Building a Transparent Regulatory Environment for Space Industry

Richard DalBello has vast experience in both public and private sector commercial space. Before taking over as the Director of NOAA’s Office of Space Commerce, Department of Commerce earlier this year, he was the Vice President of Global Engagement at Virgin Atlantic, where he managed international business development for the company’s fleet of carrier aircraft and space vehicles. Prior to that, he was the Director of Space and Aeronautics in the White House Office of Science and Technology Policy, where he had a key role in the development and implementation of domestic and international space policy and program priorities. The key mission of the Office of Space Commerce (OSC) is to further the economic and technological advancements of the US commercial space industry and position it as a leader in space. The OSC manages the licensing for private remote sensing space systems, and is also responsible for modernizing and managing the US systems for space situational awareness. In this interview, DalBello talks about the growing space economy, his new role, and the immediate priorities for the OSC.

The past few years in particular have seen a spectacular rise in commercial space activities. At the same time, there are more countries that are launching their own satellites and setting up their space programs. How do you view this evolving landscape?

The global commercial space market has seen tremendous growth over the past several years. The Satellite Industry Association (SIA) reports that the global satellite industry revenue was USD 279 billion in 2021. This number shows growth across all segments of the industry, including satellite manufacturing, satellite services, and launch and ground equipment. Also, according to SIA, 97 countries (some in consortiums) have launched their own satellites since 1957.

We are positive that the international commercial space industry will continue to grow, and we will see more innovation in technologies such as satellite servicing, debris removal, space domain awareness, and other technologies that we haven’t even heard of yet.

The Commerce Department was recently charged with the responsibility of implementing a system to monitor both active satellites and debris in orbit to ensure spaceflight safety. We are working with our colleagues in government and industry to accomplish this goal.

This also brings along the need for new norms and rules, and the scope for forging new partnerships. What are some of the prominent moves by the US in addressing these issues?

The National Oceanic and Atmospheric Administration (NOAA), within the Department of Commerce (DOC), is one of the three civil space agencies in the United States. NOAA has been fully committed to consensus-based development of norms and best practices for many years. The exponential growth in the number of commercial satellites, primarily in low Earth orbit, has resulted in the urgent need to establish and promote norms and best practices that allow the industry to innovate while ensuring a safe environment for satellite operators.

In November 2019, the White House published an update to the Orbital Debris Mitigation Standard Practices (ODMSP) document, which addressed emerging issues needing attention. Space-related licenses issued by the Federal Aviation Administration (FAA), Federal Communications Commission (FCC) and NOAA all contain a requirement for the applicants to demonstrate that they have orbital debris mitigation and end-of-life plans that comply with current US government guidelines.

The Department of Commerce was recently charged with the responsibility of implementing a system to monitor both active satellites and debris in orbit to ensure spaceflight safety. My office is working with our colleagues in government and industry to accomplish this important goal. My long experience in government and the private sector will give me the insights I need to guide this program. By blending the best approaches from both the government and the private sector we can ensure the development of a world-class space monitoring system that will provide a standard for the world.

One of the immediate priorities of DOC, as we understand, is helping US companies succeed in the new frontier of space commerce. What does that entail?

The department’s mission is to foster the conditions for the economic growth and technological advancement of the US commercial space industry. One way we do this is through advocating for the US commercial space industry. This can be anything from helping them understand how the government deals with certain issues, to helping them with specific problems they encounter. Another way is by creating a regulatory environment that is open and transparent. These critical regulatory elements will allow the commercial space industry to thrive and innovate. The next step for the US is to ensure proper authorization and regulation of other commercial space missions that are not currently authorized. The goal will be a transparent and predictable streamlined regulatory approach that will help US companies thrive in the rapidly evolving global market.

The department’s new strategic plan released on March 28 this year includes objectives to advance and promote commercial space industry innovation. The plan states that the department will grow the customer base for US commercial space goods and services. We plan to do this in part by leveraging all of our bureaus to assist US companies throughout the commercial space industry with all aspects of their competitiveness, including potential exports.

This year’s budget proposes USD 2 million in new funding for DOC’s Bureau of Economic Analysis (BEA) to provide new space economy statistics that measure the impact of commercial space-related industries on economic growth, employment, and incomes. What is the department’s plan for this — in terms of approach and timelines?

If BEA receives funding to develop space economy statistics, it will provide systematic measures of the contribution of space-related industries to US gross domestic product (GDP) and gross output, along with corresponding space economy employment and compensation. The statistics would build off and expand the initial research BEA has already conducted on the size and scale of the space economy, which was done in collaboration with the Office of Space Commerce, NOAA, and various domestic and international organizations. The statistics would be released in 2023 and would cover the years 2012-2020, including inflation-adjusted measures that reflect growth in space-related production free from the impact of inflation.

A nighttime lights image from 2020 of the contiguous US from the NOAA/NASASuomi-NPP satellite’s day-night band

There have been previous estimates regarding the value of the space economy and its impact on economic growth. How significantly do you think things may have changed?

BEA’s space economy statistics for 2012-2019 show a transition occurring in the US space economy. Inflation-adjusted GDP growth was positive and strong from 2012-2015 (averaging 6.5% annually) and then started to slow and decline between 2015 and 2019 (averaging -0.1% annually). Much of the declines from 2015-2019 were driven by a contraction in direct-to-home satellite television revenues, which dragged down the overall space economy due to its relative importance.

Alternatively, inflation-adjusted growth in manufacturing GDP averaged 7.8% over the period, driven mostly by the computer and electronic products industry, specifically, manufacturing of satellite and positioning, navigation, and timing (PNT) equipment. The BEA data show quality-adjusted prices were declining for space-related manufactured products over the period, while quantities produced were increasing, resulting in strong growth for the sector.

You have earlier said, space safety is one of the most critical issues facing the international community today. What are some of the steps the department has taken towards addressing these challenges?

The Department of Commerce, through the National Institute for Standards and Technology (NIST), provides a framework for US industry to promote standards and best practices in areas such as satellite design, operations and end-of-life disposal. Various Commerce and NOAA subject matter experts, as members of the US delegation to the United Nations Committee on the Peaceful Uses of Outer Space (UNCOPUOS), have been active participants in the Long-term Sustainability (LTS) Working Group. The Working Group produced 21 new best practices and guidelines that were adopted by the UN General Assembly. The DOC and other agencies and departments have regularly scheduled technical exchange meetings with international consortia and individual country subject matter experts to discuss additional norms and best practices.

On April 18, Vice President Kamala Harris announced that the US is imposing a self-ban on ASAT missile testing, and also seeks to establish this as a new international norm for responsible behavior in space. What has been the response from the global community?

We are aware that like-minded countries have either endorsed the US self-ban or declared their own self-ban. For more details, we refer you to the State Department Public Affairs office. At Commerce, we have focused on the reality that commercial satellites and even our own NOAA weather satellites are vulnerable to attack themselves or to damage or destruction resulting from collisions with the thousands of new debris objects created as a result of irresponsible ASAT tests.

The Department of Commerce is also involved in a wide variety of issues and activities related to the US GPS, including GPS policy and management, modernization, international GPS cooperation and GPS interference. GPS interference and jamming has come up as a major issue in recent times, and the call for GPS modernization has only become louder. What progress has been made in this area?

Like most satellite signals, the GPS signals are very low power, making GPS susceptible to interference and jamming. In recent years, the problem of intentional and malicious disruption to GPS has gone from hypothetical to all too real, with cheap (but illegal) jammers offered for sale on the internet, and widespread jamming reported across Europe. GPS modernization is adding new signals to the system, at different frequencies and with higher effective power for robustness and jam resistance. However, we do encourage critical infrastructure owners and operators to shore up their resilience with complementary PNT capabilities that do not depend on GPS alone. That is the focus of Executive Order 13905, under which the Departments of Commerce and Homeland Security are doing extensive work to publish and promote new guidance and frameworks for fielding resilient PNT solutions. The NIST has released PNT-specific implementation guidance for its widely used Cybersecurity Framework, so organizations can prevent cyber disruptions to their GPS equipment, including jamming and spoofing attacks.

How can the Commerce Department play a larger role in this?

The US coordinates GPS policy issues like these across the federal government through the National Executive Committee for Space-Based PNT (EXCOM), co-chaired by the Departments of Defense and Transportation. As secretariat of the EXCOM, the Commerce Department hosts its meetings and staff offices, so we literally sit at the center of the United States GPS policy discussions, while also representing the interests of the commercial industry in EXCOM deliberations. The PNT EXCOM has spent years dealing with threats to GPS and the United States GPS leadership, including rising concerns about interference and jamming. The commercial space revolution has seen the emergence of several companies offering alternative PNT services that improve upon the free GPS with features like cybersecurity and integrity for autonomous vehicle safety. There are also commercial space firms fielding systems that can detect and geolocate GPS interference. The Office of Space Commerce is promoting the consideration and use of such new commercial capabilities to help improve resilience and address government needs.

Space Policy Directive-7 established implementation actions and guidance for US space-based PNT programs and activities for US national and homeland security, civil, commercial, and scientific purposes. What is the progress on this aspect?

The various Departments of the PNT EXCOM are making progress on many of the implementation items in SPD-7, particularly with respect to the demonstration of alternative or complementary PNT technologies to improve national resilience. Just recently, DOT hosted a public industry forum to discuss complementary PNT sources in addition to GPS. Within the Commerce Department, I have already described some of what NIST has done in terms of promoting GPS cybersecurity. The Commerce Department’s National Telecommunications and Information Administration (NTIA) has also continued its important work with the FCC to ensure that new commercial wireless networks do not cause harmful interference to GPS users. The OSC continues to participate in international space dialogs to promote market access for United States GPS manufacturers and service providers.

Leave a Reply

Your email address will not be published.