December 9, 2019
Small Satellite Boom Threatens Congestion in Space
Regulators and policymakers are struggling to keep pace
development. National security applications have helped
with small satellites, spacecraft the size of shoe boxes that
secure U.S. government funding for many smallsat design
are displacing school bus-sized satellites for many
and manufacturing companies, which has enabled them to
purposes. “Smallsats,” as they are known, occupy low Earth
establish themselves financially and demonstrate their
orbit (LEO) at an altitude of between about 310 and 1,200
products while seeking to develop business with potential
miles above Earth’s surface. Many currently in orbit are
commercial customers.
about 10 centimeters wide and weigh less than 3 pounds.
They have been used in government operations, but
The ISS has been an important test bed for development of
commercial companies are increasingly building and
smallsats, especially “cubesats.” Cubesats measure a
deploying them for communications, broadband internet,
standard 4 inches on each side and are modular for easy
remote sensing, and Earth observation missions.
scalability depending on mission. Companies began
sending prototype commercial cubesat constellations to the
Smallsats are launched in clusters called constellations that
ISS in 2012. Test cubesats can rideshare to the ISS aboard
provide coverage and connectivity to greater areas of Earth
resupply missions for a fraction of the cost of an individual
than a single satellite can. The 328 smallsats launched in
rocket launch. From there, robotic arms and special
2018—twice the average number launched annually from
equipment aboard the ISS can eject the satellites into orbit.
2013 to 2017—accounted for 69% of all satellites launched
Between 2013 and 2017, the ISS deployed 725 cubesats,
that year. Some market forecasts project that by 2030, the
allowing many smallsat manufacturers to demonstrate their
number of smallsats in orbit will multiply exponentially.
on-orbit capabilities to investors.
This trend is largely attributable to advances in
microelectronics, shorter development and manufacturing
Figure 1. Cubesat Constructed from Smartphone Parts
cycles, and lower launch costs. Federal and international
regulators have received applications to launch commercial
smallsats to LEO by the thousands over the next five years.
With more than 1,300 satellites already orbiting there,
including the International Space Station (ISS) with humans
onboard, congestion is growing, creating potential problems
with orbital debris, collision avoidance, and allocation of
limited radio frequencies needed for command and control.
Market for Miniaturization
The first satellite launched in 1957 by the Soviet Union—
Sputnik—weighed less than 200 pounds, which would
qualify it as a smallsat as defined by the National
Source: NASA Ames Research Center.
Aeronautics and Space Administration (NASA). Its
functions, however, were limited to rudimentary radio
Crowded Space
transmissions. Most satellites launched in recent decades
Greater use of smallsats promises to add to communications
provide communications transmissions and are far larger.
problems and to increase the risk of collisions in space.
For example, many communications satellites operated by
Intelsat weigh almost 14,000 pounds and are more than 100
In October 2019, the Federal Communications Commission
feet long. These satellites typically cost several million
(FCC) requested the International Telecommunications
dollars each to build and even more to launch, both because
Union, the international organization that coordinates
of their size and the need to put them into higher orbits.
global radio frequency use, to approve spectrum for 30,000
Many smallsats cost a few thousand dollars and can
satellites on behalf of Starlink, a program of Space
rideshare on a rocket with other satellites.
Exploration Technologies (SpaceX). SpaceX has already
received a license to operate a constellation of 12,000
During the past 10 years, miniaturization of electronics,
Starlink satellites in LEO to provide internet services.
optics, and sensors has made much smaller satellites
Amazon is also planning a constellation in LEO with more
technically feasible, stimulating venture capital and defense
than 3,000 small satellites for high-speed internet service.
industry investments in smallsat companies to meet
OneWeb, a company founded in Virginia but headquartered
growing demand for data processing, global connectivity,
in the United Kingdom, is planning a constellation of at
and remote sensing services used for imagery and weather
least 650 smallsats that are expected to provide high-speed
analysis. In 2018, Boeing, Raytheon, and Lockheed Martin
internet to remote areas like the Arctic. China Aerospace
all invested in U.S. startups focused on smallsat
Science and Technology Corporation is planning a 320-
satellite constellation in LEO, also for internet coverage, by
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Small Satellite Boom Threatens Congestion in Space
2025. Thousands of new satellites in LEO could overtax the
be tracked. The satellites were launched anyway. Swarm
frequencies allocated for operators to communicate with
had used a launch brokering company, which claimed not to
their satellites and could interfere with transmissions from
know about the ruling, to book a spot for its payload on a
higher-orbit communications and weather satellites. The
rocket launched by the commercial arm of India’s space
FCC is considering new spectrum sharing regulations and
agency. The FCC fined Swarm $900,000 for the violation.
repurposing of certain frequency bands to accommodate
Even when companies follow rules, mistakes can happen.
these new users.
In September 2019, orbital data from the U.S. Air Force
Increasing the number of smallsats in LEO by thousands
indicated a European satellite and one of SpaceX’s Starlink
would likely increase risk of collisions there. In addition to
smallsats could be on a collision course. As the odds of a
satellites, NASA estimates 6,000 tons of space debris
collision rose to 10 times higher than the threshold for an
occupy LEO. In 2009, an abandoned Russian
avoidance maneuver, the European Space Agency (ESA)
communications satellite collided with an active 1,200-
repeatedly tried to make contact with SpaceX. After
pound satellite owned by Iridium, a U.S. communications
receiving no response to its warning messages, the agency
company. The U.S. Air Force Joint Space Operations
quickly boosted its satellite 300 meters out of the collision
Center monitors objects as small as cubesats in orbit and
path. According to SpaceX, the company failed to note
provides collision warnings to satellite operators
ESA’s messages due to a computer problem.
worldwide. However, some smallsats are so tiny they
cannot reliably be tracked, while others lack propulsion to
Regulatory Developments
make changes of course or altitude.
In 1967, all countries that had active space programs, and
many that aspired to, signed a United Nations treaty
With many companies planning to launch large
establishing standards and norms of international space law.
constellations of smallsats, managing congestion may
A global gentleman’s agreement for space-based activities,
become a challenge. Given the altitudes at which they orbit,
the treaty requires that a state must authorize and supervise
smallsats typically remain aloft for three to six years,
any activities carried out by its nongovernmental entities
although some orbiting close to Earth may fall out of orbit
and that any objects launched into space must be registered.
and burn up within as little as six months due to
The U.N. also issued debris mitigation guidelines
atmospheric drag. For example, Planet Labs, Inc., a
recommending objects in LEO deorbit within 25 years.
smallsat operator, says that of its 351 smallsats successfully
launched to LEO since 2012, only about 140 remain in
Within the United States, oversight of civilian satellite
orbit; the rest have already burned up. Because the FCC is
activities is in flux. Space Policy Directive-3 (SPD-3),
responsible for granting licenses to commercial satellite
signed by the President in 2018, mandated an interagency
operators for use of frequencies, it is also responsible for
effort led by NASA to draft a whole-of-government plan
approving the altitude at which an operator can place its
for space situational awareness (SSA) and debris
satellite. Smallsats on shared payloads, however, are often
mitigation. SPD-3 also directed the Department of
deployed at altitudes other than those designated and must
Commerce’s Office of Space Commerce to take over
use propulsion to boost themselves lower or higher.
commercial space traffic management from the U.S.
military. The Office of Space Commerce currently resides
Figure 2. NASA Rendering of Orbital Debris Growth
within the National Oceanic and Atmospheric
Administration (NOAA), but the Secretary of Commerce
proposed in 2018 to designate it an independent bureau
within the department. A bill that would approve such a
bureau and assign it responsibility for licensing activities
not overseen by the FCC, NOAA, or the Federal Aviation
Administration was introduced in the 115th Congress (H.R.
2809) and again in the 116th Congress (H.R. 3610), but has
not advanced. A September 2019 Senate Appropriations
Committee report (S.Rept. 116-127) expressed concern that
an independent space commerce bureau might not be
equipped to fully replace the military in providing
commercial space traffic management. The committee
recommended an independent review by the National
Academy of Public Administration.
To address gaps in current space governance, an alliance of
Source: NASA, Orbital Debris Program Office.
commercial, government, and industry stakeholders formed
the Space Safety Coalition in 2019 to develop best practices
Solutions and Enforcement Challenges
for avoiding on-orbit collisions and frequency interference.
Certain rules govern how a company should operate its
This effort to self-regulate has been endorsed by many
satellites, but not all rules are enforceable or clearly
smallsat companies.
understood by companies. For example, Silicon Valley
start-up Swarm Technologies makes smallsats that provide
Alyssa K. King, Analyst in Transportation Policy
internet access. In 2018, Swarm filed an application with
the FCC to launch four cubesats to LEO. The FCC denied
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the application, because it deemed the satellites too small to
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Small Satellite Boom Threatens Congestion in Space
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