SAIC Recommends Civil Agency for Orbital Traffic Management, But Not Which One

In a report for NASA required by the Commercial Space Launch Competitiveness Act (CSLCA), SAIC is recommending that a civil government agency take responsibility for orbital traffic management, but it does not specify which agency that should be. The Federal Aviation Administration (FAA) and its parent, the Department of Transportation (DOT), are often the center of attention in orbital — or space — traffic management discussions, but SAIC explained that the terms of reference for its study did not ask for such a recommendation.

Section 109 of CSLCA makes a sense of Congress statement that an “improved framework” may be needed for “space traffic management” of U.S. government and private sector assets in outer space and orbital debris mitigation.  It then directs that NASA, in consultation with DOT, DOD, the FCC, and the Department of Commerce, contract with an independent systems engineering and technical assistance organization to “study alternate frameworks for the management of space traffic and orbital activities.”  It goes on to specify what the study should consider and asks for recommendations on “the appropriate framework for the protection of the health, safety, and welfare of the public and economic vitality of the space industry.”

SAIC was selected to conduct the study.  Its final report was submitted to NASA on November 21.  It begins by noting that definitions of terms like “space traffic management” vary and consequently creates its own definitions for the purpose of the study. It chooses to use “orbital traffic management” rather than “space traffic management” because it believes the latter “implies a specific approach.”

The study lays out five alternative frameworks: private space traffic monitoring and coordination, DOD-based space traffic safety monitoring and data sharing (status quo), civil-based space traffic safety monitoring and facilitation, civil-based space traffic safety monitoring and coordination, and civil-based space traffic management.  It compares them in terms of three objectives: ensure safety of the space domain, protect and enhance national security space interests, and ensure the economic vitality of the space domain and space industrial base.

SAIC concluded that the current framework — where DOD tracks space objects and provides conjunction analyses to other U.S. government as well as commercial and foreign entities — is insufficient and a “holistic approach” is needed, led by a civil government agency. “However, no assumptions or recommendations are made as to which specific civil agency could or should be designated, as such a recommendation was not specified by Congress as a report product.”

Six tasks are recommended for the agency ranging from facilitating privately-led development of best practices, guidelines and standards, to providing advisory products and services in order to enhance operational safety, to providing leadership in technical and operations matters related to Space Traffic Safety in international fora and developing data-sharing relationships with international owner-operators and partners.

The agency should be provided with appropriate liability indemnification, SAIC continues, but “at this time it should not have authorities to dictate real-time operational decisions (e.g. mandating a collision avoidance maneuver).”  Legislation is needed to implement the recommended framework and a transition period will be needed to ensure that the products and services currently provided by DOD are not interrupted.

The SAIC conclusions and recommendations are in line with those advanced by Rep. Jim Bridenstine (R-OK) and George Nield, FAA Associate Administrator for Commercial Space Transportation (AST) for the past several years, although they make clear they want DOT to be the designated civil agency.  They want to start with FAA/AST assuming responsibility from DOD’s Joint Space Operations Center (JSPoC) for providing Space Situational Awareness (SSA) data and conjunction analyses to non-military users so JSPoC can focus on its core mission of meeting military requirements.  Space traffic management would come later.  Although the definitions are not precise, as SAIC notes, generally speaking space “traffic management” implies that the agency could require spacecraft operators to move their satellites, rather than simply informing them that a collision is possible.  Bridenstine’s American Space Renaissance Act would have directed that a lead agency for space traffic management be designated, and regulations promulgated, by September 2020.

An April 2016 report from the White House Office of Science and Technology Policy (OSTP) proposed a first step, recommending that the Secretary of Transportation, in coordination with the Secretary of Defense, examine planned and actual operational trajectories of space objects and advise satellite operators so as to prevent collisions.  In September, DOT reported to Congress that it is feasible for DOT to take on the role of providing SSA data to commercial and foreign entities.  It estimated that an initial investment of $20 million would be needed, with additional recurring costs for more personnel.