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Licensing Labyrinth: Regulators Must Support Access to Spectrum for On-Orbit Servicing

July 24th, 2023
Picture of Charity Weeden
Charity Weeden

Space missions cannot be tethered to Earth through a wire: they need to use the electromagnetic spectrum to send and receive commands and to transmit data on orbit. As demand for spectrum increases, this precious and limited resource is increasingly congested, carved up and allocated to space-based and terrestrial services on global, regional, and national scales. Consequently, a lot of resources are spent seeking a spectrum license which weaves through domestic, foreign, and international regulatory regimes, and often mandates coordination with coexisting government and commercial operators.

These many overlapping regimes and authorities for spectrum create a highly complex labyrinth to navigate, even for the most experienced operator. Satellite operators who have successfully exited the labyrinth with a license tend to guard their access to spectrum rigorously to ensure additional actors do not interfere with current or planned operations. All told, the spectrum licensing process is more art than science.

So, what if a new space entrant – with a critical space application, a unique technology set, and funding to support the mission – enters the spectrum license labyrinth, only to find dead ends?

Commercial on-orbit servicing missions such as life extension, debris removal, refueling, and in-orbit transportation – critical new applications revolutionizing the 21st century utilization of space – are just beginning to step into this labyrinth of spectrum access. These particular activities are value-added to the space community, carrying out missions dedicated to improving efficiency of orbits and giving operators new options for longevity and safety in orbit.

On-Orbit Servicing (OOS) includes the critical stage of Rendezvous and Proximity Operations (RPO) in which two space objects are intentionally brought together. These critical stages generally coincide with spacecraft attaining a defined orbit relative to a client object, freezing its location relative to the client, or simply arriving at a pre-identified point in time, event or orbit. Frequently, such time-critical operations are used to coordinate and approve the execution of the next phase or sub-phase of the servicing mission between the spacecraft and the client.

For the majority of spacecraft operations involving OOS and RPO, there is limited dedicated attention – or spectrum – that is needed. However, when it comes to critical segments of the operation, it is necessary to focus efforts and have assured access to spectrum. RPO brings together multiple orbital objects, with orbital speeds reaching up to 18,000 mph. It is a delicate and complex operation that requires robust planning, technologies, and dedicated, focused, attention to complete. Redundant and protected spectrum is needed to ensure responsive command and control without any risk of interference.

As foundational as OOS and RPO are to enabling the growth of the global space industry, no specific spectrum exists for these activities. This should be of concern to all who are working towards the creation of commercial infrastructure, the routine services that will support the global space industry of the future. We need regulators to acknowledge the need and support access to spectrum for these operations.

As the space industry continues to evolve, responsible space policies must be preemptively developed to sustain, and not stifle, growth. To best manage the finite natural resource of spectrum, policymakers need to acknowledge the need for commercial OOS, the applications and requirements for OOS communications, and support the pathway for this growing ecosystem by facilitating access to spectrum. In addition, OOS and RPO operators must work to integrate and coordinate spectrum use with existing services. This is not, and should not be, a spectrum “land grab” for OOS and RPO – history has shown that infrastructure is most resilient when it is interoperable, and these systems can survive and flourish so long as communications at critical points are protected.

And, regulators must establish enabling regulatory provisions for OOS and RPO services, including appropriate requirements on operations coordination and technical requirements, and in so doing establish an assured pathway for licensing OOS and RPO operations.

Commercial OOS providers are entering an already crowded spectrum ecosystem. Regulators in international and national regimes should invest and sustain innovative capabilities through a proactive response to spectrum requirements for commercial OOS and RPO services. We need to encourage the maturity of OOS technology, enhance the safety of commercial operations, and accelerate the surety in the license process.

Let’s work together to support new space activities’ efforts to successfully exit the labyrinth of spectrum licensing. VS

Charity Weeden is vice president of Global Space Policy and government relations at Astroscale U.S. Astroscale is a global on-orbit services company dedicated to the safe and sustainable development of space for the benefit of future generations.