Insight - Satellite Servicing Standards and Policy: A Progress Report

Monday, September 12, 2022

Since October 2017, Secure World Foundation has, along with Advanced Technology International (ATI) and the Space Infrastructure Foundation (SIF), served as the Secretariat for the Consortium for Execution of Rendezvous and Servicing Operations (CONFERS). CONFERS is an industry-led initiative, with initial seed funding provided by the U.S. Defense Advanced Research Projects Agency (DARPA), that aims to develop and publish non-binding, consensus-derived technical and operations standards for commercial satellite servicing activities and to facilitate the development of a satellite servicing ecosystem. Since its establishment in 2017, CONFERS has expanded to nearly 60 industry members from across the globe. This expansion in the CONFERS membership - and influence - base has tracked to an expanding set of commercial stakeholders developing and fielding satellite servicing and related capabilities (including satellite inspection, satellite refueling and life extension, and active debris removal).

Over the last five years, CONFERS has made significant progress in its primary goal of developing standards for commercial satellite servicing. In July 2022, the International Standards Organization (ISO) published a formal standard, “ISO 24330 - Rendezvous and Proximity Operations (RPO) and On Orbit Servicing (OOS) — Programmatic principles and practices” that was based on recommendations initially developed by CONFERS and is the first international satellite servicing standard. CONFERS has also initiated development of two more standards - spacecraft fiducial markers to support rendezvous and proximity operations (RPO) and prepared in-space refueling systems - that are currently being worked on by the American Institute of Aeronautics and Astronautics (AIAA) Committee on Standards. 

Yet, standards alone will not be sufficient to foster a sustainable and growing satellite servicing industry. There are also a number of other factors that require policy, regulatory, and programmatic actions by governments. With the planned end of DARPA funding support in late 2022, CONFERS will transition to a fully industry-funded operating model. As that transition occurs, it is useful to reflect on the current policy landscape for the emerging satellite servicing sector.

Over the last several months, there have been several significant announcements from governments aimed at advancing the satellite servicing industry and governments’ use of the capabilities provided by that industry. In early April 2022, the U.S White House Office of Science and Technology Policy (OSTP) announced the In-space Servicing, Assembly and Manufacturing (ISAM) National Strategy. This ISAM National Strategy identified six key goals to guide U.S. federal government activities towards supporting the emergence of a “coherent ISAM ecosystem.” These areas are:

1. Advancing ISAM research and development
2. Prioritizing expansion of “scalable infrastructure”
3. Accelerating the development of the ISAM industry
4. Promoting international collaboration and cooperation on ISAM
5. Emphasizing environmental sustainability
6. Inspiring the future workforce

OSTP followed the ISAM National Strategy by issuing a request for comment, which closed on June 30, 2022 to inform the development of an Implementation Plan for the Strategy. 

One subset of satellite servicing capabilities - active debris removal - has seen particular attention. In late June 2022, speaking at SWF’s Summit for Space Sustainability, then UK Science Minister George Freeman announced a series of UK government initiatives designed at enhancing space sustainability, including a continued investment in an active debris removal program in which UK companies will receive additional funding to develop and eventually demonstrate the capability to remove a piece of UK-owned space debris. In late July 2022, the U.S. OSTP released the National Orbital Debris Implementation Plan that included a focus on active debris removal along with better tracking and mitigation. And the Japanese government has continued work in its Commercial Removal of Debris Demonstration (CRD2) program by making Phase II awards to mature commercial close approach and grasping technology as part of a program to eventually remove pieces of Japan-owned space debris. Previously in May 2022, the SpaceWERX technology development office within the U.S. Space Force had awarded small concept studies to 125 companies related to space debris removal and other aspects of satellite servicing. 

Along with these policy and programmatic developments, government oversight and licensing of satellite servicing is also receiving increasing attention. Here, governments are developing specific licensing frameworks for commercial servicing activities, which is largely welcomed by the companies who see a need to have more certainty in regulatory requirements. In August  2022, the U.S Federal Communications Commission (FCC) announced a Proceeding On Servicing, Assembly, & Manufacturing In Space. This proceeding, which is not a rulemaking action, will seek community input on the role the FCC might take in the development and oversight of a sustainable ISAM ecosystem. CONFERS has previously commented to the FCC that there may be a need for specific spectrum allocations for future satellite servicing operations. Most recently, the White House National Space Council announced in August 2022 that it will begin an interagency process to develop regulatory and governance frameworks for novel types of space activities, including satellite servicing. 

The unresolved question is whether these various government policy efforts will be sufficient in creating a landscape in which the commercial satellite servicing industry can thrive. Several of the efforts to develop national licensing regimes have been underway for years already, and it's unclear when they will be finished. Additionally, most of the programmatic efforts are still in their infancy and have yet to amount to the significant funding enjoyed by other more well established space sectors. Making the resolution even more difficult is the interdependent nature of the government and industry efforts: industry is looking for regulatory certainty to be able to plan their future missions, while governments need to know about future missions to establish regulatory frameworks.

Looking ahead, a number of satellite servicing community events in September and October 2022 will provide for further discussion and development of these policy and programmatic efforts, and provide for industry and government interaction. On September 13 and 14, the United States Space Force Space Systems Command, Program Executive Officers (PEO) for Assured Access to Space (AATS) will be conducting a Space Mobility and Logistics (SM&L) Reverse Industry and Collaboration Day. On October 19 and 20, NASA’s Goddard Space Flight Center will host the 2022 ISAM Workshop, which will discuss upcoming ISAM missions, opportunities to collaborate on ISAM technologies and capabilities, and the importance of ISAM services to government agencies. In Europe, the PERASPERA program will host the 3rd European Operations Framework (EOF) workshop on September 28 and 29 to continue work on developing a consolidated European space space robotics community position on guidelines and principles for in-space servicing operations. CONFERS and EOF regularly exchange viewpoints in an effort to remain complementary.

On October 19 and 20, 2022 CONFERS itself will host the 2022 Global Satellite Servicing Forum (GSSF) as a primarily in-person event in Arlington, VA. The GSSF - as the premier conference focused on the satellite servicing ecosystem, will feature discussion of many of the policy, programmatic, and regulatory themes mentioned in this article. Registration for this year’s Forum is open now.  Panels & sessions at the GSSF will discuss topics such as: 

• Providing Policy & Program Frameworks for In-space Satellite Servicing
• Wheeling, Dealing, and Placing Bets on Satellite Servicing
• Mind the Gap: Avoiding Pitfalls in the Servicing Regulatory Framework
• Unknown Unknowns and Dealing with Bad Days in Space
• International Coordination on Satellite Servicing Guidelines & Principles
• The Rising Generation Outlook on Satellite Servicing
• Spreading the Word: Trust, Transparency and Tangible Benefits

Commercial satellite servicing still represents a significant leap in capabilities that will enable future space applications, market creation, and robotic and human exploration. Efforts like CONFERS to establish standards, SWF’s previous work on addressing underlying policy and legal considerations, and current governmental policies and programs are helping to ensure that satellite servicing can evolve into a successful part of the commercial space ecosystem that enhances the overall safety, sustainability, and efficiency of space capabilities.