Policy Recommendations to Address the Challenges
Posed by Small Satellite Proliferation
Kate McGinnis, Devin Osting, Kentaro Tanaka, William West
Space Policy Institute, George Washington University
1
Table of Contents
Executive Summary ____________________________________________
2
Introduction
__________________________________________________
3
Background of Policy ____________________________________________
5
Context
____________________________________________
Forces to Address
______________________________________
Current Small Satellite Policies
5
10
__________________________
11
Current Management Effort ________________________________
12
Policy Statement
____________________________________________
13
Policy Arguments
____________________________________________
17
Formation of Small Satellite Coordination Office within FAA
__
17
Small Satellite Regulation Updates __________________________
18
Spectrum Allocation Policy Updates __________________________
19
Investment in Space Situational Awareness ____________________
20
International Agreements
________________________________
21
______________________________________
22
Bibliography __________________________________________________
25
Background Materials
______________________________________
26
__________________________________________________
29
Summary and Assessment
Biographies
2
Executive Summary
Small spacecraft represent a growing segment of the satellite market and are the subject
of great optimism for reducing the cost of access to space both for commercial and
government uses. The CubeSat template is a particularly popular, low-cost innovation
that makes use of predefined small size and standard components. However, there are
also risks as new companies enter the field and as regulatory efforts attempt to catch up.
The objective of this paper is to recommend policies to the Secure World Foundation, a
think tank dedicated to promoting the sustainability of the space environment, to suggest
to policymakers in the United States. The policy recommendations are meant to
encourage the continued development of the small satellite industry while protecting the
space environment for present and future users.
In the United States, organizations intending to launch satellites must currently navigate a
convoluted process, working with multiple government agencies to obtain the required
licenses and approvals before launch. This can lead to missed requirements, large fees,
and significant delays for companies that do not always have the resources to hire teams
of regulatory experts.
There are also concerns with industry and government that small satellites are not built
and operated at the same standard expected of other satellite operators. CubeSats often
lack on-board propulsion systems and their proliferation raises concerns of possible
collisions with other spacecraft, as well as concerns regarding radio frequency
interference since they are essentially drifting while broadcasting. Because the space
environment is an international resource, it is important that the United States, which
relies heavily on space-based systems, develop a framework to promote the responsible
use of space and encourage continued growth in the satellite industry.
The following policy recommendations are intended to balance the dual goals of having
sufficient regulation to protect the space environment and of promoting innovation and
growth within the industry. First, a small satellite coordination office within the Federal
Aviation Administration Office of Commercial Space Transportation should be
established. This office would have authority to coordinate the regulations imposed by
different government agencies and would be a central resource for small satellite
companies to find information on guidelines and regulations. Second, technical and
operational regulations to minimize the hazards posed by small satellites during and
beyond their operating lifespan should be implemented. Third, spectrum allocation rules
should be updated for expedience, consistency, and in preparation of an influx of
applications. Fourth, space situational awareness capabilities should be maintained and
3
improved by the United States government. Finally, the United States should promote
such policies internationally to protect the global near-Earth space environment.
Implementing these policies will help to promote the responsible use of the space
environment as well as encourage continued growth in the small satellite industry by
making it more straightforward for companies to comply requirements. Because of the
current optimism for and well-known risks of small satellite proliferation, now is the best
time to coordinate with the satellite industry to develop workable solutions to the
potential problems ahead. Working in the present to update satellite policy will help
protect the space environment for the future.
Introduction
As satellite hardware has decreased in size over recent years, it has become possible to
construct and operate spacecraft significantly smaller than traditional satellites. As a
result of this trend, small satellites have been developed that can fulfill many of the same
functions as traditional, larger satellites. Small satellites are relatively cheap, giving
smaller organizations such as commercial startups and educational institutions access to
operate in space. Their low cost makes it easier to launch and operate satellite
constellations, which are networked systems of satellites with a common mission. This
last capability is useful in fields where ubiquitous coverage is strongly desired, such as
telecommunications and remote sensing.
Small satellites have the potential to open outer space to a wide variety of new actors and
economic prospects, but it also threatens to overwhelm a traditional policy framework
built around smaller numbers of larger satellites. Unlike traditional satellites, most small
satellites lack propellant or the ability to maneuver. Risk of creating space debris is
created when small satellites are launched into low Earth orbital trajectories that can take
longer than 25 years to decay. Small satellites are commonly built from relatively lowcost commercial off-the-shelf parts that are not suited to survive long-term in the harsh
environment of space, increasing the likelihood of breakup on orbit. Finally, the low cost
of small satellites attracts new entrants in space, which adds significantly to physical
congestion in low Earth orbit (LEO) and to the strain on the finite resource of radio
frequency spectrum.
This paper’s goal is to outline policy recommendations to the Secure World Foundation
that support the development of relevant domestic policy and encourage international
norms for responsible operational standards for small satellites. The policies are intended
to balance the government interest of protecting the space environment and private sector
4
interests in conducting activities in space, and to facilitate cooperation and consistency
between relevant rule-making agencies. To that end, the paper proposes the following
policies:
 The establishment of an overarching small satellite coordination office within the
Federal Aviation Administration (FAA) Office of Commercial Space
Transportation, which would be responsible for coordinating between the FAA,
the Federal Communications Commission (FCC) and the National Oceanic and
Atmospheric Administration (NOAA), to ensure the consistency of small satellite
regulations as well as their application.
 The creation of regulations governing small satellite design and operations, to be
applied by the FAA, the FCC and NOAA, before granting the small satellite
operators license to launch, to utilize radio frequency spectrum, and to conduction
Earth observation tasks.
 The updating of FCC policy regarding spectrum allocation for small satellites in
low-Earth orbit to restrict the number of amateur band licenses given and to
prepare for a much higher volume of commercial small satellite spectrum
licenses.
 The stabilization of investment in space situational awareness (SSA) at $1 billion
per year through fiscal year 2020.
 The pursuit of bilateral and multilateral agreements with other countries to mirror
these policies, especially those governing small satellite technical and operational
requirements.
The recommended technical and operational regulations for small satellites are:
 To require companies to file, and receive approval for, an end-of-life plan with
AST for all small satellites.
 To require the operational lifespan of a small satellite to represent two-thirds or
more of its total time on orbit.
 To prohibit satellites without any ability to maneuver, or otherwise avoid
collisions, from operating more than 650 kilometers above the Earth’s surface or
within 100 kilometers of the altitude of the International Space Station.
 To require location-emitting transponders on small satellites.
These policies will serve to lower entry barriers to space by streamlining the regulatory
process for small satellite operators while helping promote greater safety and the
protection of the LEO environment.
5
Background of Policy
Context
Small satellites are, as their name suggests, unmanned orbital spacecraft significantly less
massive than typical satellites. Broadly speaking, a small satellite is any satellite below
500 kilograms; however, small satellites can be classified more specifically according to
their size.1 Nanosatellites are small satellites between 1 and 10 kilograms, and are of
special interest due to their increasing popularity.
CubeSats are satellites that follow a popular, standardized nanosatellite template. The
CubeSat was designed in 1999 by Bob Twiggs of Stanford University and Jordi PuigSuari of California Polytechnic State University in order to support research in
aeronautics and astronautics. However, the CubeSat format quickly became widely
popular beyond universities. 2 The CubeSat design is characterized by its 10-centimeter
by 10-centimeter by 10-centimeter dimensions and its mass of approximately 1 kilogram.
A single CubeSat unit will have these dimensions, but the popularity of the CubeSat
template comes, at least in part, from the ability to design larger small satellites with
greater functionality composed of multiple CubeSat units. A satellite is described by the
number of units that comprise it; while the maximum number of CubeSats units that may
be linked together is somewhat arbitrary, the majority of CubeSats launched are smaller
than 10 kilogram. Their small size makes them relatively cheap to construct and to
launch; the approximate cost to launch a single CubeSat unit to LEO in 2015 is only
$100,000.
1
Elizabeth Buchen, Dominic DePasquale. “2014 Nano/Microsatellite Market Assessment.” SpaceWorks
Enterprises, Inc. January 2014. 5.
2
Toni Feder. “Tiny Satellites are Starting to Have a Giant Impact.” Physics Today, October 31, 2014.
6
Figure 1: The Cost to Launch Satellites According to Classification, Mass, and
Destination in 2015 (in thousands of dollars)3
CubeSat proliferation (see Figure 2 below) is one of the concerns facing satellite
operations. First, the sheer number of CubeSats increases the number of objects on orbit
that other satellites must avoid. CubeSats have attracted criticism from people concerned
with space debris. CubeSats frequently have little or no maneuvering capability and, due
to their small size, can be difficult to track visually; both of these traits aggravate the risk
they pose to other satellites.
Secondly, CubeSats increase the demand for radio spectrum, which is a limited natural
resource. Only a small number of satellites can use it before their designated bands
become overcrowded, and increased demand for spectrum will strain its supply.
Furthermore, some are concerned that CubeSat operators are not registering their
broadcast frequencies, which could lead to interference to satellites in medium Earth orbit
(MEO) or geostationary orbit (GEO). 4 Not only might they compete for the same
spectrum as these operations, they might also overpower signals to Earth from higher
altitude satellites that, thanks to technical improvements, broadcast at lower strengths
than in the past.5
3
Spaceflight Industries, “Schedule and Pricing.” Accessed December 1, 2015.
Peter de Selding. “U.S. Satellite Group: Simplify Regulatory Procedure, Create New Regime for
Smallsats.” Space News, February 3, 2015.
5
Jeff Foust. “Low Earth Orbit Constellations Could Pose Interference Risk to GEO Satellites.” Space News,
October 26, 2015.
4
7
Figure 2: Number of CubeSats launched per year between 2005 and 20146
While CubeSats do not in general currently represent an especially large hazard, due to
their low mass and the absence of chemical or pressurized explosives onboard, they still
represent a substantial hazard to other satellites. They are difficult to track due to their
size. They typically lack any propulsion that might allow them to maneuver away from
potential collisions. They are prone to deterioration, as they are frequently built from offthe-shelf parts that are not especially well built to endure outer space.
The risk of increasing space debris is likely to grow. According to researchers at the
University of Southampton, approximately one-third of CubeSats are likely to remain
orbiting Earth for a period in excess of 25 years, despite a persistent myth that CubeSats
re-enter Earth’s atmosphere after a short time in orbit.7 Figures 3 and 4 show that the
persistence of CubeSats in orbital space increasingly has clear implications for the
security of space-based assets. These figures are derived from data produced by the
Center for Space Standards and Innovation’s (CSSI) “Satellite Orbital Conjunction
Reports Assessing Threatening Encounters in Space” (SOCRATES), which calculates
conjunction probabilities twice daily (where conjunctions are defined as objects passing
within 5 kilometers of one another).
6
Tauri Group. “State of the Satellite Industry Report 2015.” Satellite Industry Association, September
2015. 21.
7
Hugh G. Lewis, et al. “An Assessment of CubeSat Collision Risk.” International Astronautical Congress,
2014. 3.
8
Figure 3: Cumulative number of conjunctions involving CubeSats from 2005 through
20148
Figure 4 below shows the cumulative number of conjunctions over time between 2005
and 2014; to date, there have been approximately 360,000 such events involving
CubeSats. It does not show the simple number of conjunctions per year, but the data
suggest that the total amount of conjunctions per year is increasing. Projections using a
model called “Debris Analysis and Monitoring Architecture to the Geosynchronous
Environment” (DAMAGE) suggest that, given current trends, the number of conjunctions
involving CubeSats will increase to a total between 16.5 million and 550 million over the
next thirty years. 9 Even at the lower bound of those projections, the yearly average
number of conjunctions is likely to be approximately 500,000, an amount larger than the
cumulative total over the previous decade.
CubeSats persist in their orbits longer at higher altitudes due to the reduced effect of
atmospheric drag. Further, the difficulty in tracking them visually also increases with
altitude. Together, those factors exacerbate a problem of CubeSat orbital persistence: not
only do CubeSats pose longer-term concerns as altitude increases, but they also represent
simply a more significant hazard with altitude as well.
8
9
Lewis et al, 4
Lewis et al, 10
9
Figure 4: Average number of conjunctions per day of individual CubeSats as a function
of perigee altitude10
End-of-life plans for CubeSats frequently rely on uncontrolled reentry into the
atmosphere, taking advantage of their often low, relatively quick-decaying orbits. The
uncontrolled nature of CubeSat reentries is the result of planning that fails to meet typical
requirements for orbital lifetime and for proper debris disposal.11 Having more
comprehensive deorbit plans before permission is granted to launch small satellites will
help avoid increased debris from poorly planned deorbit strategies.
The current 25-year orbital lifetime limit for satellites grew out of NASA research begun
in 1977. Even with significant compliance with the 25-year rule, the amount of debris
will continue to increase based on estimates done in 2011 (before many large
constellations were even proposed). Figure 5 below shows the estimated amount of debris
with different levels of 25-year post-mission disposal (PMD) compliance as predicted by
the Low Earth orbit-to-Geosynchronous orbit ENvironment Debris model (LEGEND).12
10
Lewis et al, 4
Luca Rossettini. “Op-Ed: Dealing with CubeSat Clutter.” Space News, September 10, 2015.
12
Jer Chyi Liou. “Effectiveness of Satellite Postmission Disposal to Limit Orbital Debris Population Growth
in Low Earth Orbit.” ARES Biennial Report 2012 Final; 72-74, January 1, 2014.
11
10
According to estimates from the Inter-Agency Space Debris Coordination Committee in
2011, only about 60% of LEO objects comply with the 25-year rule.13
Figure 5: Predicted number of objects 10-cm and larger LEO according to simulations
based on varying levels of compliance with current end-of-life satellite guidelines.14
Forces to Address
The major force our policy recommendations are meant to address is the increasing
amount of orbital traffic, propelled by the growth and innovation in small satellite usage.
The key innovation has been the small size and standardization of the CubeSat design,
which has significantly reduced the cost of satellite development. While this technology
has not made nanosatellites cheap in an absolute sense, it has helped to lower the cost of
entry for satellite usage into the low six-figure range. This low cost is substantially less
than standard satellites and has contributed to their recent and increasing popularity with
organizations with limited budget flexibility. Among those using CubeSats are Do-ItYourself hobbyists, commercial start-ups, smaller laboratories, universities, civil space
13
Christophe Bonnal. “Requirements for Debris Mitigation.” Presented at IISL-ECSL Space Law Symposium
2014, Vienna, Austria. March 24th, 2014.
14
Liou, 73.
11
agencies, and even K-12 schools. (While projects like CubeSats are typically done at the
high school level, elementary and middle school students have also worked to build and
launch CubeSats.) 15 Our policy recommendations aim to mitigate the hazards posed by
the proliferation of these satellites without unduly harming the innovations they enable.
Current Small Satellite Policies
In the United States, there are three federal agencies charged with regulating various
aspects of authorizing satellite operations. Satellite owners are obliged to approach each
agency separately in order to receive licenses.
The FAA, within the Department of Transportation, is responsible for licensing the
launch and reentry of spacecraft so that they comply with the United States’ international
obligations and do not threaten the safety of the public. The FAA’s Office of Commercial
Space Transportation (AST) carries out those responsibilities. An insufficient budget and,
by extension, insufficient labor for AST may act as a bottleneck and hinder the growth of
the commercial space industry,16 including small satellite operators.
The FCC, because of its authority over radio spectrum allocation, is responsible for
licensing satellites for their on-orbit operations so that they do not interfere with other
satellites’ operations. Current FCC regulations recognize the existence and use of small
satellites, but these regulations tend to assume that small satellites will be used largely for
academic or amateur purposes.17 Amateur spacecraft are only able to use a small part of
the radio frequency spectrum for a short duration, and by definition, amateur usage
precludes the satellite operator from any financial interests.18 Satellite industry members
are increasingly concerned that the FCC’s current regulatory regime does not fit the
reality of small satellite constellations, which are frequently commercial, do not always
register their broadcast frequencies, and do not always properly follow end-of-life
disposal guidelines.19
NOAA, within the Department of Commerce, is responsible for licensing satellites that
engage in Earth observation. NOAA has recognized a need to reevaluate its licensing
15
Mike Wall. “Pope Blesses Kid-Built Satellite Bound for Space.” Space.com, December 2, 2015.
Sirisha Bandia. “Flat FAA AST Budget Could Slow Growth For Commercial Space Industry.” Commercial
Spaceflight Federation, May 1, 2015.
17 Federal Communications Commission. Public Notice. “Guidance on Obtaining Licenses for Small
Satellites.” March 15, 2013.
18 47 C.F.R. §97.3 (2014)
19
Peter de Selding. “U.S. Satellite Group: Simplify Regulatory Procedure, Create New Regime for
Smallsats.” Space News, February 3, 2015.
16
12
requirements for CubeSats due to the difficulty small satellites face in complying with
those requirements, as well as due to the desire not to unduly burden U.S. commercial
satellite operators.20
Current Management Efforts
The problem of managing space traffic is global, but currently there are no international
forums dedicated to the specific problem of monitoring small satellites in orbit. However,
there are organizations that examine and work to manage the broader issue of orbital
debris and space situational awareness.
The UN Committee on the Peaceful Uses of Outer Space (UN COPUOS), the United
Nations committee dedicated to promote research and identify potential legal problems in
the use of outer space, has issued Space Debris Mitigation Guidelines.21 These guidelines
serve as broad principles rather than as specific technical or operational
recommendations.
The Inter-Agency Space Debris Coordination Committee (IADC) is an intergovernmental
forum meant to facilitate the sharing of space debris research and to investigate debris
mitigation options. Its membership consists of the larger national space agencies from
around the world, including NASA, the Japan Aerospace Exploration Agency, the
European Space Agency, Roscosmos, and the China National Space Administration.
However, competing security concerns between the United States, Russia, and China may
hinder the IADC’s purpose of data-sharing. Furthermore, the IADC’s membership is too
narrowly restricted for it to serve as a forum for sharing information on small satellites.
Not only are younger and smaller space agencies (such as the UAE’s space agency) not
members, but the majority of CubeSats operators are likely to be commercial or academic
entities by the end of 2016.22
For commercial satellite users, the Space Data Association (SDA) serves as a datasharing forum for commercial satellite operators. As CubeSats are commercialized, SDA
is likely to become increasingly important as a means of maintaining awareness of onorbit small satellites. However, its membership is limited to commercial satellite
operators, which prevents it from serving as a forum for other satellite operators (e.g.,
space agencies).
20
Ram Jakhu and Joseph Pelton. “Small Satellites and Their Regulation.” Springer. 2013. p. 51.
United Nations Committee on the Peaceful Uses of Outer Space. “Space Debris Mitigation Guidelines.”
2010.
22
Bunchen and DePasquale, 9
21
13
In the defense sector, the most prominent institution for orbital monitoring and space
situational awareness is the Joint Space Operations Center’s (JSpOC) Space Surveillance
Network (SSN). The SSN monitors approximately 22,000 objects in space, using a
combination of ground-based and space-based sensors.23 In the LEO environment, it is
capable of tracking discrete objects as small as 5 centimeters, but it cannot track objects
this small in geosynchronous orbit.24
The SSN is limited by the number of sensors it has available and their geographic
distribution (at least for earth-based satellites), with the result that it cannot continuously
track orbital objects; instead, SSN monitors objects using discrete “spot-checks,” which
relies on predictive analyses of where objects are expected to be (and their subsequent
confirmation). The use of spot-checks is not conducive to tracking CubeSats, which, due
to their size, are difficult to distinguish if more than one are deployed in quick
succession.
A commonly suggested solution to the issue of coordinating space traffic management is
to expand the mandate and jurisdiction of the United Nations’ International Civil
Aviation Organization (ICAO).25 These proposals, however, do not address ICAO’s the
lack of experience, technical expertise, and organizational capacity with regard to space.
There are significant physical differences between orbital flight, which is essentially
uncontrolled after the initial placement into orbit, and atmospheric flight, which is
(outside of technical difficulties) always controllable. Nor do these proposals recognize
the different legal regime facing space traffic management. Unlike in air traffic
management, there is no agreed-upon means of managing orbital traffic and space debris.
Airspace can be regulated by the sovereign nations that control it, but outer space has no
sovereign that could exercise the requisite jurisdiction.
Policy Statement
This section recommends policies that the Secure World Foundation should promote for
adoption by United States policymakers.
23
Vandenberg Air Force Base. “Joint Functional Component Command for Space.” Accessed December 2,
2015.
24
National Aeronautics and Space Administration. “Space Debris and Human Spacecraft.” September 26,
2013.
25
Ram Jakhu, Tammaso Sgobba, and Paul Dempsy. “The Need for an Integrated Regulatory Regime for
Aviation and Space; ICAO for Space?” Springer Wein, New York, 2011
14
The intended result of our policy recommendations for the Secure World Foundation is
the sustainability of the near-Earth space environment. These recommendations are
intended to support the development of domestic and international norms for the design
and operational standards for small satellites, and especially for nanosatellites. They are
intended to: balance the public interest in protecting the space environment with private
interests in conducting activities in space; facilitate cooperation and consistency between
relevant regulatory agencies; and to promote communication and cooperation between
those public and private actors.
In order to further the goals of small satellite users in industry and education, as well as
their supporters in government, the Secure World Foundation should encourage the
United States government to put forth policies that encourage groups planning to design
and launch small satellites. These policies should avoid convoluted regulations while also
establishing the responsibility for satellite operators and designers to avoid causing
damage or harmful interference to other spacecraft. Based on these goals, we recommend
the following policies.
First, the Secure World Foundation should advocate for Congress to establish an
overarching small satellite coordination office within the FAA’s Office of Commercial
Space Transportation (AST). This new office would be responsible for synchronizing the
licensing process between the various relevant regulatory agencies and small satellite
operators. The coordination office would help small satellite operators, and especially
new entrants to the industry, to become aware of and to comply with applicable
regulations.
The office would also coordinate regulations between various government agencies,
including the FAA, the FCC, and NOAA, to ensure regulatory consistency across those
as agencies and over time as technology develops and the small satellite industry matures.
Additionally, the small satellite coordination office would streamline the process for
licensing small satellites compared to prior use of experimental applications. Although
the coordination office would not mandate specific regulations for other agencies to
adopt, authority for this office to coordinate between the regulatory agencies would be
granted by Congress.
Second, the Secure World Foundation should advocate for Congress and the Executive
Branch to require new regulations governing small satellite operations. These regulations
would be adopted by the FCC as a condition for granting permission to satellite operators
15
to use radio spectrum frequencies, by NOAA as a condition for licensing Earth
observation small satellites, and by the FAA as a condition for granting launch permits.
The first of these regulations would require companies to file an end-of life plan with
AST. The end-of-life plan would need to be approved by AST before the launch license
could be granted, by the FCC before spectrum usage could be licensed, and by NOAA
before any remote sensing license could be granted. This requirement would reduce the
congestion of the LEO environment by decreasing the length of time during which small
satellites will be in orbit and thereby reducing the risk of collision they pose over time.
The second regulation would require the operational lifespan of the small satellite to be at
least two-thirds of the total on-orbit duration of the satellite. This would not replace the
pre-existing 25-year limit on total time while on orbit, but would be an additional
condition for small satellites in LEO. By requiring a shorter duration for post-operational
time on orbit, this regulation would also reduce the risk of collisions due to abandoned
satellites.
The third regulation would prohibit satellites without the ability to maneuver or otherwise
avoid collisions from operating higher than 650 kilometers above the Earth’s surface or
within 100 kilometers of the average altitude of the International Space Station (375 km).
This policy would minimize the risk of collisions and harmful interference near humancrewed spacecraft and in orbits where CubeSats are expected to persist for 25 years or
longer.
The fourth regulation would require location-emitting transponders on all small satellites.
This policy would make location information available to ground-based tracking systems
as well as to nearby satellites, allowing satellite operators to respond accordingly to
nearby CubeSats.
Third, the Secure World Foundation should encourage Congress to instruct the FCC to
update its policies for spectrum allocation for small satellites in LEO. These policies
should limit the number of amateur band licenses granted and should prepare for a
significantly higher volume of commercial satellite owners to use spectrum for small
satellite constellations. The development of these policies, as well as the resulting
licensing process, must be not be so time-consuming that it hinders the development of
satellite systems. These policies must be consistent with international norms; while the
current regulations are in line with established international rules, there are concerns by
16
other regulators about the use of amateur frequencies and by industry stakeholders about
the pace at which the FCC processes spectrum filings.
Fourth, the Secure World Foundation should encourage Congress to continue investing in
space situational awareness (SSA) with no less than $1 billion per year through fiscal
year 2020. By providing consistent funding to maintain and update SSA programs such
as those within JSpOC, Congress can ensure that all stakeholders will have reliable
information available.
Finally, the Secure World Foundation should encourage the Executive Branch to seek
bilateral and multilateral agreements with other countries. To make the regulations
regarding technical and operational requirements for small satellites universal, it will be
necessary for other nations with the capacity to launch small satellites to apply these
regulations. The effective implementation of these policies should encourage other
countries to follow the lead of the United States, and by pursuing bilateral and
multilateral agreements, the United States government can expand the use of these
regulations without the need to arrange for global consensus all at once.
We considered several alternative policy ideas in developing our recommendations. With
regard to domestic policies, we considered some less formal mechanisms, such as having
the FAA encourage the satellite industry to develop a set of best practices for small
satellite operators to follow voluntarily. This approach would likely not address the
asymmetry between earlier industry participants and new entrants into the industry.
Established stakeholders are concerned that lax application of safety standards for small
satellites could harm their traditional satellites, which represent significant investments,
while small satellite companies are concerned that traditional satellite operators will use
their position to discourage the use of small satellites. Furthermore, this approach would
necessarily lack the force of regulations.
Another indirect mechanism would have recommended that the small satellite
coordination office work with space industry insurers to produce standard insurance
policy rules that would require safe practices in the LEO environment. This approach,
which would remove control from regulators, could produce a system that would
disproportionately benefit insurers at the expense of the small satellite industry. It would
be dependent on the cooperation of the insurance companies, who might develop their
own less effective standards, and on the cooperation of small satellite companies, who
could seek out insurance companies with less rigorous requirements. Moreover, this
17
indirect approach to regulation is not likely to be accepted by international regulatory
bodies.
At the international level, we considered proposing modifications to the 1975
Registration Convention and to the 1967 Outer Space Treaty, and attempting to work
with UN COPUOS and the UN Office for Outer Space Affairs. All of these approaches
would be impractical for several reasons. First, they require time-consuming negotiations
without any guarantee of success. This is especially true with regard to the several space
treaties, where the amendment process would require an improbable consensus among
countries with significantly disparate interests in space. Furthermore, these processes
would give undue weight to the interests of countries with relatively little investment in
space, and those countries would be capable of exercising that weight for strictly political
reasons rather than in the interest of protecting the sustainability of the space
environment.
Policy Arguments
1. Formation of small satellite coordination office within FAA
Strengths:
Private actors interested in launching small satellites must obtain the necessary approvals
and permits before launch. A single office where companies and other entities could find
all information relevant to obtaining permits would simplify the licensing process and
reduce the barriers to entry into space. This office would also help companies in
navigating the regulatory process, which would lead to improved regulatory compliance
by satellite operators because they could more easily learn about their responsibilities.
A central office with authority granted by Congress would be able to coordinate between
various regulatory bodies to ensure consistency and would clarify for industry
stakeholders where in the government they could direct their concerns about these
policies. The office could also have a role in mediating disputes between satellite
operators before satellites are placed in orbit.
Weaknesses:
While a new office, properly implemented, could streamline the process of getting small
satellites into space, a poorly implemented office could add another barrier to businesses
looking to innovate in space. All stakeholders would need to cooperate fully with this
office in order to achieve the desired increases in regulatory efficiency. The FAA-based
office would need sufficient authority from Congress in order to preempt interagency
conflict. New entrants into space may become less cooperative if they observe regulatory
18
exceptions made to grandfather in heritage spacecraft.
Opportunities:
This is an opportune time for putting together an office of small satellite coordination
housed in the FAA. Small satellite companies have so far generally launched proof-ofconcept satellites and they can still make changes to their architecture if they are given
the necessary information and clear regulations. Creating a single point of contact
between companies and the government will enable communication as regulations are
updated to reflect the realities of LEO operations, which will reduce companies’
frustration as well as their temptation to leave the United States in order to skirt
confusing or redundant requirements.
Threats:
The small satellite coordination would require action from Congress, and such action
cannot be taken as a given. Without legislative authority to carry out its mission, a
coordination office in FAA would lack the power to ensure the consistency of the
licensing process across the other relevant regulatory agencies. Without steady funding,
the coordination office would risk becoming a burdensome layer of bureaucracy rather
than a source of information and support for pre-launch requirements.
Companies themselves may prove reluctant to provide information to the coordination
office if they don’t believe that trade secrets will not be kept confidential. Further,
companies may seek to lobby in support of their individual interests against regulations
that are beneficial at a larger scale, which could result in regulations that do not
effectively mitigate the increasing risks in orbital space.
2. Small satellite regulation updates
Strengths:
Regulations that outline methods of satellite control, position knowledge, and end-of-life
plans would increase spacecraft operator confidence in the safety of their assets.
Requiring satellite maneuverability in certain orbits and end-of-life plans will make it
easier for companies to comply with limits on orbital lifetime. Implementing these
policies now would help to avoid increasing congestion in LEO.
Better space situational awareness and spacecraft maneuverability could make it possible
to avoid predicted collisions. Signal-transmitting beacons would allow spacecraft to be
identified more quickly after launch, which is particularly important when dozens of
CubeSats can be accommodated on a single launch vehicle.
19
Weaknesses:
Regulations that drive satellite operators to change mission parameters are more difficult
to justify since they directly affect the financial cost of the project, and therefore satellite
operators are more likely to oppose regulations that add to cost during the design stage.
Regulators and industry stakeholders may decide that concerns over unduly burdening
the small satellite industry should outweigh the improvements in space situational
awareness provided by these requirements.
Tasking the FAA with a larger responsibility for small satellite regulation would require
additional funding, which may not be forthcoming. Furthermore, the FAA may not have
the existing knowledge needed to properly implement new policies without the
cooperation of other government agencies. The need for international cooperation may
also be a challenge; even in areas which affect all space actors, improved knowledge of
the space environment disproportionately helps larger space powers, which discourages
broader support for initiatives such as debris mitigation.
Opportunities:
At this early point in the small satellite industry’s development, establishing requirements
now for certain types of beacons or propulsion systems could reduce the development
cost per small satellite unit. Further, the cost of implementing these requirements now
would be less expensive than the cost of a catastrophic collision as a result of untracked,
unmaneuverable objects on orbit. Better knowledge of satellites’ positions could also
make it easier to manage radio spectrum by scheduling their ground contacts more
precisely. In the future, better position knowledge could be useful for satellite servicing
and component reuse.
Threats:
If the U.S. Department of Defense (DoD) were to use small satellites for national security
purposes, DoD would likely be exempt from requirements that support reporting
positioning data for other satellite operators’ benefit. In that case, non-compliance by
government actors could create distrust when satellites are operating very near one
another but cannot be identified.
3. Spectrum allocation policy updates for small satellites in LEO
Strengths:
While current spectrum policies are effective for the number of satellites that are
currently on orbit, updates need to be made in preparation for the increasing usage of
20
LEO in general and by future small satellite constellations in particular. Preparing for
increasing applications will allow the FCC to process them more quickly as needed.
Limiting amateur licenses will help the U.S. to comply with international norms and
reduce the likelihood that amateur spacecraft will interfere with other spacecraft. Policy
updates that streamline the FCC licensing process will support continued commercial
small satellite growth, ensure consistent regulation, and avoid stifling innovation while
providing clear guidelines for small companies.
Weaknesses:
While smaller companies may find that updates to spectrum management policy in the
United States would be helpful to them, larger satellite operators who rely heavily on
spectrum in specific orbital slots may seek to block updates. Enforcing changes to
existing spectrum policies may be difficult due to the large number of satellites already in
orbit that cannot be updated and that may interfere with spacecraft using new protocols.
Limitations on amateur spectrum usage could stall improvements in small satellite
technology since it would be difficult to obtain low-cost and quick spectrum licensing for
proof-of-concept missions.
Opportunities:
Because spectrum registration in the United States can take a long time and because its
complexity can be a challenge for new satellite owners to navigate, there is excitement in
the small satellites industry for developing a more streamlined process. International
radio spectrum and telecommunications meetings are a good opportunity for small
satellite companies and the United States government to put forward policies that are
acceptable for all stakeholders.
Threats:
The current spectrum management rules work well for a small number of satellites,
whose owners would not likely support changes to the status quo. Poorly implemented
policy updates could cause the expected influx of spectrum requests to become
backlogged, which would discourage confidence in the regulatory system.
4. Investment in Space Situational Awareness
Strengths:
Current U.S. investment in JSpOC’s space situational awareness capacity is roughly $1
billion per year, but the actual amount varies annually. The Government Accountability
Office has found operation of a comprehensive SSA system within the DoD to be of vital
21
importance; because SSA is vital to space operations, stabilizing investment in SSA at the
$1 billion level should be easily justifiable to lawmakers.
Weaknesses:
Comprehensive space situational awareness is expensive. Even in the case where it has
broad bipartisan support, it is difficult to implement in a cost-effective and expedient
manner. The amount of debris and inactive spacecraft tracked using the current groundbased methods is large and could strain JSpOC’s capacity to monitor it all.
Comprehensive SSA requires tracking locations distributed around the world, which in
turn requires international cooperation. New technology may require an increase in
funding beyond the current $1 billion recommendation.
Opportunities:
The United States government is already a leader in space situational awareness and can
demonstrate that position by continuing to support this critical service. Because JSpOC is
within DoD, national security arguments in favor of strong funding are likely to be
compelling to lawmakers. Further, the recent movie Gravity has brought the problem of
debris strikes into the public consciousness, which could also be used to support SSA
efforts.
Threats:
Though defense concerns may justify increased SSA spending, the DoD may also plan to
put limits on the sharing of data to protect the location of its assets, even though open
sharing of information is important for the success of SSA.
5. International agreements
Strengths:
Working to standardize regulations internationally would make it easier to justify specific
requirements domestically. There are precedents for international partners agreeing to
regulations proposed by the US when there are clear justifications for them, such as the
25-year orbital lifetime requirement.
Weaknesses:
The United States will have trouble advocating for policies whose utility have not yet
been fully demonstrated; international agreements would likely need to wait until U.S.
policies have been proven effective. Enforceable international agreements are frequently
difficult and time-consuming to negotiate.
22
Opportunities:
The United States has the opportunity to act as a leader in instituting workable space
regulations and bringing evidence of success to international partners. Since many of the
new small satellite operators are based in the United States, U.S. regulations will already
have an impact on operator planning and on the space environment. There have also
already been discussions internationally at previous IADC meetings concerning the need
for updated regulations concerning small satellites.
Threats:
The pursuit of international agreements on small satellites may see objections from
parties from in the U.S. and from other countries. U.S. skeptics of such agreements may
argue that they limit U.S. industry, and Congress may be unwilling to work with certain
countries, reducing the chances for universal adoption. International skeptics may be
concerned that these agreements would largely benefit only the U.S.
Summary and Assessment
This paper recommends policies to address concerns over small satellite proliferation. As
small satellites increase their share of the market, the government needs to implement
measures that encourage private sector activities and thereby strengthen U.S.
competitiveness internationally. On the other hand, satellite proliferation has resulted in
an increased risk of collision between satellites in orbit. Fully a third of CubeSats are
expected to remain in orbit well beyond their operational lifespan, which increases the
collision risk they pose to other spacecraft. Further, spectrum interference is a pressing
concern as the number of satellites in orbit continues to grow. The U.S. government will
increasingly face these issues as small satellites proliferate in LEO over the next 5-10
years and beyond. As a leader in space, the United States must address these issues,
solidifying its own regulatory regime nationally and promoting responsible international
norms for others to follow.
To mitigate those problems, this paper presents the following policy recommendations:
creating a small satellite coordination office, imposing new technical and operational
requirements for small satellites, updating spectrum allocation policy for small satellites,
stabilizing the budget for space situational awareness through 2020, and promoting U.S.
regulations as international standards through pursuit of bilateral or multilateral
agreements. The implementation of these policy recommendations is intended to shorten
the length of the time needed to license small satellites; to mitigate harmful radio
23
frequency interference; and to slow both the rate of spacecraft conjunctions occurring on
orbit and the rate at which space debris is generated.
First, this paper recommends that the government establish an overarching small satellite
coordination office within the FAA. Since the increasing number of small satellite
operators may not be familiar with the regulatory process and the reasons for it, this
office would facilitate their understanding of, as well as their compliance with, those
regulations. This office would also streamline the licensing procedures for small satellite
operators by coordinating with other regulatory agencies, to improve the efficiency of the
process and to support the international competitiveness of U.S. companies. However, the
government should avoid simply creating another layer of bureaucracy for satellite
operators to navigate. To this end, Congress needs to give this office sufficient authority
and funding so that it may play an effective role in coordinating the licensing process
among the other regulatory authorities.
Second, the government should update requirements for small satellite operations to
include stricter end-of-life plans, the inclusion of some means of satellite attitude control,
updated orbital slot requirements, and the inclusion of a signal-transmitter to provide
positioning information. These would make it easier for the government to predict and
avoid collisions, and satellite operators to have confidence in the safety of their space
assets. While the long-term benefits of improving spacecraft safety are significant, these
regulations could result in an increase in the cost of building small satellites.
Third, the U.S. government should update its spectrum management policies for small
satellites. The risk of spectrum interference has been increasing as the number of small
satellites increase, especially with amateur operators who previously could not afford the
costs of satellite operation. Because amateur band licensees currently have no right to
claim protection from interference, they will be more likely to cause interference
themselves in the near future as the number of licensees increases. Tightening the
screening criteria for them could help to mitigate future interference. Further, the
government should streamline registration procedures to manage these new entrants, as
well as to promote innovation in the United States and to avoid driving it to other
countries.
Fourth, the government should maintain the current levels of investment in space
situational awareness, in order to continue upgrading the hardware and software
necessary to monitor an increasingly crowded space environment. Better understanding
of the space environment will help to ensure that small satellite operators follow national
24
and international space-debris mitigation guidelines and help the government to protect
their own space assets. However, it costs a significant amount of money to build and
maintain SSA facilities; even the current level of expenditures may not be sufficient if the
volume of satellites and space debris increase at the current rate. It is furthermore
impossible to monitor space in all directions from U.S. territory alone. Therefore,
pursuing international cooperation is key to the success of maintaining and improving the
capacity of U.S. space situational awareness.
Finally, the United States should promote its regulations for the operation of small
satellites as the international standard through bilateral and multilateral agreements.
Presently, the COPUOS space debris mitigation guidelines are too vague with regard to
technical requirements, while the IADC space debris mitigation guidelines are limited by
the IADC’s small membership. In either case, these guidelines lack legal force. As the
leading nation in space, the United States needs to solidify its domestic regulatory
regime, and then use it to promote it as the international standard. Because it would be
nearly impossible to gain the needed consensus from every country at once, the best
approach to establishing a consensus is the steady, step-by-step pursuit of bilateral or
multilateral agreements with other countries.
25
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Biographies
Kate McGinnis is a master’s candidate studying space policy at the Space Policy
Institute within the George Washington University’s Elliott School of International
Affairs. She holds bachelor’s and master’s degrees in mechanical engineering. She
previously worked as a spacecraft proposal engineer at Orbital ATK and is currently a
satellite systems engineer at NOAA.
Devin Osting is a master’s candidate studying space policy at the Space Policy Institute
within the George Washington University’s Elliott School of International Affairs. He
holds a bachelor’s degree in political science/philosophy/economics.
Kentaro Tanaka holds a bachelor’s degree in astrophysics and is a master’s candidate
studying space policy at the Space Policy Institute within the George Washington
University’s Elliott School of International Affairs. He works for SKY Perfect JSAT
Corporation, a Japanese satellite operator. He has worked in Hong Kong for the AsiaOceania telecommunications satellite industry, and in Tokyo developing one of the
largest public-private projects in Japan for the Japanese space and defense field.
William West is a master’s candidate studying space policy at the Space Policy Institute
within the George Washington University’s Elliott School of International Affairs. He
has worked in NASA’s Office of International and Interagency Relations, and he has a
bachelor’s degree in Geography.