A report on space traffic management prepared for NASA recommends that the responsibility for tracking satellites and orbital debris be transferred from the Department of Defense (DOD) to a civilian agency, but it does not recommend which one.
The analysis, titled “Orbital Traffic Management,” was done by Science Applications International Corporation (SAIC) under a NASA contract. Congress ordered the study as part of the Commercial Space Launch Competitiveness Act of 2015.
DOD officials have said they are interested in transferring space traffic management to another organization. The Federal Aviation Administration (FAA), which already oversees commercial space activities, is the most likely agency to take over this responsibility.
SAIC examined five options in its study ranging from maintaining DOD control to turning responsibility over to a private organization. The evaluation judged one framework — Option 3: Civil-Based Safety Traffic Safety Monitoring and Facilitation — as slightly better than Option 4: Civil-Based Space Traffic Safety Monitoring and Coordination.
Option 3 would have a civil agency take over DOD space traffic monitoring functions and provide products and services to private and foreign entities. The agency would facilitate information sharing among satellite owners and operators.
“The civil agency also facilitates the private development and evolution of Space Traffic Safety best practices, guidelines, and standards. This is a ‘bottom-up’ approach,'” the report stated.
Under Option 3, the civil agency would establish desired high-level goals and objectives for the development of space traffic rules of the road. It would also create and manage U.S. government inter-agency working groups and committees focused on space traffic safety.
Under Option 3, the agency would have no authority “to mandate communication or coordination among owner-operators or dictate operational decisions (e.g., to maneuver for collision avoidance).”
Under Option 4, the agency would have the “authority to mandate some level of communication and coordination among private owner- operators but does not have authority to dictate operational decisions (e.g., to maneuver for collision avoidance).”
Option 4 would also require the agency to establishes space traffic safety–focused working groups, engineering forums, and committees, including formal advisory boards and committees that would represent spacecraft developers and owner-operators.
The most significant drawback to Option 4 as compared with Option 3 “is that the regulatory mandates of the approach could inhibit new startups and potentially begin to drive companies offshore due to actual or perceived compliance burdens,” the report states.
Evaluations of Option 3 and Option 4 as well as the report’s executive summary follow.
Orbital Traffic Management Study
21 November 2016
National Aeronautics and Space Administration (NASA) Headquarters
Science Applications International Corporation
Civil-Based Space Traffic Safety Monitoring and Facilitation (Option 3)
Ensure Safety of the Space Domain—Safety-centric, codified best practices, guidelines, and standards can evolve through the leadership of the safety, security, and commerce-focused civil organization. Unlike the civil agency, DOD lacks any regulatory authorities required to evolve the licensing process to further reduce Space Traffic Safety risks. The commercial approach (less typical USG acquisition delays) option could lead to innovation and rapid development of a diversified set of SSA sensors, computing platforms, and applications, creating additional and improved Space Traffic Safety products and services and enabling more informed decision-making. There are potential conflicts between DOD-derived and civil agency–derived products and services (e.g., discrepancies between DOD and civil-agency catalogs if using this approach), but a common understanding of the differences in methods and models can ameliorate this concern.
Protect and Enhance NSS Interests—The elimination of DOD overhead for development and delivery of Space Traffic Safety products and services allows for the DOD to focus on its space defense and protection mission and further enhances resiliency. DOD SSA systems become “tuned” to space defense and protection needs. This Framework provides mechanisms for the USG to develop safety-focused areas of interest for potential international cooperation. It enables the USG to play a leadership role in the development and maturation of safety-centric best practices, guidelines, and standards that serve as the foundation of international norms of behavior. It allows the USG to play a leadership role in establishing reasonable and realistic domestically controlled space catalog data security policies.
Ensure the Economic Vitality of the Space Domain and Space Industrial Base—The USG will facilitate but have limited input in the development of new best practices, guidelines, and standards from a bottom-up approach. This approach appropriately relies on commercial industry to be more technically informed based on a full accounting of unique owner-operator values, needs, and capabilities. Reducing overhead and the number of false alarms leads to higher operational efficiencies. This Framework provides more certainty to new startups of Space Traffic Safety–related licensing expectations. The approach also incentivizes continued growth and maturation of a new commercial space sector offering SSA services and capabilities.
Civil-Based Space Traffic Safety Monitoring and Coordination (Option 4)
Ensure Safety of the Space Domain—Safety-centric, codified best practices, guidelines, and standards can evolve through the clear, coordinated leadership of the safety- and commerce-focused civil organization. Unlike the civil agency, DOD lacks any regulatory authorities required to evolve the licensing process to further reduce Space Traffic Safety risks. The commercial approach (less USG acquisition delays) option could lead to innovation and rapid development of a diversified set of SSA sensors, computing platforms, and applications, creating additional and improved Space Traffic Safety products and services. There are potential conflicts between DOD-derived and civil agency–derived products and services (e.g., discrepancies between DOD and civil-agency catalogs if this approach is used), but a common understanding of differences in methods and models can ameliorate this concern. Overall, the safety related benefits of this Framework option are about the same as those presented in Option 3. However, because of the additional USG roles, it will take longer to implement.
Protect and Enhance NSS Interests—The elimination of DOD overhead for development and delivery of Space Traffic safety products and services can allow for the DOD to focus on space defense and protection mission and further enhancing resiliency. This Framework provides mechanisms for the USG to develop safety-focused areas of interest for potential international cooperation. It enables the USG to play a leadership role in the development and maturation of safety-centric best practices, guidelines, and standards that serve as the foundation of norms of behavior. It allows the USG to play a leadership role in establishing reasonable and realistic catalog data security policies.
Ensure the Economic Vitality of the Space Domain and Space Industrial Base—This approach requires commercial industry to be more technically informed based on full accounting of unique owner-operator needs and capabilities. Reducing overhead and the number of false alarms leads to higher operational efficiencies. This Framework provides more certainty to new startups of Space Traffic Safety–related licensing expectations. The approach also incentivizes continued growth and maturation of a new commercial space sector offering SSA services and capabilities. The most significant difference presented by this Framework option, as compared to Option 3, is that the regulatory mandates of the approach could inhibit new startups and potentially begin to drive companies offshore due to actual or perceived compliance burdens.
As stated in Section 109 of Public Law (Pub.L.) No. 114-90, “U.S. Commercial Space Launch Competitiveness Act.”:
“It is the sense of the Congress that an improved framework may be necessary for space traffic management of United States Government (USG) assets and United States private sector assets in outer space and orbital debris mitigation.”1
Further, that law provides direction to make “recommendations related to the appropriate framework for the protection of the health, safety, and welfare of the public and economic vitality of the space industry.”
Directed assessments of relevant policy, regulations, international considerations, technology, and operations topics have been conducted. These assessments provided the foundation for developing, evaluating, and recommending alternate frameworks for the management of space traffic and orbital activities.
Orbiting spacecraft and the space environment in which those spacecraft operate are critically important. In this decade, a new focus has been appropriately made on the defense and protection of spacecraft to ensure the continued flow of information to and from space. Just as there is risk to spacecraft that must be mitigated through defense and protection, there is risk to spacecraft because of the possibility of unintended collisions and physical interference from space objects in intersecting orbits. The likelihood of such events is low, but the consequences can be high, especially in cases involving crewed spacecraft. Therefore, it is in the U.S. national strategic and economic interests to have an improved domestic space traffic safety governance framework (Framework) that specifically aims to mitigate and reduce the risk of possible space traffic safety incidents, while at the same protect the economic vitality of the space industry. Likewise it is important to enable the Department of Defense (DOD) to focus on its space protection and defense mission operationally, and allow its technical support systems to evolve based on protection and defense-centric requirements.
The current Framework does not provide a holistic approach by leading in the combined development of technically informed “rules of the road” and the provision of value-driven, safety-based products and services used during spacecraft operations. Such “rules of the road”, based on space traffic safety concerns, could lead to the maturation of international norms of behavior, which would greatly enhance the strategic stability of the space domain.
Objectives for any space traffic safety governance framework were created by the study team that focus on mitigating space traffic safety–related risks, protecting and enhancing national security interests, and ensuring the economic vitality of the space domain and industry. Five Frameworks were created for consideration. Each Framework exists at a distinct point on a continuous spectrum of space traffic safety governance options in which the USG’s prescriptive role ranges from low to high. The specific possible USG roles for consideration were the following:
- Developing and enforcing space traffic safety–related data sharing policies, best practices, guidelines, standards, and rules and regulations
- Providing space traffic safety products and services to private and foreign space operators
- Selecting, employing, and/or training space traffic safety SSA operators, certifying private spacecraft operators, and developing operational processes and procedures
After review and assessment of a range of Framework options, conclusions and recommendations are provided as follows.
A Framework that best balances the needs for safety, national security, and economic interest is a framework led by a civil agency. That civil agency will perform the following activities:
- Facilitate privately led, technically informed development of codified best practices, guidelines, and standards. These documented processes include improved approaches to reduce the risk of space traffic safety incidents. These processes can inform future licensing requirements for payloads.2
- Provide advisory products and services that enhance operational safety, such as a public space catalog and conjunctions data messages. The agency should become the trusted open source of SSA data.
- Provide leadership in technical and operations matters related to space traffic safety in international fora and develop data-sharing relationships with international owner-operators and partners.
- Balance the needs of space traffic safety with the interests of space commerce and the space industrial base and, therefore, encourage, facilitate, and promote the uninterrupted and free flow of commerce in orbital space.
- Use a business approach for providing SSA products and services in a manner that is most cost-effective, enables innovation to occur on commercial technology development timescales, and is consistent with the required data security policies needed for national security.
- Interface appropriately with all interagency partners to ensure a whole-USG approach to space traffic safety governance.
A civil agency should be provided with appropriate liability indemnification, and at this time it should not have authorities to dictate real-time operational decisions (e.g. mandating a collision avoidance maneuver). The civil agency will be required to develop strong interagency processes and procedures with other USG spacecraft owner-operators (i.e. Department of Defense [DOD], Intelligence Community [IC], and NASA). Strong consideration must be given to facility and personnel security requirements based on the requirements of these interagency interfaces.
This particular Framework is also the quickest and most affordable way to implement the civil-based options. It also offers the most flexibility by providing options to increase the role of the civil organization over time (and possibly transition to the more prescriptive Framework options) as is deemed appropriate.
Implementation of this Framework would require legislative authorities to be granted and appropriate funding to be provided. A time of transition will be required to ensure that expected flows of products and services, currently provided by the DOD, are uninterrupted.
1 Pub.L. 114-90, Nov. 25, 2015, Section 109.
2 This implies that reviews related to orbital debris mitigation are most appropriately conducted by this civil agency. This may require the transfer and/or consolidation of these activities from the agencies that are currently responsible for such reviews (FCC, FAA, NOAA) to this civil agency. Because the FCC will continue to license radiofrequency use, this will result in the need for most commercial space activities to obtain two authorizations—one for radio frequency use and another for the other safety-focused aspects of its space operations.