Voluntary best practices will not solve the impending problem of debris and congestion in orbit alone.
In college, I learned of a concept both fearful and awesome — one that is a measure of chaos and reminds us of the importance of order: entropy.
Put in a social science sense, humans fight against the effects of entropy; we organize societies, develop language and set rules, norms, and laws for ourselves. In democracies, this can be an especially messy process, but it tends to come out on the side of order, predictability, and certainty.
Newer uses of the space environment (think: large constellations, space tourism, commercial habitats) have been characterized as the “Wild West,” and are at an important crossroads: we either continue on our current path of uncertainty and succumb to an ever more disorganized and limiting space environment or, we solidify and organize — processes, tools and standards — to use our orbits more effectively and sustainably.
The global space community is figuring out which path to take. While it can be uncomfortable in the moment, we must come together to understand and develop common responsible orbital behavior before entropy hinders our growth and economic prosperity.
Take space debris. Thankfully, the global space community recognizes that we do have a debris and congestion problem. We are now figuring out the details — that elusive balance between self-restraint in a global commons and full-on freedom to do whatever our imagination (and investors) will allow.
Both industry best practices and its technical cousin, standards, serve a purpose not only to support a safe and sustainable space environment but also to inform impending regulation. And impending regulation will motivate industry to create said best practices.
The Federal Communications Commission (FCC) first introduced Mitigation of Orbital Debris in the New Space Age, IB Docket 18-313, in 2018 after a flush of spectrum rounds that brought a significant number of large constellations to light. While there were Inter-Agency Space Debris Coordination Committee (IADC) guidelines for debris mitigation available at the time, there were very few established industry-made best practices in space, particularly for large constellations.
Since 2018, multiple coalitions worldwide have come together to establish and declare what space sustainability best practices mean to them in this new era of multiple-thousand satellite systems. A key question in 18-313 was if the FCC should shorten the end-of-life de-orbit time from 25 to five years. Then, in 2019, the Space Safety Coalition Best Practices were formed with exactly that recommendation, that “Operators of spacecraft that use chemical or electric propulsion to deorbit should strive to complete the deorbit phase within five years of end-of-mission.”
In 2022, after reviewing responses, the FCC announced a rule for a five-year de- orbit timeframe. The industry best practice ceiling was established, which led to raising the regulatory floor. This example highlights the interplay between best practice development and regulation — limiting the chaos.
The five-year rule was the most palatable item at the time in the 18-313 further notice of proposed rulemaking but is not the complete package needed for space sustainability. Remaining for decision is how the FCC should measure risk of systems, by each satellite (the current process) or by measuring the risk of all satellites within the system, otherwise known as probability of collision in the aggregate (Pc aggregate). Astroscale U.S.’s position is that capping a Pc aggregate risk is an essential complement to the five-year rule. Together, they support a more certain future in the space environment.
This year, a Paris Peace Forum Net Zero Space Working Group recommended a Pc aggregate approach as well. Further, in both the SpaceX Mod 3 and Kuiper authorizations, the FCC effectively imposed conditions that yield a Pc aggregate outcome, limiting the number of defunct satellites in the systems to three and two respectively before being required to report back to the FCC.
Will the Commission now follow suit and codify Pc aggregate as an established rule? I certainly hope so.
There is no doubt industry is truly concerned about space debris. Operators are facing an increasing number of dangerous conjunctions. They are also feeling public, government and investor pressure to act responsibly. If they aren’t already, they will soon feel the economic impact of debris. However, there is reticence to incur additional costs or apply stronger performance-based regulation. It’s the Wild West of the space environment and if we don’t act, entropy will prevail.
Voluntary best practices, while a step forward, will not solve the impending problem of debris and congestion in orbit alone. It will take a suite of efforts that include industry best practices, regulation, economic models, and technology investment to get where we all want to be: thriving in a safe, secure and sustainable space environment.
This article was first published in the May 2023 issue of Via Satellite.