NGSO Orbits Need New Allocation Mechanism, Viasat CEO Says
Much the same way the ITU governs and doles out geostationary orbital (GSO) slots, non-geostationary orbits (NGSO) need a central way of being allocated, Viasat Executive Chairman Mark Dankberg said Wednesday at the SmallSat Symposium. He said there should be policy discussions about and calculations of what the carrying limits are for orbital altitudes and how those constraints get allocated. Former NASA Administrator Jim Bridenstine, now Acorn Growth Companies adviser, said a key policy need is a way of holding companies accountable for debris they create, so they have incentives not to create more.
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The current ITU model for NGSO applicants -- protecting against spectrum interference but not registering orbits -- means it would be fine with two constellations in different frequency bands operating at the same altitude and trajectories, Dankberg said. He said space agencies internationally need to develop a common framework to evaluate such constraints. He said individual nations have leverage in the form of market access to force compliance with rules on orbital shell occupation.
Much of Dankberg and Bridenstine's discussion was about the FCC's 2021 approval of SpaceX's first-generation constellation license modification (see 2104270027), though the constellation was never specifically named. The FCC's handling of collision risks in its licensing process underestimates the risk posed by debris and dead satellites, Bridenstine said: The 1 in 44.5 cumulative collision risk the FCC accepts in that approval is actually "very high" given the impact such a collision might have. "It seems like we are missing a big chunk of the risk that is actually there," he said. The FCC's approach just looks at the risk of dead satellites, and doesn't take into account the numerous other constellations wanting to deploy into those same orbital regimes. The FCC didn't comment.
Dankberg said the reporting requirements in the FCC approval point to the agency starting to wrestle with failure rates and the need to monitor them over the lifetime of an applicant. He said assessing the aggregate impacts of constellations needs to be done by trusted third parties, such as academicians, because red flags raised by other space operators often are criticized as attempts to forestall competition.
Bridenstine said the FAA's payload review process should include a requirement that the applicant hire a third party, licensed by Commerce, to provide space situational awareness and space traffic management services. Dankberg said giving constellation operators a set failure rate they can't go past could create a marketplace for debris removal services.
GSO satcom still carries the bulk of data traffic, but the next couple of years will bring "a crossover point" with GEO growth potentially flattening out and NGSO services eclipsing it, Northern Sky Research President Brad Grady said. Melissa Farrell, Stellar Solutions vice president-commercial programs, said there's "a Wild West rush" by satellite operators for spectrum, and there should be rationalization of what their actual needs are.