What a tragic irony if continued access to space is lost as a consequence of lower launch and spacecraft costs. The U.S. is the global space leader and has more to lose than any other nation from diminished access. That’s why the FCC on April 23 is about to adopt new space safety rules for Non Geo Synchronous Orbit (NGSO) satellites that minimize that possibility. The Commission should be applauded for their thorough work and conclusions.
The essence of the new FCC rules extends a longstanding NASA standard on collision risk for individual spacecraft to an entire NGSO constellation. Notably, the FCC allows operators to manage this risk to acceptable levels by building and operating reliable spacecraft that can be maneuvered to avoid collisions for the duration of the license term. Ensuring spacecraft can reliably avoid collisions is important because a single collision can create large debris clouds of high-speed shrapnel in space that increase probabilities of even more collisions.
The timing of the new rules is critical in light of NewSpace investments focused on smaller, faster, cheaper space technologies. NewSpace can be transformational. Miniaturization and more frequent, lower-cost launches enable disaggregating large, expensive mission functions into vast numbers of small, cheap, expendable satellites – aka mega-constellations. But NewSpace business models are still uncertain, while technology and investment capital have leapfrogged regulatory regimes. Market forces alone cannot manage collective collision risks, and current regulations are inadequate.
This is why the FCC’s framework is timely and appropriate: it anticipates potential for orders of magnitude increases in cheap, expendable NGSO spacecraft. Replacing failed satellites can be easy and economical for an individual operator – but measurably increases collision probabilities due to still orbiting uncontrollable failures. As a leading GSO and NGSO technology company, one of the largest and most innovative GSO operators and with a pending NGSO license, it is evident to us that individual operators depend on the collective risk being effectively managed. The FCC’s new rules take a “total system” approach allowing each operator to trade off its own constellation size and reliability while still managing the associated collision risk. Failure to manage space collision probabilities could cause a “Kessler syndrome” – a catastrophic avalanche of collisions of spacecraft and debris that could deny everyone access to space for decades or more.
The FCC’s new requirements emphasize that the whole NGSO constellation must fulfill its license term with a probability of less than one in a thousand (.001) chance of colliding with a large space object. That obviously means the chance of a collision for any individual satellite has to be proportionately lower.
Opponents of the FCC rules argue we should ignore the impact of an entire constellation over its 15-year FCC license term. Simple math shows that would be foolish. Consider a constellation of 42,000 satellites that would be replenished each 5 years - representative of a mega-constellation filing. That implies 126,000 satellites launched over the license term. Applying a .001 probability of collision individually to each of those 126,000 satellites means the expected number of collisions would be 126 over 15 years – averaging 8 each year. In contrast, only two events in the last two decades still account for 25% of all tracked orbital debris today. The debris from each collision makes the follow-on collision risks for that constellation, as well for all other spacecraft, even higher than the expected value – undermining space enterprise for everyone. Ignoring space safety would not unleash NewSpace innovation – it will kill it.
The FCC’s approach wisely reduces the chance of a collision for the entire constellation to one in a thousand. It’s telling and disappointing when operators profess a desire to scale their networks safely – yet oppose FCC regulation that would ensure space safety. The FCC rules are not overly conservative. They enable multiple mega-constellations to co-exist safely as long as the individual satellites have reliable propulsion and control—and are therefore reliably maneuverable while in orbit.
The FCC requirement is feasible in practice. A low constellation collision probability depends only on satellites being deployed with reliability commensurate with the size of the constellation. Reliability has been a cornerstone of space safety, and economic success. While cheap components and low-cost launches might make low-quality, unreliable satellites economically acceptable for a particular constellation from a commercial perspective, collective statistical risks must be managed for all missions for the public good. Market forces on earth have fostered mass production of innovative, low-cost, integrated, reliable and environmentally safe computing, sensing and telecommunications technology. There’s no reason we can’t achieve that in space.
The FCC rules unleash scalable NewSpace innovation with a light regulatory touch. Applying a collision probability requirement to a whole constellation integrates safety into market-based economic equations – similar to health or environmental safety as a shared economic concern on earth. It incents trading the number of satellites for a specific mission against commensurate quality and reliability requirements. It balances economic incentives that might otherwise lead to large numbers of economically expendable satellites at intolerable collective risk. Space is shared. The world depends on many types of NGSO missions for navigation and timing, environmental sensing, meteorology, imaging, communications and more. It makes sense to think in terms of missions – not individual satellites – when apportioning responsibility for safety.
The FCC rules are a critical, positive step forward. But they represent a first step toward effective management of space. To ensure operators do what they propose, and their commitments are clear, we need confirmation of in-orbit performance, along with transparent analysis of constellation design at the outset. Fortunately, that confirmation is easily obtained by observing in-orbit performance of the first satellites launched and considering them as samples of the proposed complete constellation. Statistical sample testing is a well understood method for predicting the reliability of a large population. Mega-constellations must achieve committed levels of failure free on-orbit operational time to meet their aggregate collision requirement. Instances of unresponsive satellites, satellites outside their assigned trajectories, failure to meet expected mission life, or other observable anomalies are early indicators of low confidence in achieving commitments. That enables corrective actions well before there are thousands, or tens of thousands, of unreliable spacecraft in orbit, with irreversible consequences. Ensuring transparency to the FCC about constellation design and the related analyses of expected reliability of spacecraft maneuverability can be achieved by enumerating underlying assumptions in FCC applications. Analyses should comply with objective standards for reliability predictions.
The FCC is addressing very real risks in space. There are already filings for individual constellations with tens of thousands of satellites, and even over 100,000 satellites, to be deployed over an FCC license term. The first mega-constellations are already manifesting the inevitable tensions between small cheap spacecraft and the maneuvering reliability needed to scale to even low thousands of satellites.
The FCC regulations are on target and timely. They should be welcomed by everyone that depends on access to space. And, they should be especially welcomed by those who would lead the NewSpace era.
This op-ed was originally published in SpaceNews.
