FCC's Object-Years Cap, Aggregate Risk Approaches Lack Consensus
Many space operators continue assailing the FCC's idea of a 100 object-years cap, reply comments in docket 18-313 show. However, SpaceX remains a staunch defender of object-years. The object-years approach -- capping at 100 the number of years failed satellites in a constellation could remain in orbit -- also came under fire last month in the agency's orbital debris docket record refresh (see 2406280009). In addition, there remains a schism over the idea of adopting aggregate, system-wide collision risk metrics.
The object-years approach faces broad opposition, as it doesn't meaningfully address collision risk, Eutelsat/OneWeb said in the docket Monday. Instead, it urged that the commission examine designing satellite features that allow future active debris removal and adopting maneuverability requirements for non-geostationary orbit (NGSO) systems operating at altitudes higher than the International Space Station.
Iridium's constellation operates at around 780 km, and one failed satellite can take more than 100 years to deorbit, the company said. A 100 object-years cap, it argued, "would stifle innovation and handicap constellations at higher altitudes by making it unreasonably burdensome to launch new satellites into those orbits." Iridium said alternative approaches, such as requiring orbital separation in altitude between constellations or requiring sharing space situational awareness data with other operators, would help space sustainability "without imposing undue burdens on operators at higher altitudes."
With nearly everyone against the object-years approach, the FCC instead should look at making operators of large NGSO constellations calculate the collision probability associated with any non-maneuverable satellite that is in orbit and cease launching satellites when the cumulative total reaches a certain point, said Viasat. A per-satellite collision risk, it added, would allow "intolerable levels of collision risk to persist and grow." It said an aggregate collision risk limit would give operators flexibility in designing and operating their systems.
"There is no need for significant changes to the Commission’s space safety rules," as the agency has been busy with rules and clarifications for the past several years, Amazon's Kuiper said. It argued against an object-years approach and an aggregate risk metric. With other federal agencies also working on orbital debris issues, Kuiper said any further FCC space safety work should revolve around evaluating the efficacy of its existing rules and complementing the efforts of those other agencies.
On the other hand, SpaceX said an object-years approach would incentivize responsible behavior in orbit. It also urged against the adoption of an aggregate collision risk assessment. It noted a near-universal agreement that operators should share ephemeris data and details about planned maneuvers. Moreover, operators should coordinate satellite deployments into, and movements through, operating constellations.
FCC arguments that it has broad authority to regulate space no longer resonate in a post-Chevron doctrine world, TechFreedom said. The agency must show it has subject-matter expertise on orbital debris, it said. NASA is heavily cited and relied on in the record refresh, TechFreedom said. The FCC's authority is largely limited to instituting reporting requirements on space operators, but the agency "will be hard-pressed to defend" technical requirements related to orbital operations under the Administrative Procedure Act's "arbitrary and capricious' standard," it said.