SpaceX Order Points to FCC Orbital Debris Intentions
Satellite regulatory experts said SpaceX's license modification approved last month (see 2104270027) could point to how the FCC is thinking about collision risk in its orbital debris proceeding. An official said it’s not clear when acting Chairwoman Jessica Rosenworcel might act on that docket, or if she will wait until there’s a full roster of commissioners. The official said the rules update item doesn’t seem very controversial since SpaceX and Kuiper, which would be the biggest mega constellations, haven’t lodged big objections.
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By taking the risk of failing to dispose a single satellite, and the rate of disposal failure, “a relatively simple calculation can estimate the risk from disposal failure for the constellation as a whole,” said the SpaceX license mod OK. The company and agency didn't comment.
There's no consensus in the docket about whether to calculate risk, but there's a lot of backing for looking at the aggregate collision probabilities of constellations instead of per satellite, said a space company regulatory official. The expert said if that approach is good enough for SpaceX in the license modification, it would make sense for the agency to consider it good enough for non-geostationary orbit satellites broadly. The agency not only does an aggregate risk analysis of SpaceX but also seems to lean toward the idea that even if satellites have maneuvering capabilities, that doesn't mean there's zero risk of a collision, said a satellite operator executive. A satellite executive said the order noted that SpaceX complies with the 25-year rule for disposing of satellites after the end of their use and that might suggest the agency is incorporating that into the orbital debris rulemaking.
Talking about constellations as a whole makes sense and SpaceX's OK may indicate the FCC is “adjusting to this new reality” of mega constellations and maybe leaning in that direction, said Mariel Borowitz, Georgia Institute of Technology international affairs associate professor. She said whatever direction the FCC goes on orbital debris, if rules are considered effective, other nations will follow them. The U.S. has such a large space presence its rules would have big impact, she said.
The SpaceX order seems to signal the FCC is seeking more data before it makes a broader orbital debris determination for large constellations, said Secure World Foundation Program Planning Director Brian Weeden. The license mod requires SpaceX to provide information on some additional items, such as spacecraft failures, and repeats that the FCC may impose future enforcement measures, he noted.
Regulatory Affairs Director Nick Spina said Kuiper put substantial time into assessing and portraying the SpaceX license mod, as did others, and was “surprised by the FCC's ruling in spite of the evidence presented.” He said Kuiper is looking into the larger precedent that the license mod order has on the low earth orbit ecosystem.
Astroscale officials, meeting with International Bureau staffers, urged an aggregate system collision risk assessment when considering license applications and modifications, said a docket 18-313 post. It said limiting the maximum aggregate probability of collision, such as at 1 per 1,000, “would be a natural cap on the number of failed satellites in a system, not the total allowable number of satellites in a system.” It urged monitoring aggregate collision probability through frequent real-time reporting.