands identified in the FCC rules, and 

operations are on a temporary, non-interference basis, i.e., the operations can neither cause interference 

nor claim protection from interference. Commercial satellite operations (Part 25) may have additional 

protections if operated as a primary allocated service in certain frequency bands.

Although the FCC does not guarantee a specific timeline for considering experimental license requests, 

applicants should expect the FCC to take between 45 and 180 days depending on the complexity of the 

system and the need to coordinate with Federal or other entities based on the selected frequency band. 

When submitting license applications, license requesters should be prepared to respond promptly to any 

questions from the FCC to ensure timely consideration. Specifically, the applicant should be prepared to 

address questions about arrangements for ownership and operation of the satellite, and ultimate control of 

the overall mission, particularly where the mission is closely affiliated with a government entity or 

entities. FCC has increasingly inquired about such information, so it is in the best interest for all to 

clearly provide that information as early in the process as possible.

The NASA mission and project management should ensure during any formal reviews that the nonFederal entity is progressing with obtaining FCC license authorization. While technical assistance can be 

provided by NASA, it is the responsibility of the non-Federal entity to obtain licensing from the FCC.

4.5. International Satellite Notification and Coordination

Under international agreement, any spacecraft which will transmit or receive electromagnetic energy of a 

frequency below 300 GHz shall be filed and, as necessary, coordinated through the International 

Telecommunication Union (ITU), a specialized agency of the United Nations. This treaty-level 

obligation does not contain any unique provisions or exemptions for small satellites; it applies regardless 

of spacecraft size, mass, transmit power, or mission lifetime. These requirements apply to 

electromagnetic spectrum use for communication, radio science, active sensing, and passive sensing. 

There is no requirement or procedure for the filing of electromagnetic spectrum use above 300 GHz (e.g., 

laser communication, infrared imaging, or sensing in the ultra-violet regions).

Under Article 9.1 of the International Radio Regulations, the filing procedure is initiated, “not earlier than 

seven years and preferably not later than two years before the planned [deployment] of the network or 

system.” The filing procedures for a typical NASA mission may require at least a year to complete. 

However, the specific filing requirements vary by frequency band and service. Also, backlogs in the 

processing of satellite filing paperwork at the ITU can and do occur. Therefore, the process could take 

much longer.

It is understood within the NASA spectrum management office that the relatively quick development time 

and often short operational time of small satellites is not always commensurate with the timeframe 

required to properly complete the filing procedure for a spacecraft in the ITU. Parameters (e.g., orbital 

elements) required for the filing process may not be known until shortly before the mission is deployed. 

NASA will generally not prohibit a mission from being deployed strictly because the ITU filing 

procedure has not been completed. However, at a minimum, the initial step, called “Advance 

Publication” should be initiated. If the operational life of the mission is less than the time required to 
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complete the ITU filing process, Advance Publication may be the only step completed. Missions which 

have not fully completed the ITU filing procedure must operate on a non-interference basis; they may 

neither cause interference to nor claim protection from other systems which are properly filed.

For almost all NASA-related satellite operations, only advance publication and notification will be 

required. However, there are a few specific situations in which formal ITU satellite coordination may be 

required. One of these situations includes use of the 450 MHz band for earth-to-space communications, a 

band used by several small satellite systems. See Appendix C for additional band-related information.

Finally, the ITU as part of the 2015 World Radiocommunication Conference is considering these 

processes as they relate to small satellite systems, so the specific processes may be modified in the future.

4.5.1 Satellite Notification for NASA Missions

The ITU satellite filing process should largely be transparent to a NASA (federal designated) mission 

since the requests generated by the responsible Center Spectrum Manager for spectrum certification are 

also used to generate the corresponding satellite filing material sent to the ITU.

The ITU charges processing fees for each of the satellite notification steps, and for NASA missions these 

fees are paid directly by the spectrum management office at NASA HQ. These fees are not passed along 

to the missions themselves.

As the ITU filing procedure is inherently an international process, all earth stations, both U.S. and 

foreign, and/or service areas are required for filing. Many foreign countries have domestic rules only 

allowing earth station operations with spacecraft that are filed, or have at least been Advance Published in 

the ITU and which identify locations within their territory as being associated with that mission. Failure 

to include this information in the ITU filing material could delay cooperative foreign earth stations from 

obtaining their own domestic authorizations. Consequently, NASA missions must ensure that both 

domestic and foreign earth stations and/or service areas are included in the requests for spectrum 

certification.

NASA’s practice is that all NASA space-based missions are filed in the ITU. Additionally, per other 

NASA international and domestic agreements, all mission frequency selections and planned operations 

must be notified and coordinated with other space agencies. Thus, when preparing materials and inputs 

for NTIA or frequency selection by the Spectrum Manager, the small satellite project should:

• Include all needed satellite information necessary for ITU filing as part of the NTIA certification 

request (Center Spectrum Manager will assist); and,

• Include information about all ground stations, both U.S. and international, in the certification request 

so that such information can be used by NASA to insure appropriate frequency selection and 

coordination and to prepare ITU filings.

4.5.2 Satellite Notification for Non-NASA (Non-Federal) Systems

For NASA-supported but non-federal (non-NASA) designated space systems, the mission is responsible 

to follow the FCC and ITU processes for satellite notification and coordination. These types of systems 

are typically not eligible to file as Amateur Radio Satellite systems. For non-federal systems, NASA 

cannot represent or engage in the satellite filing process on behalf of the mission.

The FCC requires that all space-based systems, including small satellite systems, follow the ITU satellite 

notification processes. For non-federal systems seeking experimental licenses, the situation for most

NASA supported, non-federal systems, the FCC will file the necessary information with the ITU based on 

inputs from the applicant. For all systems including those providing commercial services, amateur radio

systems, and experimental systems, the applicant is responsible to prepare a draft notification using the 
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ITU software “SpaceCap,” 2 and to forward it to the FCC as well as to coordinate domestically and 

internationally if necessary.

When preparing materials and inputs for FCC licenses, the small satellite project should:

• Include needed satellite information, as outlined in the FCC Guidance On Obtaining Licenses For 

Small Satellites, necessary for ITU filing; and,

• Include information about all ground stations, both U.S. and international, in the FCC license 

application since, even though international ground stations are not licensed by the FCC, such 

information is required for the ITU filing process.

The ITU charges processing fees for each of the satellite notification steps, and each non-Federal mission 

is required to cover these costs; the FCC does not pay these fees. Systems operating in the amateursatellite service may not need to pay these fees; however, it is very unlikely that NASA-supported 

missions will qualify as amateur systems. The FCC may also request applicants provide a cost recovery 

letter stating payment was completed or committing the applicant to paying the fees incurred as part of

the ITU filing process. Example fees3 include:

• Advanced Publication for non-geostationary systems not requiring coordination = 570 CHF; and,

• Notification for non-geostationary systems not requiring coordination = 7030 CHF.

As noted in previous sections, non-Federal missions should consult the FCC Guidance On Obtaining 

Licenses For Small Satellites and work with the FCC to ensure the ITU-related satellite notification and 

coordination requirements are fulfilled.

 

2 The “SpaceCap” software can be downloaded from the following link: http://www.itu.int/ITU-R/go/spacesoftware/en specifically item “SpaceCap – Space data capture” (http://www.itu.int/en/ITUR/software/Pages/spacecap.aspx). Information about using the SpaceCap software can be found at 

http://www.itu.int/en/ITU-R/space/workshops/2015-prague-small-sat/Presentations/ARS-API_help.pdf and 

http://www.cubesat.org/images/developers/licensing/spacecap_guide.pdf.

3 Per ITU Circular Letter CR/295 (19 Dec 2008) (see http://www.itu.int/ITU-R/go/space-cost-recovery/en)
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Figure 3: Frequency Authorization Process for Non-Federal Systems – FCC Process

Project/Mission Concept & 

Requirements

(Sensor EM use, communication support, 

orbital debris mitigation, etc.)

Eligible 

Amateur 

Radio Use?

Commercial 

Purpose?

Follow Satellite 

Communications

Part 25 Process

Few small satellites have used this process, 

but emerging commercial systems are using it

Follow Amateur 

Satellite Service

Part 97 Process

Follow Experimental 

Service

Part 5 Process

Lifetime 

< 6 months?

Using 

Amateur 

Satellite 

Band?

Submit Special 

Temporary Authority 

(STA)

Most small satellites use this process

Yes

No

Submit STA or Experimental 

license request not later than 30 

days after the date of launch 

vehicle determination, and in no 

event later than 90 days before 

integration of the space station 

into the launch vehicle

Submit 

pre-launch 

ITU 

notification

Yes

Yes

No

Submit Experimental 

License request

Conduct IARU 

Coordination Yes

No

As part of STA or Experimental license request, 

requester should submit:

- Orbital Debris Assessment 

Report (ODAR)

Note: if launch or other changes made after 

initial license application, mission must resubmit orbital debris information

- ITU data (SpaceCap file)

- Cost recovery letter

Submit IARU coordination 

10 months prior to integration 

on launch vehicle

IARU Coordination Letter

FCC review & coordination with 

primary and government (via 

NTIA) users

FCC notifies ITU

FCC issues Frequency 

License/Authorization

Process for FCC licensing—for non-Federal Government stations

(See FCC Document DA: 13-445 Guidance On Obtaining Licenses For Small Satellites)

NTIA & IRAC

Coordination if 

involves US Gov 

frequencies

FCC often requests 

additional information 

during the review process

Note: All experimental licenses are granted on a 

non-interference basis, i.e., the licensed 

operations can neither cause interference nor 

claim protection from interference

Federal 

Government 

Station?

No

Follow FCC 

Process

No

+30 Days

Integration into 

launch vehicle

Launch vehicle 

determination

Recommended to submit STA or 

Experimental license request to 

FCC prior to shown dates

-90 Days

Initial 

Transmission

File further notification following 

launch and not later than 7 days

after commencement of 

transmissions, indicating the status 

of the satellite

File notification of 

termination

+7 Days

Launch Termination

+3 months

-2 weeks to 

-6 months

FCC Recommended Filing Dates

- Submit Orbital Debris Assessment

- Provide information for ITU satellite notification 

(SpaceCap file)

Conduct IARU 

Coordination
27 August 2015

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5. Provisions for Contracts, Grants, and Other Agreements and Announcements

To assist NASA in complying with federal spectrum laws and regulations, NASA contracts, grants, and 

other agreements (e.g., cooperative research and development agreement (CRADA)) should provide clear 

language associated with spectrum regulatory requirements. Appendix B provides additional information 

and example language that can be included in contracts, grants, and other agreements.

In addition, any NASA Announcement of Opportunity, Request for Proposal (RFP), or other such 

solicitation should indicate that any system that uses the electromagnetic spectrum for transmission, 

reception, or both shall follow the United States spectrum regulatory rules and processes as referenced in 

the documents listed in “Authority Documents” as well as all applicable international spectrum 

regulations.

Two items, spectrum authorization and ownership/operations, should be addressed in NASA contracts, 

grants, and other agreements that involve the use of the electromagnetic spectrum for transmission, 

reception, or both.

5.1. Contracts/Agreements: Require Spectrum Authorization

Any NASA contract, grant, or other agreement should clearly state that spectrum authorization is required 

for all systems using the electromagnetic spectrum for transmission, reception, or both;

• As noted by NPR 2570 (Section 3.5), for NASA-funded but non-Federal designated systems, NASA 

requires that the contractor or grantee obtain spectrum licensing through the appropriate FCC 

processes;

• Appendix B provides specific example contract clauses and example agreement language.

5.2. Contracts/Agreements: Indicate Ownership & Operator (Effective Control)

Any NASA contract, grant, or other agreement that involves the use of the electromagnetic spectrum for 

transmission, reception, or both should explicitly indicate the following:

a) Ownership of equipment: Agreement should state whether the system, specifically the 

radiocommunication (transmitter, receiver) system, is owned by NASA (Federal Government) or not.

 For NASA ownership, cases may include equipment developed by a contractor, government 

procured or developed systems provided to a contractor (i.e., Government Furnished Equipment 

(GFE)) but claimed as NASA (Federal Government) property. NASA ownership may also 

include a sub-system that is included as a hosted payload on a non-NASA platform or spacecraft. 

Other cases may also exist.

 For non-NASA (non-Federal Government), cases may include systems developed under contract 

or systems procured by NASA but formally transferred to a non-NASA entity. Other cases may 

also exist.

b) Operations (effective control): Agreement should identify the organization that has effective control of 

the operations of the system specifically the radiocommunication system and the capability to conduct or 

cease transmissions;

 For NASA (Federal) operations, the effective control may be exercised in several ways including, 

but not limited to, a NASA civil servant with direct control of the systems conducting 

radiocommunications or a contract directing a contractor conducting operations to follow 

instructions from NASA.

 For non-NASA (non-Federal) operations, the contractor or other entity exercises sole authority, 

without direction from NASA (Federal Government), over the operations of the system 

specifically the radiocommunications transmissions.
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6. Launch and Deployment Related Requirements: Launch Services and ISS

In addition to the core frequency authorization processes, a small satellite system must also follow launch, 

launch range, International Space Station (ISS), or other launch services spectrum-related requirements 

including timelines and milestones. Such requirements may include obtaining frequency 

licensing/authorization prior to integration on the launch vehicle, safeguards to prevent RF emissions 

until a set time after deployment, exposure or associated electromagnetic interference (EMI) limits, and 

other factors.

This section provides information concerning launch services processes and typical requirements; 

however, each small satellite mission will need to work with the appropriate launch service organization 

to identify the specific requirements for its launch.

6.1. Launch Requirements: Expendable Launch Vehicles (ELVs)

NASA Launch Services Program (LSP), including services through the CubeSat Launch Initiative (CSLI)

(where manifests for each launch opportunity uses the designation “ELaNa [number]” (ELaNa = 

Educational Launch of Nanosatellites)), and other launch and range integration activities often require 

several items associated with electromagnetic emissions to ensure that the small satellite secondary and 

auxiliary payloads do not increase the baseline mission risk. Each launch event is unique, and the rules 

governing secondary and auxiliary payloads are defined by the specific launch vehicle customer, ELV 

developer, and the launch range.

Typically, these launch-related requirements will be stated in a contract or CRADA, launch vehicle 

Interface Control Document (ICD), or other launch-specific document. Each small satellite mission will 

need to work with NASA/LSP or other launch and range integration organization to identify the specific 

launch-related requirements. As an example, an auxiliary payload to be deployed by the future NASA 

Space Launch System (SLS) vehicle, which has the capability to accommodate up to 11 6U cubesats, 

would need to comply with the SLS Interface Definition Requirements Document (IDRD).

Launch-related requirements may include:

• Frequency Licensing/Authorization: The mission must obtain frequency licensing/authorization prior 

to integration on the launch vehicle. The required date prior to launch or launch vehicle will be set 

for each mission and may vary depending upon on the specific launch vehicle integration process;

• Inhibit and Delayed Communications: The small satellite (e.g., cubesat) shall not generate or transmit 

any signal from the time of integration into the launch container (e.g., PPOD) through a specified

time period (e.g., 45 minutes) after on-orbit deployment (Note: time period depends on launch vehicle 

or system); and,

• Permissible Exposure Limit (PEL) & Electromagnetic Interference (EMI) Compatibility: Some 

launch systems and ranges may require compliance with PEL and EMI standards or requirements

(e.g., ANSI/IEEE C95.1) to ensure that personnel and equipment are not exposed to hazardous energy 

levels.

Other types of requirements (e.g., limits on propulsion systems, hazardous materials, etc.) may also apply, 

so each small satellite developer is encouraged to work with the launch integration and range activities as 

soon as known since launch-related requirements will affect the specification and design of the small 

satellite systems. The NASA/LSP Poly-Picosatellite Orbital Deployer (PPOD) and CubeSat 

Requirements Document (LSP-REQ-317.0) provides an example set of requirements. Appendix C

provides additional information concerning these and related design considerations.
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6.2. ISS Deployment Requirements

For any small satellite systems (e.g., cubesat) to be deployed from the ISS such as those deployed by 

Nanoracks or the Cyclops system, the small satellite system must work with the ISS payload manager, 

follow the ISS risk assessment processes, and work with the Progrm (ISS) Spectrum Manager, currently 

the JSC Spectrum Manager, in regards to the system requirements imposed by ISS.

Required actions include:

• ISS Safety Review Process: The mission must work with the ISS payload integration office and the 

ISS spectrum management activity to conduct two analyses:

 EM Hazard/Keep out Zone (e.g., human exposure, equipment EMI) [NASA-STD-3000 116, 

NASA-STD-3001, section 5, SSP 30237, SSP 50237];

 EM Compatibility to ensure no RFI to ISS EM systems [Various RF system performance 

specifications, including SSP 30237 and SSP 50237];

• Frequency Licensing/Authorization: The mission must obtain frequency licensing/authorization prior 

to integration on the launch vehicle. Preferably, the mission should obtain its frequency 

licensing/authorization prior to integration in the deployment mechanism (e.g., NanoRacks). [SSP 

57000, 57003, 57004]

• Inhibit and Delayed Communications: The small satellite (e.g., cubesat) shall not generate or transmit 

any signal from the time of integration into the launch container (e.g., NanoRacks) through [45] 

minutes after on-orbit deployment.

Appendix C provides additional information concerning these and related design considerations. 
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7. Processes Affiliated with Spectrum Authorization

Small satellite systems must follow other regulatory processes associated with space systems and such 

processes may also be a requirement for spectrum licensing and authorization. Although details for 

orbital debris mitigation and remote sensing licensing are not covered in this Guidance, these processes 

are cited as they are applicable for NASA-affiliated small satellite systems.

7.1. Orbital Debris Mitigation

Several standards and practices address orbital debris mitigation:

• Federal/NASA Systems: Per U.S. Government Orbital Debris Mitigation Standard Practices, 

“Programs and projects will assess and limit the amount of debris released in a planned manner 

during normal operations;” (NASA Standard 8719.14A, NASA Handbook 8719.14)

• NASA Systems: Per NPR 8715.6A, NASA Procedural Requirements for Limiting Orbital Debris, 

NASA’s objective is “to limit the generation of debris in Earth,” and, thus, the “NASA 

Program/Project Manager shall ensure that all NASA and NASA-funded or NASA-controlled 

spacecraft and launch vehicles are designed to be disposed of in accordance with” various activities 

and standards, as outlined in the NPR;

• Non-NASA (non-Federal) systems: As part of the FCC licensing process, small satellite systems must 

provide information and analysis concerning orbital debris mitigation. Guidance for such information 

is discussed in the FCC Rules and Document DA: 13-445, Guidance On Obtaining Licenses For 

Small Satellites (see http://www.fcc.gov/document/guidance-obtaining-licenses-small-satellites). In 

addition, as part of the NOAA authorization of remote sensing, NOAA also requires non-Federal 

systems to address orbital debris standards—see subsequent section on Remote Sensing Licensing;

NASA provides useful information concerning orbital debris mitigation standards and also provides 

software for missions, including small satellite missions, to assess their potential for orbital debris: see 

http://orbitaldebris.jsc.nasa.gov/index.html.

Although not explicitly required by policy or licensing rules at this time, missions may be asked by the 

FCC or other organizations to designate a contact for receiving conjunction messages and other 

operational information and to register with U.S. Strategic Command’s (USSTRATCOM) Joint Space 

Operations Center (JSpOC) at: https://www.space-track.org/documentation#odr.

All missions should check on the latest NASA and other organization’s orbital debris-related standards 

and policies as many of them are under review and subject to change.

7.2. Private Remote Sensing Space System Licensing

Pursuant to the National and Commercial Space Programs Act (NCSPA or Act), 51 U.S.C. § 60101, et 

seq,, private space-based remote sensing systems require licensing, and such licensing responsibilities 

have been delegated from the Secretary of Commerce to the National Oceanic and Atmospheric 

Administration (NOAA). Per requirements in NCSPA, NOAA also requires imaging system licensees to

assess and minimize the amount of orbital debris released during the post-mission disposal of their

satellite(s).

For specific information, see:

• http://www.nesdis.noaa.gov/CRSRA/index.html; and, 

• http://www.nesdis.noaa.gov/CRSRA/licenseHome.html.

Federally owned remote sensing systems are not required to follow this remote sensing licensing process; 

however, all systems should review the NOAA guidance in making the determination whether or not such 

licensing is required.
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Appendix A. Acronyms and Definitions 

AP Advanced Publication

CRADA Cooperative Research and Development Agreement

CSLI CubeSat Launch Initiative

ELaNa Educational Launch of Nanosatellites

EM Electromagnetic

EMI Electromagnetic Interference

FAR Federal Acquisition Regulation

FAS Frequency Assignment Subcommittee

FCC Federal Communications Commission

GSFC Goddard Space Flight Center

HEOMD Human Exploration and Operations Mission Directorate

GFE Government Furnished Equipment

IARU International Amateur Radio Union

ICD Interface Control Document

IRAC Interdepartment Radio Advisory Committee

ISS International Space Station

ITU International Telecommunication Union

JPL Jet Propulsion Laboratory

JSC Johnson Space Center

JSpOC Joint Space Operations Center

KSC Kennedy Space Center

LSP Launch Services Program

NCSPA National and Commercial Space Programs Act

NOAA National Oceanic and Atmospheric Administration

NPD NASA Policy Directive

NPR NASA Procedural Requirements

NTIA National Telecommunications and Information Administration

ODAR Orbital Debris Assessment Report

PEL Permissible Exposure Limit

pfd Power Flux Density

PPOD Poly-Picosatellite Orbital Deployer

RFI Radio Frequency Interference

RFP Request for Proposal

RR Radio Regulations

SCaN Space Communications and Navigation

SFCG Space Frequency Coordination Group

SM Spectrum Manager

SMD Science Mission Directorate

SPS Spectrum Planning Subcommittee

SSS Space Systems Subcommittee

USSTRATCOM U.S. Strategic Command
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Appendix B. Spectrum-Related Provisions for Contracts and Other Agreements

As discussed in Section 5, to assist NASA in complying with federal spectrum laws and regulations, 

NASA contracts, grants, and other agreements (e.g., cooperative research and development agreements

(CRADAs)) should provide clear language associated with spectrum regulatory requirements. The 

following sub-sections provide example language that can be included in contracts, grants, and other 

agreements.

B.1 Language for Spectrum Authorization/Frequency Licensing

Given that any NASA contract, grant, or other agreement should clearly state that spectrum authorization 

is required for all systems using the electromagnetic spectrum for transmission, reception, or both, the 

following identifies existing contract clauses and example language.

a. Contracts

The following Federal Acquisition Regulation (FAR) clauses within the NASA FAR supplement4are 

available for inclusion in contracts explicitly highlighting the requirement to obtain spectrum 

authorization:

Subpart 1823.71—Frequency Authorization

1823.7101 Contract clause.

The contracting officer shall insert the clause at 1852.223–71, Frequency Authorization, in 

solicitations and contracts calling for developing, producing, constructing, testing, or operating a 

device for which a radio frequency authorization is required.

1823.7102 Procedures.

The contracting officer shall obtain the necessary frequency authorization and other procedural details 

from the installation’s spectrum manager.

1852.223-71 Frequency Authorization.

 As prescribed in 1823.7101, insert the following clause:

FREQUENCY AUTHORIZATION (DECEMBER 1988)

 (a) Authorization of radio frequencies required in support of this contract shall be obtained by the 

Contractor or subcontractor in need thereof.

 (b) For any experimental, developmental, or operational equipment for which the appropriate 

frequency allocation has not been made, the Contractor or subcontractor shall provide the technical 

operating characteristics of the proposed electromagnetic radiating device to the Contracting Officer 

during the initial planning, experimental, or developmental phase of contractual performance. 

Procedures furnished by the Contracting Officer shall be followed in obtaining radio frequency 

authorization.

 (c) This clause, including this paragraph (c), shall be included in all subcontracts that call for 

developing, producing, testing, or operating a device for which a radio frequency authorization is 

required.

If the contract does not need to use the pre-defined FAR clauses, a statement such as the following may 

be sufficient:

 

4 Referenced at http://www.hq.nasa.gov/office/procurement/regs/nfstoc.htm and specifically at 

http://www.hq.nasa.gov/office/procurement/regs/1823.htm#23_71 (as of 27 April 2015)
27 August 2015

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“The Contractor shall arrange for radio frequency licensing in advance of launch date. The Contractor 

shall provide a copy of the frequency license prior to launch.”

The example language from the following “Other Agreements” section can also serve as models for 

contract requirements.

b. Other Agreements

The NASA/CSLI program has a template CRADA5 and Statement of Work that provide a model for any 

NASA grant or other agreement highlighting the need to obtain spectrum authorization:

1. CRADA Clause (with minor modification):

## RADIOFREQUENCY AUTHORIZATION

##.1 Compliance. The Parties agree that use of radiofrequencies for any purpose, such as spacecraft 

tracking and control, information (data) transmission to and from the spacecraft, or sensors with 

active radiofrequency emissions, will be in accordance with all U.S. laws and regulations, and with 

the International Radio Regulations promulgated by the International Telecommunication Union 

(ITU). The COLLABORATOR shall obtain radiofrequency authorization from the Federal 

Communications Commission (FCC) in accordance with the Rules and Regulations, Title 47, of the 

Code of Federal Regulations.

2. Appendix in Statement of Work

##. RESPONSIBILITIES AND MILESTONES

##. COLLABORATOR will use reasonable efforts to perform the following tasks:

##. COLLABORATOR shall provide to NASA documentation required to demonstrate compliance 

with regulatory obligations regarding radiofrequency authorization. Specifically, the 

COLLABORATOR shall provide: (1) A detailed technical description of the spacecraft, including 

description of its communications system; (2) a copy of the application for radiofrequency 

authorization as submitted to the FCC, and a copy of the radiofrequency authorization when obtained; 

(3) a copy of the information specified in Appendix 4 of the International Radio Regulations, which is 

required by the FCC for compliance with the frequency assignment notification and recording 

procedures of the International Radio Regulations; and (4) if amateur satellite service frequencies are 

employed, a copy of the Amateur Satellite Frequency Coordination Request as submitted to the 

International Amateur Radio Union (IARU), and a copy of the IARU response when obtained.

B.2 Language for Ownership and Operation (Effective Control)

Noting that any NASA contract, grant, or other agreement that involves the use of the electromagnetic 

spectrum for transmission, reception, or both should explicitly indicate the ownership and operator 

(effective control) of the radiocommunication (transmitter, receiver) system, the following provide 

example language for inclusion in contracts and other agreements.

a. Ownership of equipment – Contracts & Other Agreements

Besides standard contract language concerning government property, the following example clauses may 

be helpful to explicitly state the ownership of equipment:

1. Government Owned: “Any experimental, developmental, or operational equipment that involves the

use of the electromagnetic spectrum for transmission, reception, or both that is developed, procured, or 

furnished by the Government under this [contract/agreement] shall be owned by NASA”;

 

5 See http://www.nasa.gov/627971main_2012_02_13_CubeSat_CRADA_Template.docx (as of 27 April 2015)
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2. Non-Government Owned: “NASA does not claim ownership of any experimental, developmental, or 

operational equipment that involves the use of the electromagnetic spectrum for transmission, reception, 

or both that is developed or procured under this [contract/agreement].”

b. Operations (effective control) – Contracts & Other Agreements

Contract and agreement language needs to express which organization, NASA or a supporting

organization, has effective control whether via direction from NASA or whether the NASA-supported 

organization retains sole control without direction from NASA. Such language may include:

1. Government Operated: “Any experimental, developmental, or operational equipment that involves the

use of the electromagnetic spectrum for transmission, reception, or both as part of this 

[contract/agreement] shall be operated by NASA personnel”;

2. Government Directed (NASA retains effective control): “Any experimental, developmental, or 

operational equipment that involves the use of the electromagnetic spectrum for transmission, reception, 

or both that is operated under this [contract/agreement] shall be operated per direction from NASA 

whereby NASA retains effective control including the right to direct the shut down of any transmission, 

reception, or both in the event that there are any problems, such as radio communication interference 

issues”;

3. Non-Government Operated: “the [contracting organization’s] use of any experimental, developmental, 

or operational equipment that involves the use of the electromagnetic spectrum for transmission, 

reception, or both that is operated under this [contract/agreement] shall be under [contracting 

organization’s] discretion and control; NASA does not claim any authority over the operations of the 

electromagnetic spectrum systems.”

c. Communications with Regulatory Agencies

If necessary, the regulatory agencies (NTIA, FCC) may require a letter from NASA and the contracting 

organization indicating the ownership or operator (effective control) for the small spacecraft, such a letter 

may consider using the following language when the operations are conducted by a non-government 

operator:

“The purpose of this letter is to confirm [Operating Organization’s] role in operating the [mission 

name] spacecraft, currently manifested for launch in [date]. [Operating Organization] is the 

contracted mission control organization for the [mission name]. This letter acknowledges that the 

mission operations team at [Operating Organization] will exercise full control of the operational 

aspects of these experiments/mission. This includes the ability – without seeking permission from or 

consulting with NASA – to shut down any experimental, developmental, or operational equipment 

that involves the use of the electromagnetic spectrum for transmission, reception, or both in the event

that there are any problems, such as radio communication interference issues.

Please contact [Point of Contact] if you have any questions or comments regarding [Operating 

Organization’s] role. [Operating Organization] looks forward to continued operation as per all FCC 

requirements and regulations.”
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Appendix C. Design Considerations and Potential Frequency Bands

[Note: The following section is organized, essentially, as a concise “handbook” for a mission developer 

and, as such, provides details beyond what is necessary for frequency authorization.]

The design and operation of small satellite communication and sensors (i.e., any system that involves the

use of the electromagnetic spectrum for transmission, reception, or both) need to consider a variety of 

factors including spectrum regulations, network services, spaceflight equipment availability, and others 

depending upon the mission needs. Descriptions of the functionality and emission characteristics (e.g., 

emission levels both in-band and out-of-band, etc.) of systems may also be required as part of the 

frequency licensing and authorization processes. This section provides guidance on several of the 

spectrum-related items including potential frequency bands. This section is provided for information only 

and should not be viewed as a requirements document.

C.1 Mission Operations Planning

Mission developers are encouraged to: i) Prepare a mission operations plan to guide and define needed 

access to the electromagnetic spectrum; and, ii) Seek spectrum guidance (as noted in Section 4), before 

designing or procuring any spectrum dependent systems. Such preliminary planning is essential to avoid 

spectrum regulatory challenges that have affected a number of small satellite missions.

Such planning includes understanding a mission’s basic operational needs, including data and 

communication needs, such as:

• What type of radiofrequency sensors (if any) will the mission need? (Such systems could be passive 

sensors (e.g., radiometers) or active sensors (e.g., altimeters, radars, etc..)

• How often does the mission need to receive telemetry from the spacecraft and instruments?

• How often does the mission need to command the spacecraft and instruments?

• How much data (data volume) and how quickly (latency) does the mission need to transport data from 

the spacecraft to final locations (e.g., Mission Operations Center, Science Operations Center, etc.)?

Further, a mission should understand several other factors:

• What type of mission is the system? Is the mission performing:

 Earth remote sensing (e.g., Earth Exploration Satellite Service, Meteorological Satellite Service), 

or

 Exploration of the sun, planetary bodies, or universe (e.g., Space Research Satellite Service), or

 Technology demonstrations (e.g., Space Research, Space Operation Services or experimental).

• Is the mission Federal or Non-Federal? (See Section 4)

As part of the design process, a mission will need to consider whether it will operate its own 

communication support systems (e.g., ground sites) or use space relay or ground network services from 

other organizations (e.g., NASA’s SCaN networks, commercial networks, etc.) which will also dictate 

which frequency bands are available.

Given an understanding of these needs and status, a mission should then seek guidance from the spectrum 

community and, if a NASA-affiliated mission, from NASA Center Spectrum Managers, before designing 

or procuring any spectrum dependent systems.
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C.2 Network Support and Spaceflight Hardware Availability

For mission operations, systems typically need to connect with supporting ground or space-based 

communication stations and networks. A system designer needs to consider the desired services, 

available earth station equipment, space communication network support, and available spaceflight 

hardware. Mission support for small satellites has ranged from a single mission-procured earth station to 

use of NASA’s space communication networks. 

Use of NASA’s space communication assets are covered by NASA policy and practices, and are outside 

the scope of this guidance. However, NASA’s Space Communication and Navigation (SCaN) networks 

and the NASA GSFC Wallops Flight Facility (WFF) range ground station, can support small satellite 

systems, and those missions with some level of NASA sponsorship may wish to contact these systems to 

explore possible operational support:

• SCaN Networks including the Deep Space Network (DSN), Near Earth Network (NEN), and the 

Space Network (SN) (i.e., TDRSS). Point of Contact: 

 Gary Morse, SCaN Mission Commitment Manager

 202.358.0504

 gary.a.morse@nasa.gov

• GSFC WFF Range Ground Station. Point of Contacts:

 Tom Johnson

 757.824.2560

 thomas.e.johnson@nasa.gov

Table 6 and Table 7 indicate frequency bands supported by NASA network systems.

C.3 Operational Considerations

As part of a mission’s design and implementation, a variety of operational considerations for 

radiofrequency systems need to be considered, as outlined in this section.

a. Inhibit and Delayed Communications

Most launch vehicle and associated services, including small satellite launches provided on the ISS, 

require small satellites, including cubesats, to inhibit any radiofrequency emissions until a period of time 

after deployment from the launch vehicle or ISS. To satisfy this requirement, a small satellite (e.g., 

cubesat) may use different mechanisms such as a deployment switch to physically cut off the cubesat 

batteries from the rest of the satellite or other mechanism. Since there is typically no access to the small 

satellites at the launch site, there are no radiated emissions from the small satellites at the launch site.

Each small satellite mission will need to work with the launch services and range organization associated 

with its launch to identify the specific requirements. Example requirements include:

• The small satellite shall not generate or transmit any signal from the time of integration into the 

deployment mechanism (often months in advance of launch) through 45 minutes after on-orbit 

deployment;

• RF Inhibits: The small satellite shall be designed to meet at least one of the following requirements to 

prohibit inadvertent RF transmission:

 Transmission Power Limit: The small satellite will have one RF inhibit and have a RF power 

output of no greater than 1.5W at the transmitting antenna’s RF input;

 Dual Independent RF Inhibits: The small satellite will have two independent RF inhibits.
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b. Control and Cessation of Emissions

The U.S. regulatory agencies, FCC and NTIA, require, as does NASA policy, that all space systems, 

including small satellites, maintain control of transmissions including the capability to cease 

transmissions. For example, per NTIA Manual (Section 8.2.32), “The use of frequencies by space 

stations will be authorized only in those cases where such stations are equipped so as to ensure the ability 

to turn on or to provide immediate cessation of emissions by telecommand.” Similarly, per No. 22.1 of 

the ITU Radio Regulations, “Space stations shall be fitted with devices to ensure immediate cessation of 

their radio emissions by telecommand, whenever such cessation is required under the provisions of these 

Regulations.” Consequently, the design of any communication or active sensor system on a small 

satellite must include such a capability and report on that capability in the frequency licensing or 

authorization application. Several methods exist that can satisfy this requirement including:

• Telecommand (via an uplink command process) that can schedule or directly command transmission 

and cessation of emissions (a requirement for all Federal and NASA space systems);

• A “fail-safe” operating mode where the satellite can transmit only while an uplink is active and 

detected; (to accomplish this, a system could wire the transmitter directly to the satellite TT&C link 

carrier detect, that way when the TT&C link is lost at the satellite (either by going out of view or by 

turning off the ground station radio) then the satellite transmitter immediately ceases, with no delay); 

and,

• Indirect methods (e.g., battery life, timing devices, etc.) that will ensure definite cessation of 

emissions.

In addition, space systems may not transmit when not in view of an associated earth station or service 

area, as per No. 15.1 of the ITU Radio Regulations, “All stations are forbidden to carry out unnecessary 

transmissions...” Consequently, the operational plans for small satellite systems should follow this 

directive.

Each small satellite project will need to work with the Center Spectrum Manager or other spectrum 

advisor to discuss the documentation of such capabilities in the licensing or authorization process.

c. Permissible Exposure Limit (PEL) & Electromagnetic Interference (EMI) Compatibility

Some launch systems and ranges may require compliance with PEL and EMI standards or requirements to 

ensure that personnel and equipment are not exposed to hazardous energy levels. For example, a system 

may be required to meet range requirements, such as those defined in AFSPCMAN 91-710, Range Safety 

User Requirements Manual Volume 3 – Launch Vehicle, Payloads, and Ground Support Systems 

Requirements. As specified in the range document, an example requirement is limiting exposure as 

defined in ANSI/IEEE C95.1, Safety Levels with Respect to Human Exposure to Radio Frequency 

Electromagnetic Fields, 3 kHz to 300 GHz. 

As noted in previous sections, each launch event is unique, and the rules governing secondary and 

auxiliary payloads are defined by the specific launch vehicle customer, ELV developer, and the launch 

range; thus, each small satellite mission needs to engage the launch and range activities as soon as known 

to establish the specific PEL and EMI requirements for its mission.

d. Security

Each mission, considering the mission goals and associated mission-level requirements, needs to 

determine its link and data security requirements especially in regards to commanding and controlling the 

spacecraft. Devices, such as encryption systems, exist and are compatible with small satellite form 

factors and are often implemented in-line with the command and data handling and communication 

systems. Such security systems, although not necessary for regulatory requirements in controlling 
27 August 2015

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spacecraft emissions, may be useful to demonstrate control. As noted, each mission needs to make it’s 

own determination in implementing security systems.

C.4 Frequency Band Selection & Technical Parameter Constraints

As with all systems using the electromagnetic spectrum, the choice of a specific frequency will depend on 

the desired service (e.g., communications, active sensor, etc.), spectrum regulations including the status 

(e.g., Federal, non-Federal) and service designation of a system, the characteristics of a frequency band 

(e.g., bandwidth, propagation), the availability of network services whether via ground apertures or spacebased relays, spaceflight equipment availability and physical constraints (e.g., size, mass, power), and 

cost. To date, small satellites have used many different frequency bands; however, the long-term viability 

for some of the bands is not guaranteed, so careful consideration should be made in selecting a frequency. 

Each small satellite project should work with the Center Spectrum Manager or other spectrum 

representative to help select the specific frequency band.

Spectrum regulations affecting frequency selection include:

• The need for (or not) regulatory protection (see below for additional information); and,

• Constraints on emissions (e.g., out-of-band emissions, power flux density (pfd) limits, etc.) (see 

below for additional information).

Table 6 and Table 7 list a variety of potential frequency bands that may be or have been used for small 

satellite operations and communications. This listing should only be viewed as informational and does 

not indicate recommendations or requirements.

Many frequency bands are available for passive and active sensors; projects are encouraged to work with 

Center Spectrum Managers to assist with identifying appropriate bands for sensors.

a. Regulatory Protection and Status

To date, most small satellite systems operate with an experimental license on a secondary noninterference basis. That is, the system must accept any interference from and must not cause interference 

to systems that operate on a primary basis. While such secondary operations may be appropriate for 

experimental or demonstration projects, such secondary status operations may not be acceptable or 

permitted for long-term exploration or science missions. Also:

• For experimental licensed operations (i.e., non-primary), there are no specific bands identified in the 

FCC rules, and operations are on a temporary, non-interference basis, i.e., the operations can neither 

cause interference nor claim protection from interference; and,

• For Federal systems, per NTIA 8.2.53, command and control must be accomplished in frequency 

bands allocated on a primary basis for this purpose (e.g., and Earth-to-space allocation for an 

appropriate space service) and for which fully protected operations are approved. “The tracking, 

telemetry, and telecommand operations of a satellite network shall have Stage 4 NTIA spectrum 

certification and frequency assignments with operational station class(es) before the launch of the 

spacecraft.”

b. Technical Parameter Constraints

Spectrum regulations often limit space system emissions to facilitate operations of other systems 

operating in the band or in adjacent bands. Such limits may include spectral masks for emissions outside 

of the needed bandwidth and power flux density (pfd) limits for emission received at the earth (often 

specified per an elevation angle from the horizon). These limits, defined in the international ITU Radio 

Regulations and in U.S. FCC and NTIA regulations, are often specified depending upon the specific 
27 August 2015

22

frequency band or mission service designation. Each small satellite project will need to work with the 

Center Spectrum Manager or other representative to identify these emission requirements.

Example technical constraints include:

• Earth Station Power Limits: To protect other systems, some bands limit an Earth station’s equivalent 

isotropically radiated power (EIRP) toward the horizon and specified antenna elevation angles above 

the horizontal plane;

• Power flux density (pfd) limits: To protect terrestrial system operations, many frequency bands have 

limits on the power incident on the Earth for a reference bandwidth

 Example: For 460-470 MHz, the power flux density produced at the Earth’s surface by any space 

station in this band shall not exceed -152 dBW/m2/4 kHz;

• Out of band emissions (spectral masks): To protect systems operating in adjacent bands, many system 

types and frequency bands have limits on out of band emissions (Filtering and other signal shaping 

techniques may be required);

• Bandwidth constraints: some frequency bands constrain transmission bandwidths or follow channel 

plans

 Example: Per U.S. policy, signals in the 2200-2290 MHz band are limited to 5 MHz or less;

 Example: Per international space agency agreement, signals (space research service) in the 8450-

8500 MHz band are limited to 10 MHz or less.
27 August 2015

23

Table 6: Potential Frequency Bands for Small Satellite Communications – Below 2 GHz

(selected bands only, others possible)

Band%Lower+

(MHz)

Band%Upper+

(MHz) Status Uplink(Earth'to'space)

Downlink

(space'to'Earth) Considerations Applicable+US+Allocations+&+Footnotes

137 138 Gov4&4Non'Gov X

SPACE4OPERATION4(space'to'Earth)

METEOROLOGICAL'SATELLITE4(space'to'Earth)

MOBILE'SATELLITE4(space'to'Earth)

SPACE4RESEARCH4(space'to'Earth)

144 146 Non'Gov X X

IARU4no4longer4coordinating4"experimental"4

license4use;4thus,4only4amateur4systems4

permitted

AMATEUR4SATELLITE

148 149.9 X subject4to4coordination4under4RR4Art.494Sect.4II4&4

shared4terrestrially

235 322 Gov4Only X X Not4available4for4NASA4or4non'Federal4systems MOBILE'SATELLITE4via4US4footnote

Military4services4only

335.4 399.9 Gov4Only X X Not4available4for4NASA4or4non'Federal4systems MOBILE'SATELLITE4via4US4footnote

Military4services4only

399.9 400.05 Gov4&4Non'Gov X

NASA4ground4support4possible4for4qualifying4

missions

Federal4systems4limited4to4ground4stations4

operating4with4non'Federal4space4systems

MOBILE'SATELLITE4(Earth'to'space)

(non'voice,4LEO4systems)

400.15 401 Gov4&4Non'Gov X NASA4ground4support4possible4for4qualifying4

missions

METEOROLOGICAL'SATELLITE4(space'to'Earth)

MOBILE4SATELLITE4(space'to'Earth)

SPACE4RESEARCH4(space'to'Earth)

Space4Operation4(space'to'Earth)

401 402 Gov4&4Non'Gov X X NASA4ground4support4possible4for4qualifying4

missions

SPACE4OPERATION4(space'to'Earth)

EARTH4EXPLORATION'SATELLITE4(Earth'to'space)

METEOROLOGICAL'SATELLITE4(Earth'to'space)

402 403 Gov4&4Non'Gov X NASA4ground4support4possible4for4qualifying4

missions

EARTH4EXPLORATION'SATELLITE4(Earth'to'space)

METEOROLOGICAL'SATELLITE4(Earth'to'space)

435 438 Non'Gov X X Must4coordinate4with4IARU

Possible4use4for4beacon4"services" Amateur4Satellite4(via4footnote)

449.75 450.25 Gov4&4Non'Gov X

NASA4ground4support4possible4for4qualifying4

missions

International4coordination/nofication4required

Space4operation4service4(Earth'to'space)

Space4research4service4(Earth'to'space)

(via4footnote)

460 470 Gov4&4Non'Gov X NASA4ground4support4(WFF4range)4possible4for4

qualifying4missions;4PFD4Limits4apply

Meteorological'satellite4(space'to'Earth)

Earth4exploration'satellite4service4(via4footnote)

902 928 Non'Gov X X

Numerous4unlicensed4operations,4so4ground4

support4may4encounter4interference4depending4

upon4location

No4allocation;4available4for4experimental4use4only

1615 1617.5 Gov4&4Non'Gov X

(via4space4relay)

X

(via4space4relay)

Commercial4service4(Globalstar);4experimental4

use4only

MOBILE'SATELLITE4(Earth'to'space)

Mobile'satellite4(space'to'Earth)

1618.7 1626.5 Gov4&4Non'Gov X

(via4space4relay)

X

(via4space4relay)

Commercial4service4(Iridium);44experimental4use4

only

MOBILE'SATELLITE4(Earth'to'space)

Mobile'satellite4(space'to'Earth)
27 August 2015

24

Table 7: Potential Frequency Bands for Small Satellite Communications – Above 2 GHz

(selected bands only, others possible)

Note: other frequency bands above 35 GHz are possible for use.

Band%Lower+

(MHz)

Band%Upper+

(MHz) Status Uplink(Earth'to'space)

Downlink

(space'to'Earth) Considerations Applicable+US+Allocations+&+Footnotes

2025 2110 Gov4&

Non'Gov X

NASA4communication4support4possible4for4qualifying4

missions4(NASA4Space4Communication4Networks)

Non'Federal4subject4to4conditions4on4a4case'by'case4

basis

SPACE4OPERATION4(Earth'to'space)4(space'to'space)

EARTH4EXPLORATION'SATELLITE4(Earth'to'space)4

(space'to'space)

SPACE4RESEARCH4(Earth'to'space)4(space'to'space)

2110 2120 Gov4Only X

(deep4space)

NASA4communication4support4possible4for4qualifying4

missions4(NASA4Space4Communication4Networks)

Non'Federal4subject4to4conditions4on4a4case'by'case4

basis

SPACE4RESEARCH4(deep4space)4(Earth'to'space)4

(Goldstone,4CA)

2200 2290 Gov4Only X

NASA4communication4support4possible4for4qualifying4

missions4(NASA4Space4Communication4Networks)

pdf4limits4apply

SPACE4OPERATION4(space'to'Earth)4(space'to'space)

EARTH4EXPLORATION'SATELLITE4(space'to'Earth)4

(space'to'space)

SPACE4RESEARCH4(space'to'Earth)4(space'to'space)

2290 2300 Gov4&

Non'Gov

X

(deep4space)

NASA4communication4support4possible4for4qualifying4

missions4(NASA4Space4Communication4Networks)

pdf4limits4apply

SPACE4RESEARCH4(deep4space)4(space'to'Earth)

2400 2450 Non'Gov X X

Ubiquitous4unlicensed4operations,4so4ground4support4

may4encounter4interference4depending4upon4

location

Amateur4Satellite4(via4footnote)

3400 3410 Non'Gov X X Secondary Amateur4Satellite4(via4footnote)

7145 7190 Gov4&

Non'Gov

X

(deep4space)

Non'Federal4use4on4a4Secondary4basis;4

Limited4to4Goldstone,4CA SPACE4RESEARCH4(deep4space)4(Earth'to'space)

7190 7235 Gov4Only X SPACE4RESEARCH4(Earth'to'space)

8025 8400 Gov4&

Non'Gov X

NASA4communication4support4possible4for4qualifying4

missions4(NASA4Space4Communication4Networks)

Non'Federal4subject4to4conditions4on4a4case'by'case4

basis

pdf4limits4apply

EARTH4EXPLORATION'SATELLITE4(space'to'Earth)

METEOROLOGICAL'SATELLITE4(Earth'to'space)

Mobile'satellite4(Earth'to'space)4(no4airborne4

transmissions)

8400 8450 Gov4&

Non'Gov

X

(deep4space)

NASA4communication4support4possible4for4qualifying4

missions4(NASA4Space4Communication4Networks)

Non'Federal4subject4to4conditions4on4a4case'by'case4

basis

pdf4limits4apply

SPACE4RESEARCH4(deep4space)4(space'to'Earth)

8450 8500 Gov4&

Non'Gov X

Civilian4space4agencies'4policy4to4limit4bandwidth4to4

104MHz

pdf4limits4apply

SPACE4RESEARCH4(space'to'Earth)

14800 1535 Gov4&

Non'Gov X X

NASA4communication4support4possible4for4qualifying4

missions4(NASA4Space4Communication4Networks)

Non'Federal4subject4to4conditions4on4a4case'by'case4

basis

Space4research4(Primary4in4US)

22550 23550 Gov4&

Non'Gov

NASA4communication4support4possible4for4qualifying4

missions4(NASA4Space4Communication4Networks)

Future4Space4Research/EESS4earth'to'space4

allocation4likely

INTER'SATELLITE

25500 27000 Gov4&

Non'Gov X

NASA4communication4support4possible4for4qualifying4

missions4(NASA4Space4Communication4Networks)

Non'Federal4subject4to4conditions4on4a4case'by'case4

basis

Inter'satellite4service425.25'27.54GHz

EARTH4EXPLORATION'SATELLITE4(space'to'Earth)

INTER'SATELLITE

SPACE4RESEARCH4(space'to'Earth)

31800 32300 Gov4&

Non'Gov

X

(deep4space)

NASA4communication4support4possible4for4qualifying4

missions4(NASA4Space4Communication4Networks)

Non'Federal4subject4to4conditions4on4a4case'by'case4

basis

SPACE4RESEARCH4(deep4space)4(space'to'Earth)

34200 34700 Gov4&

Non'Gov

X

(deep4space)

NASA4communication4support4possible4for4qualifying4

missions4(NASA4Space4Communication4Networks)

Non'Federal4subject4to4conditions4on4a4case'by'case4

basis

SPACE4RESEARCH4(deep4space)4(Earth'to'space)