Comment 
Regarding IB Docket # 18-86 
NPRM FCC 18-44 Streamlining Licensing Procedures for Small Satellites 

Reference  "Spacecraft/Payload Integration &Evolution (SPIE) Non-NASA Payload Flights on Space Launch System (SLS)-RFI"
Solicitation Number: NNM18ZXP008L
https://www.fbo.gov/notices/d61b86c6885720d93f288c030825af23

The NASA Space Launch System (SLS) provides optional Secondary Payload Accomodations for 6 and 12 U cubesat dispensers.

These cubesat dispensers are only exposed to space after separation of the Primary Payload. 

This occurs after the Upper Stage completes the Trans-Lunar Injection (TLI) burn for typical SLS mission profiles. 

After TLI, all secondary payload cubesats dispensed will have sufficient delta-V to reach cis-Lunar space and beyond.

In many cases, the delta-V change required for an SLS Secondary Payload cubesat dispensed after TLI to eject from the Earth-Moon system or impact on the lunar surface may be considerably less (or even zero) compared to that required for disposal by Earth reentry.

With this understanding, and given the resource constraints of a typical cubesat platform, I recommend that that FCC consider conditions under which Lunar impact or Solar Orbit disposal options for Small Satellites may be entertained for this rulemaking.