The Office of Space Commerce: Coming to Terms with Space Operations

The Office of Space Commerce: Coming to Terms with Space Operations

Roads, Behaviors, Rules, Risks, and Civility

When a person drives on U.S. roads, there are several risk elements, such as drunk or impaired drivers, suicidal wildlife, Florida drivers, and law enforcement. Generally speaking, those are the “unlikely knowns,” the risks most drivers are aware of but believe they have a near-zero risk of experiencing themselves.

Certain things help stack the deck towards keeping the risks low, such as driver-licensing exams, agreed-upon rules (right on a red, stopping at stop signs, pulling over for emergency vehicles), and technology (anti-lock brakes, seat belts, intelligent cruise control). All of that comes together and usually works.

All allow a person to, for the most part, avoid altogether unexpected and unlikely risks. That low risk encourages drivers to get on the road, whether good or bad. It’s good if drivers learn from their experiences on the road, but bad if it somehow affirms antisocial behaviors.

However, imagine if driving was a riskier proposition. What if people without any driver’s license drove cars that couldn’t steer? Or, semi-truck trailers were allowed to be abandoned on busy freeways? Perhaps vehicles of all sizes could drive on any road, some with parts falling off to remain in the middle of those roads? What if drivers not only had no standard rules, such as stopping at stop signs, but some also drove by rules only known to them? The unlikely knowns would have a much higher than zero chance of occurring.

Somehow, that insanity happens almost daily in the space industry, and it’s accepted. While several space situational awareness systems provide orbital object data, effective space traffic management of spacecraft orbiting the Earth is essentially non-existent. Because of that lack, even the unlikely knowns of operating spacecraft in orbit have an increased chance of occurring. In this case, the unlikely knowns are caused by rocket bodies that transport satellites, then abandoned to orbit the Earth, endangering operational satellites and space stations. Or satellites that can’t maneuver, that, when they eventually stop working, will remain in orbit for years. Like the rocket bodies, they also present a collision risk to other spacecraft in orbit at the same altitude.

Is it any wonder that many companies pass on those risks, despite the lowering costs of available satellites and increased launch opportunities?

Legacy SSA: Conflicted Interest

However, those risks were much lower for legacy space operators a decade ago. There weren’t nearly as many satellites orbiting the Earth then as now. Despite the lower perceived risks, bad things still happened then, such as the collision between a Russian and Iridium satellite. That was one reason the U.S. Air Force started sharing orbital object tracking information with commercial operators. That information sharing was the least the USAF could do, but it was helpful.

Still, it provided only data confirming that objects, such as satellites and capsules, were racing along their orbital paths as the orbital mechanics maths predicted. Worse, some orbital track information was and continues to be withheld from the public. For example, certain U.S. military satellites are judged to transcend orbital mechanics somehow, and the U.S. military withholds the basic orbital information (even though many amateur observers can figure out that information in a day). The image below exemplifies the problem (the cells in the red outline typically contain orbital information).

For those who don’t have 20/10 vision, the cells are supposed to contain, from left to right, the orbital period (how long it takes a satellite to complete a circuit around the Earth), inclination (the angle at which the satellite’s orbital path intersects with the Earth’s equator), apogee (the satellite’s furthest point in orbit from the Earth’s surface), and perigee (the closest point). The information is supplied from, a U.S. military-sponsored site, and is very useful.

So, the USAF provides useful tracking information–to a point. But, if the information involves a super-secret satellite, such as USA 338 in the table above, then commercial operators are out of luck. Such decisions demonstrated the challenges of a military organization, whose primary mission is national security, sharing information in its attempt to stave off future orbital apocalypses. It was a conflict of interest. I’ve gone over that and other issues in a previous analysis.

That issue alone is reason enough for transferring object space tracking to the U.S. Department of Commerce, as directed in 2018 through Space Policy Directive -3. However, DoC still needs to gain the expertise to do that. It doesn’t even have the equivalent Department of Defense’s satellite tracking technology and expertise.

OSC Concerns (or Lessons in Cat-herding)

This lack, and others regarding space traffic management, were recently acknowledged by Richard DalBello, the director of the U.S. Office of Space Commerce (OSC). In a recent Breaking Defense article, DalBello listed things necessary to deal with the current insanity surrounding orbital space operations. The article lists his concerns:

  • Space situational awareness (SSA) technology shortfalls
  • International challenges
  • Doing no economic harm
  • Regulatory challenges
  • Cultivating operator responsibilities

I’ve already covered some of the technology challenges for SSA in a previous analysis. Still, the upshot of all that is the way the military accomplishes it, and the resulting data is not enough for commercial needs. More needs to be done, and if OSC is the one that can do that, fantastic!

For international challenges, DalBello provides a refreshing take:

“China is a major space player and will be a major space player. They are not participating in the global dialogue, and in global information sharing on SSA. That’s unsustainable,” DalBello said. “The current way of communicating with China, which is by email and the occasionally tersely written démarche, is comically insufficient. And so, major problem.”

The lack of the usual negative hyperbole about China’s space efforts is worth noting. The fact is that ANYONE who operates spacecraft should be a part of “the global dialogue.” That noted, while China’s space activities result in multiple spacecraft deployments, none come close to the deployments of U.S. space operators such as SpaceX (which is hopefully already chatting with OSC).

Another part of the international challenges DalBello observes is the tendency for countries and consortiums to work on parochial solutions to the global challenge of space traffic management. He noted that the European Union is doing its own thing, developing a separate SSA system. Likely, China, Russia, and India are also working on their solutions.

DalBello doesn’t begrudge them the right to do so. Still, he correctly worries that different rules from each system may use different biases and analytics, yielding possibly inappropriate policies and processes. Moreover, they would likely not be interoperable, a considerable omission considering the global nature of satellite orbits. It’s the equivalent of nations using different colors and shapes for a stop sign instead of a red octagon. It could be as bad as using imperial instead of metric units.

When DalBello mentions the challenge of not doing economic harm, his comment is more concerned about negatively impacting the existing commercial businesses built up on the DoD’s way of conducting SSA operations–the disruption they will face. Unspoken is that those SSA businesses aren’t providing the data necessary for commercial satellite operators and their concerns about increased satellite traffic. It’s not that those services aren’t helpful; it’s just that what’s required is more than what they provide.

The regulatory challenges DalBello references concern the regulation of technologies, services, and activities in space that weren’t quite so prevalent a decade before. He mentions in-space refueling, manufacturing, space stations, moon mining, etc. Although, to be fair, those activities aren’t currently prevalent, either. But this concern is the concern of all those who deal in government regulation–the balance of regulation against fostering the growth of the space industry.

The last one, I suspect, will probably be the most difficult–getting space operators to become more responsible in space. First, OSC will get pushback from U.S. space operators as they note that those changes will cause them loss in some way–whether money, a competitive edge, or some other tired old business trope. If those sound familiar, it’s because regular U.S. businesses spout off the same excuses in attempts to keep regulation from touching them. Those are floated often enough for us to recognize them.

Still, space operators should seek more responsible ways to operate in space. DalBello’s quote, which is a true statement, is worth repeating:

“’s a little bit alarming to learn that not all operators know where their stuff is.”

That and other little space operator behavioral quirks need to change. While the U.S. will eventually enforce behavioral changes for satellites launched from the U.S., that still leaves the satellites launched from other nations at large. Some nations, like Russia, seem to encourage rogue behavior in satellite operators. That nation’s government does it with its “Inspektor” satellites.

Perhaps, however, the U.S. setting the example of expectations for spacecraft operations launched from the U.S. will be seen as setting industry best practices.

DalBello’s concerns set a decent recognition of the OSC’s challenges as it attempts to fulfill its SPD-3 obligations and parts of the White House’s Space Priorities Framework. Moreover, it demonstrates the U.S. government’s recognition that the current way space operations are conducted isn’t sustainable. Attempting to stay the course would harm the industry and stunt opportunities in the space sector.

If OSC succeeds in its efforts in the U.S., it is helping to minimize the risk of the unlikely knowns. Based on DalBello’s comments, OSC will help push technologies, behaviors, and rules to lower the chances of those risks occurring. What he’s contemplating already appears to be more thought out than what the DoD has historically provided. But to succeed, OSC will need to move quickly and gain support as it moves. With companies like SpaceX already deploying thousands of satellites and Amazon’s Project Kuiper looking to deploy thousands more soon, OSC is facing these challenges from a disadvantaged position.