Increasingly Crowded Space Not Seen Getting Universal Traffic Management Rules Soon
Any international space traffic management rules regime likely has to start with individual countries crafting STM rules governing the mushrooming of big smallsat constellations and of other commercial space missions and then standardizing those rules, space experts said Wednesday evening at an FCBA CLE. Oversize STM attention is being paid to the relatively unlikely collision of operating objects when the far bigger problem facing satellite operators is from orbital debris, said OneWeb Mission Systems Engineering Director Tim Maclay.
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At least for the next decade, talking about one STM rules regime isn't realistic, and commercial space operators need to look at existing models, such as maritime, as a means for working together, said Bhavya Lal, researcher, Institute for Defense Analyses' Science and Technology Policy Institute. Added Secure World Foundation Director-Program Planning Brian Weeden, different orbital altitudes likely will need different rules regimes because of the differing dynamics and traffic involved.
Satellite Industry Association Senior Policy Director Therese Jones said that even though evolution is toward a variety of national regimes, they can have commonality, with the U.S. wanting to be a leader in helping countries establish STM and space situational awareness (SSA) practices. However, Lal said, some nations see STM as a U.S. construct aimed at hampering what other countries do in space. So she said it might be prudent to start any international cooperation with SSA collaboration since even emerging countries understand the need for knowing where assets are in space.
Space activity faces a tragedy of the commons, Maclay said: “It only takes one accident to mess things up for everybody." He said regulators need to update rules for smallsat megaconstellations by codifying "basic, common-sense" design and operational practices such as requiring large constellations not overlap in altitude and that maneuverability be mandatory for missions operating near existing high-value assets. He said existing 25-year guidelines for deorbiting are outdated and deorbiting should be required within five years or within the same time as the operational design life of the satellite, whichever is shorter. And he said that while there is a one in 10,000 casualty risk per satellite guideline, OneWeb would back using instead a constellation-wide risk threshold requirement.
Existing FCC rules regarding debris mitigation don't overlap much with SSA or STM issues such as determining what two satellites do in a possible collision, said International Bureau Satellite Division Deputy Chief Karl Kensinger. He said one area the agency has been more active in is trying to help new operators, particularly in the smallsat space, understand their license obligations. He said that if there is to be a "space controller" role, ordering operators to act in the event of a predicted collision, that role isn't something the FCC -- or perhaps any agency -- is prepared to take on and such situations are likely better handled by operators themselves. He said that while the rules regime regarding how to assess and plan for coordination is less developed in the low earth orbit realm, the agency has pushed operators with multiple proposed LEO satellites to resolve such issues before launch. He said with current non-geostationary orbit applications before the agency, operators that proposed overlapping altitudes "all have additional work to do."
One challenge is no universal definition of STM, with some seeing it as efforts to prevent any physical collisions in space, while others see it also involving prevention of RF interference, said Space Data Center Program Manager Daniel Oltrogge. He said that while about half the objects tracked in geostationary orbit are active satellites, meaning a sizable percentage of predicted conjunctions involve something that can maneuver, that is far lower in low earth orbit: "It's not a good situation."
While the Commerce Department is focused on pro-business space reforms, including removing regulatory burdens, there isn't a lot of space regulation, which is both good and concerning, said James Uthmeier, senior counsel of the Office of General Counsel. He said export controls reforms are of particular interest to space industry players, while the agency also is looking at updating "dinosaur age" commercial remote sensing rules. While Commerce has lacked a permanent director of its Office of Space Commerce for more than a decade, one should be named soon, Uthmeier said. He said the department should have some recommendations on STM later this month as part of a series of recommendations sought by the National Space Council (see 1802210019).
STM enforcement needs to be a long-term goal, so regulatory licensing needs to increasingly incorporate SSA, Weeden said. The U.S. gap between licensing work done by agencies like the FCC and NOAA and space data collection and monitoring work done by the Air Force should be closed, he said.