Today’s Tidbits: September 11, 2022

So much has been happening recently that it’s tough to keep up with all the news so we are resurrecting our “tidbits” feature to provide at least a glimpse, if not as much context as usual, into three important stories over the past few days: DOD and the Department of Commerce signed an agreement on Space Traffic Management, the National Academies reported on whether Ligado will interfere with DOD’s GPS system, and DOD issued a new space policy.

DOD and Department of Commerce Sign Agreement on Space Traffic Management

Four years ago, President Trump signed Space Policy Directive-3, directing the Department of Commerce (DOC) to become the interface with the civil and commercial space sectors on Space Situational Awareness (SSA) and Space Traffic Management (STM). DOD has been responsible for tracking space objects and warning of potential collisons for everyone all these years. With the tremendous growth in the amount of space debris and number of operational satellites, it wants to be able to focus on its national security responsibilities and let a civil government agency be responsible for civil and commercial satellite operators.

On Friday, the two departments finally signed a Memorandum of Agreement spelling out their respective roles.

Progress has been slow for a variety of reasons, including the fact that it took time for Congress to warm up to the idea of DOC’s Office of Space Commerce (OSC) assuming this task. OSC is part of the National Oceanic and Atmospheric Administration (NOAA) that operates the nation’s weather satellites.

During the Trump Administration, then-OSC Director Kevin O’Connell started building an Open Access Data Repository (OADR) incorporating data on space objects from DOD and commercial sources. But the office had only meager funding as congressional appropriators awaited a report from the National Academy of Public Administration on whether DOC was the right place for the job. The 2020 NAPA report said yes and funding began to increase, but then the Administrations changed and it took President Biden 15-months to name O’Connell’s successor, Richard DalBello.

The Biden Administration now has finally embraced the effort and is requesting a substantial increase for OSC in FY2023. It also elevated OSC to a higher level within NOAA. With the signing of this MOA, perhaps progress will accelerate.

Rick Spinrad, Under Secretary of Commerce for Oceans and Atmosphere and the head of NOAA, said “Establishing and maintaining coordinated SSA and STM technology, data, and services for civil and commercial entities is the foundation of the Department of Commerce’s efforts to ensure the continued safe and sustainable growth of the commercial space industry. ” He added:  “We are pleased to partner with DoD on this important and timely effort as we collectively support new services, research and innovations to further our vision of a sustainable space environment for all.”

DOD’s Assistant Secretary for Space Policy John Plumb said “We are pleased to partner with DoC on this effort and look to broaden our relationship with industry, allies, and partners to help achieve the objectives of SPD-3. We also take this opportunity to encourage and invite commercial or other partners who can assist in this effort.”

National Academies Agrees Ligado will Interfere with DOD’s GPS Receivers, But Not Everyone’s

Also on Friday, the National Academies of Sciences, Engineering, and Medicine (NASEM) released its eagerly awaited report on whether a terrestrial cellular system proposed by Ligado Networks will interfere with DOD’s Global Positioning System (GPS) receivers.

DOD has been sounding the alarm about the effect of Ligado’s system, previously known as LightSquared, for a decade or more. It argues that the frequencies Ligado will use for its terrestrial system will create harmful interference with GPS receivers. Ligado got approval for its system from the Federal Communications Commission (FCC) in 2020 after making modifications and proposing mitigation measures, but DOD, with the backing of key members of Congress, has been trying to overturn it.

In the FY2021 National Defense Authorization Act, Congress directed that the National Academies convene an expert committee to conduct an independent review of the FCC’s decision, FCC Order 20-28.

The Academies’ study committee was chaired by J. Michael McQuade from Carnegie Mellon University. The report, Analysis of Potential Interference Issues Related to FCC Order 20-48, is very technical, but the bottom line is that although Ligado will not create harmful interference (the report goes on in some detail about the use of that term) for most commercially-produced GPS receivers, the high-precision receivers used by DOD are the most vulnerable. However, it adds that technology is available to make all GPS receivers “robust to Ligado signals.”

The report also concluded, however, that Ligado will interfere with Iridium mobile communications satellite system receivers, which use an adjacent frequency band: “Iridium terminals will experience harmful interference on their downlink caused by Ligado user terminals operating in the UL1 band while those Iridium terminals are within a significant range of a Ligado emitter—up to 732 meters.”

DOD sees the report as confirming its claims:

The NASEM study confirms that Ligado’s system will interfere with DoD GPS receivers, which include high-precision GPS receivers. The study also confirms that Iridium satellite communications will experience harmful interference caused by Ligado user terminals. Further, the study notes that when DoD’s testing approach, which is based on signal-to-noise ratio, is correctly applied, it is the more comprehensive and informative approach to assessing interference. The study also concludes that the Federal Communication Commission’s (FCC) proposed mitigation and replacement measures are impractical, cost prohibitive, and possibly ineffective.

The Senate Armed Services Committee’s chair and ranking member, Sen. Jack Reed (D-RI) and Sen. Jim Inhofe (R-OK), who have fiercely defended DOD’s position, released a statement again calling on the FCC to “to stay and reconsider their 2020 Order.”

Ligado reads the report completely differently: “NAS found what the nation’s experts at the FCC already determined: A small percentage of very old and poorly designed GPS devices may require upgrading. Ligado, in tandem with the FCC, established a program two years ago to upgrade or replace federal equipment, and we remain ready to help any agency that comes forward with outdated devices. So far, none have.”

It seems the debate will continue.

DOD Issues New Space Policy

Although issued on August 30, DOD released only last week a new Space Policy, replacing the version from October 18, 2012 as amended in 2016.

A lot has happened since then, with the reestablishment of U.S. Space Command in August 2019 and creation of the U.S. Space Force as a sixth military service in December 2019.

The 20-page document spells out DOD’s space policy, starting with recognizing space as “a priority domain of national military power that underpins joint and combined military operations to advance national security.”

The policy calls for cooperation not only with others in the U.S. Government, but international and commercial partners. DOD will “Strengthen space-related alliances and build new partnerships that provide a durable strategic advantage for the United States, and its allies and partners” and “Leverage and promote a thriving domestic civil and commercial space industry, including expanding and increasing emphasis on innovative and emerging commercial space capabilities.”

The policy incorporates Secretary of Defense Lloyd Austin’s five Tenets of Responsible Behavior in Space, issued last summer.

As formalized in the DOD-DOC Memoradum of Agreement signed on Friday and described above, it also says DOD will cooperate with DOC on Space Situational Awareness.

Nine pages are devoted to detailing the responsibilities of a wide range of DOD officials from the Under Secretaries of Defense for Policy, Acquisition and Sustainment, Research and Engineering, and Personnel and Readiness, to the Directors of the Defense Intelligence Agency, National Geospatial-Intelligence Agency, National Reconnaissance Office, and National Security Agency/Central Security Service, to the Secretaries of the Military Departments, to the Chairman of the Joint Chiefs of Staff and to the Combatant Commanders especially U.S. Space Command.