The Aerospace Industries Association (AIA) and our more than 300 member companies would like to thank the FCC for working to update rules on orbital debris mitigation for Commission-authorized satellites. Orbital debris mitigation is an issue of great importance to maintain the long-term safe operation of all commercial, civil, and national security spacecraft and one all members of AIA agree needs careful attention. However, we have concerns about the proposed regulations in the draft report and order, as well as the proposals in the Further Notice of Proposed Rulemaking (FNPRM). Given these concerns, we urge the Commission to postpone consideration of orbital debris mitigation items at the April 23, 2020, meeting to provide adequate time for consideration and comment, including a discussion on the importance of a common integrated approach to space across all expert agencies.
