Orbital Satellite Servicing About to Take Off, but Regulatory Certainty Seen Lagging Behind

New space activities like on-orbit servicing often don’t fit traditional regulatory boxes, and it's challenging to move from a traditional oversight approach involving prelaunch licensing to a regime of space traffic management with different types of oversight, said Brian Weeden, Secure World Foundation director-program planning. Rendezvous proximity operations pose questions about the maturity of the technology in question and who has responsibility and ownership during the different stages of the mission lifecycle, said U.K. Space Agency launch systems head Andrew Ratcliffe. Those missions are a space traffic management issue, and inevitably, multiple government agencies are going to be involved in oversight and approval, said Stephen Earle, space traffic lead of the FAA Office of Commercial Space Transportation.

There eventually will be international cooperation on space traffic management issues like on-orbit missions, but rules regimes likely have to be developed at the national level first, Earle said. He said since not every nation has the same capabilities as the U.S. in areas like continuous observation of missions, there has to be a recognition that U.S. capabilities can't necessarily drive international requirements.

Tahara Dawkins, director-commercial remote sensing regulatory affairs office, said parts of NOAA's current rules regime covering non-earth imaging are overly problematic for the industry. The agency is trying to work through that, she said. Such imaging includes cameras on on-orbit satellite servicing missions.

Refueling surely will be the biggest market for commercial satellites at least initially, though the national security sector is particularly interested in the ability to upgrade orbiting satellites, Kennedy said. He said rather than focusing on particularly technical operating standards for on-orbit servicing, which will never be universally agreed to, industry focus needs to be more on guaranteeing transparency of missions, notifying interested parties about flight plans. NASA wants to start employing commercial satellite servicing capabilities, when appropriate, said Jim Reuter, acting associate administrator of the Space Technology Mission Directorate.

On-orbit servicing likely won't be the norm for dealing with most aging satellites. SES Government Solutions Senior Director-Innovation Bryan Benedict cautioned against a servicing bubble of too-many potential operators interested in the market: “We’re not looking at servicing half the fleet.”

Ken Lee, Intelsat senior vice president-space systems, said he has talked to satellite manufacturers about a more-standardized design approach that could accommodate on-orbit servicing. He said the satellite industry needs to develop common interfaces.

Between uncertainty about the future of the use of C-band and new technologies coming online like phased arrays that let a satellite go into any orbital slot, some satellites that are candidates for refueling can quickly turn into something that makes more sense to replace, Benedict said. He said smaller satellite operators likely will become more interested in on-orbit servicing once they see larger operators like SES and Intelsat remain confident in the service.

As satellites last longer, many geostationary orbit (GSO) operators are waiting to see what happens with non-geostationary orbit (NGSO) satellites before investing more heavily in GSOs, and increased use of high-throughput satellites create uncertainty about the need to service older satellites, said Therese Jones, Satellite Industry Association senior director-policy. While it's "promising" there are some contracts to service satellites, "we'll see what the next few years have in store," she said.

When Intelsat does its first mission-extension mission in the second half of 2019 with Orbital ATK's SpaceLogistics, it will be about 300 kilometers outside geosynchronous orbit to ensure that any mishap wouldn't cause debris problems for that orbital plane, said Lee. Doing on-orbit servicing work in the graveyard orbit perhaps should be a norm, required by regulators, he said. "That's our beachfront property." Lee and Benedict said when servicing becomes more routine and the technology more proven, that work could be done in geosynchronous orbit. The two said servicing missions are less likely for NGSO satellites. The size of planned NGSO mega constellations means losing a satellite or a few doesn't affect constellation capacity, Lee said, saying a market for tow truck removal of dead satellites is possible.

CONFERS’ guiding principles for commercial rendezvous operations and on-orbit servicing -- released in conjunction with the event -- say both the servicer and the client will comply with appropriate regulations of the national jurisdictions of involved parties. They say "reasonable provisions" will be made in mission planning to avoid collisions and space debris generation and that commercial servicing best practices "will be based upon actual, accumulated operational experience."