Orbital Debris Update Comments Clash on Collision Risk

Looking at collision, explosion and human casualty risks on a per-satellite basis instead of in the aggregate would "underestimate the real potential for harm to the space environment" from big constellations, SES/O3b said. Calling the existing orbital debris rules for geostationary orbit satellites adequate, Eutelsat said the FCC should consider getting input from other federal agencies, including NASA, on appropriate aggregate collision risks. A focus on aggregate collision risk ensures a proposed system doesn't create undue risk and fosters competition, Viasat said. Required maneuvering capabilities, granting authority in stages and conditioning that authority on the satellites actually being built and performing in a manner consistent with the application will help ensure a constellation doesn't exceed the collision risk threshold, it said. Also backing aggregate calculation of such risks and collision and reentry casualty, OneWeb said the FCC should require onboard propulsion for spacecraft operating above 400 kilometers and limit post-mission orbit lifetime for low-earth orbit satellites to a maximum of five years.

Benefits of an aggregate approach are unclear, and the harms would outweigh it, SpaceX said. It said no update can work if it applies only to U.S.-licensed systems, arguing for its petition against the foreign operator exemption (see 2009250070). Applying the current collision risk in the aggregate would make it impossible for mega constellations to reasonably comply, and a new metric is needed to address the probability of collisions with large objects involving large LEO systems, said Boeing. It backs maneuverability requirements for satellites between 400 and 600 kilometers, saying there should be exceptions for small experimental satellites. Amazon's Kuiper urged the FCC to work with the federal government and satellite industry on more stringent collision standards that would be applied on a satellite-by-satellite basis. It said the commission should evaluate post-mission disposal plans as part of its risk assessment.

Requiring indemnification would be "legally suspect, unnecessary and burdensome," the Satellite Industry Association said. SIA said its members back the FCC working with the satellite industry on finding a replacement for the 25-year standard for post-mission disposal. Operators are incentivized to promptly dispose of malfunctioning or post-mission satellites, and bonds would deter participation in the U.S. space industry due to long-term financial burdens, it said. SIA opposed any mandate that satellites disposed of through atmospheric reentry be designed to burn up. The bond requirement would create more debris by incentivizing use of shorter-lived satellites, which need more replacements and thus more launches, the Aerospace Industries Association said. EchoStar/Hughes opposed such bonds.

Urging a tiered approach to mandated maneuverability, Myriota said maneuverability requirements should be phased in, and existing and substantially designed systems should be grandfathered. It suggested tiers of a maneuverability requirement above 400 kilometers that could include use of differential drag and a propulsion requirement above 600 kilometers.

Endorsing a post-mission lifetime of five years max for satellites below 2,000 kilometers, with shorter post-mission life for larger constellations, Iridium said there shouldn't be approvals of multiple constellations in the same orbital plane between 400 and 2,000 kilometers because of complexity and risk. It supported the post-mission disposal bond, urging smaller amounts.