Orbital Data Centers and Space Sustainability: Policy and Safety Implications

Okay. Well, good afternoon everyone. Um, I guess we'll start. Thank you so much for joining us today on this panel for orbital data centers on space safety and sustainability organized by the Secure World Foundation. So, my name is Alex Shei. I'm a senior program analyst at SWF looking at space safety matters. Um, and my background is a mix of policy and tech. So I got my doctorate in aerospace engineering focusing on space sustainability and before that I worked a number of years in government policym um and I'm going to be moderating our panel discussion for today. Um so before we start I wanted to give a little bit of a background on this topic. So over you know this past year we've seen very fast growing interest in orbital data centers or ODC's. Um we've seen you know a number of companies filing applications with the FCC and there's also you know growing interest and activity overseas as well and from the way we look at it when we look at these proposed constellations uh we find that there are a number of features that really set them apart from the satellite constellations uh that we see today. So most notably in the number of satellites um for scale we have about 16,000 active satellites orbiting you know over overhead today and many of these uh ODC um applications are actually orders of magnitude larger with up to a million um satellites right um in addition to that um a lot of them are also looking at very you know large uh size solar panels to address the uh energy use needs and we see a lot of concentrated interest in sun-synchronous orbits or SSOs Um and some of them are also looking at you know using optical links instead of the traditional RF frequencies. Um so um in this context the Secure World Foundations has actually filed uh comments to some of these uh company applications with the FCC and in these comments we um recognize you know the importance of supporting commercial innovation but at the same time we also see um a number of unique space safety and sustainability considerations that pertain to these ODCs and that's what we're here um to talk about today. Right. So here in the US today um the the the you know scope of ODC's and the potential impact that they may have do not cleanly fall within the remitt of any you know single one agency although we do have the space commerce cert certification which I understand now has the you know green light to go ahead. So that might touch on some of that and address um some of that we can talk about that a little bit later. Um but in general what we see is is a need for a more kind of coordinated measured approach to looking at these uh uh satellite constellation proposals and authorizing them for certainty as well as uh consistency. So um we also understand that you know there's a lot of active discussion today about the technical and economic viability of orbital data centers in space. So those are very important questions but that's not going to be the focus of our panel discussion uh for today. Nevertheless, we're going to be interested in the associated uh policy and operational implications of some of these. So, specifically questions like, you know, what um what can space policy and safety measures do to ensure a safe and stable orbital environment while facilitating innovation as the technology and economics of orbital data centers uh continue to develop. So, that's a very big question. Uh fortunately, I don't have to answer it. we do have with us you know an esteemed panel of experts with very very diverse experience and expertise um to shed some light on this topic. So I would like to now just give a very brief introduction of our panelists. Um they will probably share more about themselves when they speak. Um so to my right here I have Ron Burke uh principal director of the space enterprise evolution uh directorate of the aerospace corporation. So Ron has had decades of you know experience in aerospace system strategic planning both in government and in the private sector. Um to his right we have Matias Kava the national space policy lead at the office of space commerce. So Matias oversees the uh regulatory reform uh for mission authorization for novel space missions um in the US including space commerce certification that I just mentioned. He also has prior experience in the FAA on re-entry um and launch licensing. And to his right we have Jeff O'Neal which is who is the director of government affairs of Planet Labs. So Planet Labs I understand has an ongoing collaboration with Google uh for proposed orbital data center constellation uh project suncatcher I believe that's what it's called. So in uh in his role Jeff uh works with federal agencies and congress on remote licensing uh policy. Um I believe he also has experience on Capitol Hill. And finally, last but certainly not least, joining us virtually, we have Ezra Felden, who is a co-founder and CTO of StarCloud. So StarCloud is one of the companies who has filed a formal application with the FCC for an orbital data center and at StarCloud, uh, Ezra oversees ODC, uh, development. So uh, very well a warm welcome to our panelists. Really looking forward to the discussion today. Um, and just one more point I think before we start on audience questions. So we do uh intend to take audience questions via slidoh. You will see a piece of paper on your p on your tables with the QR code. So feel free to you know scan them um uh and enter your questions at any point. We will try to weave them in during our discussion but if not we will have some time set aside towards the end for audience questions. Um so yeah with that now out of the way um I wanted to start by maybe asking our panelists each to briefly share your interest and background on the topic and then maybe start by talking through some of the broad uh sort of risk and governance related considerations of ODC's that you see um in your role. So uh maybe you know for the operators uh perhaps we can get an operator view in terms of what a safe and stable orbital environment uh requires and what new considerations ODC's might add to that and maybe you know for Matias and and and Ron um on the governance side you know what sort of um maybe policy or coordination gaps um do you think we need to maybe pay a little bit more attention to with this development um whether it's across government agencies or maybe even internationally. So >> yeah. >> Yeah. Happy to happy to start kick it off uh from an operator perspective. So um for for those of you who don't know a ton about Planet, we are mostly known for taking pictures of the Earth. Um we take a daily uh basically a daily scan of the Earth with a couple hundred satellites. Uh been doing that for over 10 years now. um trying to leverage uh both sort of what we call medium resolution, pairing it with high resolution capabilities um or hyperspectral capabilities to um make better decisions here on Earth. So what we've been gotten really good at is building large building and operating a large constellation of uh Earth imaging satellites. Uh I've launched up uh almost 700 of them over the course of the history of the company. Um, so we've gotten really good at figuring out how to um get the sort of technology up there, uh, leverage those capabilities to image the Earth, um, de-orbit them safely, um, maintain our sort of safe orbital environment where we want to continue operating, uh, and then sort of continue to innovate sort of through this agile approach to to aerospace manufacturing. So taking you know commercial off-the-shelf technologies uh getting satellites up there into space at at fractions of the cost that uh you know some of the larger satellites uh may operate with and still getting that value for our customers. And so uh as we you know sort of think of the the planet of sort of here today and where we are uh you know Google has sort of come to us and said hey uh can we leverage that sort of agile approach to uh aerospace manufacturing and take that to sort of orbital data centers and so uh we we have this uh project suncatcher uh ops mentioned uh to help test out some of those capabilities. So take Google's processing units and uh put them up in space. So it's going to be on sort of our next generation owl platform. Um so instead of putting a telescope on it, we're going to put uh these uh data processing uh uh instruments. And so for us as we are thinking about how we sort of in a measured way test out the capabilities and sort of scale we want to both protect our you know existing business and sort of where uh satellite operators are today uh and make sure that we are sort of scaling appropriately and say let uh laying the right foundation here today so that as you know uh earth observing satellites as communication satellites as these potential orbital data centers are continuing to operate operate harmoniously. Uh we're doing so in a way that everyone can have that same access to serve their customers um as well. So that that's sort of the framing I think that uh you know planet and and I'll bring to the conversation today. >> Yeah. >> Yeah. I'll I'll jump in next. Yeah. Pleasure to to speak to you today. Thank you for for having me on. Um as Alex mentioned, my name is Ezra Fielden. I'm the co-founder and CTO, chief technology officer of StarCloud. I started StarCloud with my two co-founders about two and a half years ago um with the the objective of deploying large scale uh data centers in in low Earth orbits. Um back in 2024, this was a a pretty unusual idea um which was met with a lot of skepticism um from from many many different directions. Um so it's it's been it's been great to see um how rapidly it's been accepted and now I would say is even the consensus view that we will deploy gigawatts of compute into low earth orbits. Um and uh yeah I'm very happy that star cloud any role that starcloud is played in uh in in in that transition in in the industry. Um we've been thinking about this problem for I think longer than than anyone else. So like I say, we've been uh completely dedicated to this problem for around 2 and a half years. Um and um I think it would be helpful to just spend 30 seconds talking about why these um orbital data sensors are are an attractive proposition. So the reason why we're building this is AI requires an enormous amount of power. Um I'm sure the audience is familiar with with scaling laws. These these are a set of holistic um empirical rules which is which have demonstrated that for AI to be more capable and smarter, we need the chips need to get larger and more power hungry. Large numbers of chips need to be deployed together and those chips need to to think on on the problems that we give them for longer. All three of these factors means AI is requiring more and more power to to be smarter and smarter. The problem is we can't build enough power on the ground in especially in the western world. We really struggle to build large scale energy infrastructure. Um and the the grid simply cannot keep up with the exponential demand that's coming from uh from AI. And so to to maintain the US's leadership in this in AI um we we need to look at all options including orbital data centers. Um and uh and really this uh It's it's I I I believe this is an an existential risk for for the US if the US loses its leadership in AI to to other international players outside of the West. So that's the the context for why this is attractive. Um as far as um what's required for a safe um orbital environment for everyone, I think the the example that we should be following is is that of of Starlink. Um so Starink has roughly 10,000 active satellites in orbit today um and have been operating um essentially without uh without any major um safety issues. Um so I think this is a clearly a good worked example for for the industry to follow regarding conjunction avoidance regarding beginning of life end of life. Um and I think this is yeah a template that industry can follow um until each each of uh you know each of these uh industry players have a commen similar level of experience and and capability with with large scale constellations. Um yeah to get a little bit more specific um the the good example which I'm talking about is deploying satellites to a low altitude initially so that they can perform checkouts um uh at uh in a regime where if there's an issue they rapidly the orbit. Um coordinating orbit rays to their final operational orbits. um having satellites being uh the constellation being very responsible with reliable propulsion and critical subsystems, having transparency of um the satellites operations and publishing um ephemeras and tracking data very freely um and at the end of life um ensuring we have a rapid de-orbit um passively um with full demisability um uh yeah the demisability I is in particular is is is very important. Um and proposals which require um a directed re-entry um I think should be that we should take a very close look at uh at uh the safety implications of that. Um yeah very happy to talk to to any of those points in in more in more detail. Um but that's uh that's what a safe orbital environment looks like from from StarCloud's perspective. Thank you, Esra. Um, Ron Matias, your end. >> So, my name is Matias Cava, uh, recovering lawyer. I'm now at the Office of Space Commerce, uh, and I'm working mission authorization. And for those of you who don't know what mission authorization is, the office of space commerce was tasked with filling the regulator or the governance gap that Alex mentioned in her question uh with regard to activities in space that are not clearly or straightforwardly regulated. Um now just to set the scene, FAA regulates launch and re-entry. FCC regulates radio frequency. uh KrisRA regulates remote sensing. A lot of what ODC's do is not in that list, right? And regulation governance follows policy, right? FCC uh via the Open Sky policy, FAA, via uh just public safety policy in general. Now, placing mission authorization at the Office of Space Commerce suggests that the US government recognizes the potential that ODC's represent. Uh, but precisely what the commercial lens means, I think, has yet to be determined, right? And I think that that's what we're looking to do at the Office of Space Commerce as we begin to accept applications. >> Thank you. Yeah, Ron. >> All right. Thank you, Alex. Um, so Ron Burke, uh, with the Aerospace Corporation, which is a federally funded research and development center, uh, for the United States, um, whose purpose is, uh, to support government agencies in assessments and analysis associated with the evolution of space systems. Um and I think it's important to um to add the note that there's an expectation from our government sponsor that we uh enhance and enable the success of companies as well um in in in the context of US leadership in space. So uh the group within u aerospace that that I support is the space enterprise evolution directorate uh which really focuses on the areas of space that are evolving uh into the future. Um and and colloally um I I I I tend to say uh looking at the areas of space that look very different through the windshield than they do through the rearview mirror. Um this clearly is one of those um and areas and Ezra pointed out um two years ago this was a relatively um nent uh topic uh that didn't have clarity on really where it might go or or or how it might get there. Um over the course of the last two years a tremendous amount um has transpired and and and progress has been made. So [clears throat] in the context of of those elements um our role um is to support [clears throat] both uh the government in terms of the physics and engineering um assessments of the viability and um independent objective um assessments of performance of these systems and be informed um on when they might be available for purposes that the government may have. Um and that's been an interesting topic in itself. >> Yeah. >> Technical difficulty. >> Yeah. >> Okay. Sound check. Okay. All right. Thank you for uh for that patience. Um so uh both in terms of and helping them to appreciate um when and and sort of where the opport the act the capabilities will be available um and applicable um as well as an expectation that we support any hard problems that might be um identified along the way. In the context of that uh there's also a legacy expectation for aerospace to conduct uh debris analysis. Um we have a center for orbital um re-entry and debris, our chords center. Um and uh within that context um our subject matter experts um are looking at this domain um and recognizing the importance of applying time and talent to be able to model uh these uh capabilities into the future. Um as well as to be able to uh close gaps in both analyses and modeling capabilities um including the identification of thresholds for metrics. And I appreciate how important that is, Matias, in your work. Um, and um, being able to assess uh, the degree to which uh, the uh, disposal approaches um, are sustainable. uh to to points Ezra and Jeff made um as well as assessing the robustness of our uh space situational awareness uh capabilities to be able to monitor um all of these systems and and their dynamic uh activities over time. >> Thank you, Ron. Thank you panelists for talking that um issue. So um I want to maybe you know come back to our operators for a minute and maybe touch on something that Ezra mentioned a bit earlier. I think you mentioned that you know Starling has uh kind of set an industry standard for safety of operational safety um in in space. Um you know they have 10,000 satellites in terms of collision uh assessment and u maneuvers. Um you know they're doing a good job but um I want to maybe just pull on that a little bit in terms of you know some of the ODC constellation proposals that we're looking at. a lot of them are um several times larger than that than 10,000 satellites that we see and we may also have several operators you know having that number of satellites operating in very close or very similar orbits so I'm wondering from your perspectives for both operators um is it you know how do we kind of you know address the safety and sustainability aspects of that is it kind of just doing more of the same or is there something different uh that we need to be looking at and in that sense um is there any role that policy you should be looking to play if you're looking at, you know, doing additional uh safety measures. >> Ezra, feel free to start. [laughter] >> I can jump in. I think I think industry coordination is the key really. Um the if so it's it's uh one one can imagine that um if a single operator deploys into a single shell um of even to a very high density um you know let's say thousands of satellites in a single in a single shell. um the number of conjunctions can be very low um if the the satellites are all co-orbiting um and orbit rays in orbit lower in in a way in a manner that's well coordinated with the with within the constellation. I think the challenge really comes when um you have multiple players multiple diverse constellations um which are doing performing these activities um without uh close coordination. So I think that that's really the role that um that uh the regulators can play is that that is encouraging and facilitating very close coordination between um different providers um who are looking [clears throat] to to use similar orbsol regimes. Um I I think I think that's the most important point um on this topic. Yeah, I I'll I'll add to that and I think you've sort of heard this thread around um you know for for me I'm still thinking about it in terms of the the coordination frameworks and uh for us having um the the right SSA capabilities that are sort of trusted um you know OSC has obviously been working on this for a number of years so have the Europeans and Chinese are doing their own thing right so there is this spectrum uh where it's a really strong important role for the US government to play to create this trusted data set that's based on all the transparency that Ezra and I have been talking about around you know operators publishing their ephemerous data. Uh it includes better um modeling of the the space environment. Um you know space weather uh was actually the first panel I spoke at for secure world foundation years ago when I was on the hill. uh and that is still very important so that we can understand the the density of the different um you know orbital altitudes and what is happening in more real time uh and so those are places where I think we need to continue to spend time on today uh that is going to help these orbital data centers as they get off the ground that's going to help remote sensing operators the the comm's operators so I I think as we're we are thinking about this new problem of million plus satellites you know up there uh It's still in some ways foundational to sort of how we take these bite-sized pieces and we say, "Okay, let's still continue to work with our international partners to uh create those sort of trusted partnerships on on SSA data sharing um and and let's create the right rules of the road with operators so that we can encourage that operator operator communication um and sort of those uh those standards that we can help create. So I I think all of that is leading towards uh helping today's environment and allowing us to scale in the future. >> Right. Thank you. Yeah. So SSA capabilities certainly comes up as a very uh you know talked about topic when we when we speak to others about this topic as well. I'm actually interested in hearing you know what Ron and Matias might have to say uh in this regard whether it's in terms of the technical capabilities or maybe the tracks initiative. um just you know in the sense that you know how well can our current uh SSA capabilities and mechanisms whether it's the hardware part the software part the policy part scale to kind of address some of these considerations that the ODC constellations uh bring up is there you know anything more that we need to do are there capabilities data that we need to have that we don't have today that will help us address this better >> absolutely thank you um so it it it is worth noting um that the the systems [clears throat] uh that are in play today um weren't designed uh for the volume and and the attributes or the characteristics of orbital data centers. Uh so there is um the need for um addressing a scaling issue uh to be able to have sufficient uh sensing capability with a s sufficient um accuracy to [clears throat] be able to not only monitor where all of the spacecraft are and and have a current and accurate representation of where all of the spacecraft are. uh but also to be able to understand the potential for maneuverability um and to be able to track and keep up with uh spacecraft as they move uh relative to their existing positions. Um it's it's noted there was a aerospace uh u u America uh article that came out uh this week uh and it's noted in that that article that um in the current constellations there are hundreds of thousands of maneuvers that are done annually. uh that in a environment with up to a million uh spacecraft um that could be more like a half a billion uh maneuvers um over time. So that that sets the stage for uh more robust uh sensing and um and um um exchange of current and accurate information of location. Um, it also sets the stage for more robust modeling um and digital engineering environment configurations to be able to not only keep up with where everything is, but to be able to do assessments of what uh different um uh decisions might have um on where things will be. >> Yeah. I mean, I think that these constellations raise a few concerns, right? I mean orbital congestion certainly dark skies is another one the effects of re-entry another one and there are part fit solutions here right so tracks which is in its pilot phase has done I think a good job in terms of SSA in terms of atmospheric re-entry there are some overlaps with FAA regs in so far as the FA a has authority when something re-enters the atmosphere partially intact. In terms of dark skies, you know, we just saw uh the FCC say that uh they are limited in their statutory authority, right? There are some aspects of nonrf behavior in space that they can't regulate. Um and those certainly implicate uh what operators do with respect to dark skies. I mean these are as I said part fits. Um and if you want a full solution uh then uh I think you'd need Congress to act to give statutory authority to an organization agency. >> Yeah. Um thank you Matias for mentioning some of these potential externalities because that was going to be my next question. So I wanted to ask you know as you mentioned you know today you know that authority is kind of you know spread out and I was wondering maybe uh you can talk a little bit more about the spacecommerce certification which of these aspects you think that might be able to address through the inter agency mechanism which of these uh maybe you know not yet might need more authority I think people are also wanting to hear more about it I've got one in my audience questions asking about the impact of space commerce certification on companies including those looking to to build orbital data centers is >> so the space commerce certification is tasked with uh making sure that the United States fulfills its outer space treaty obligations. Now the outer space treaty requires that each state supervise and authorize the actions of its nationals right activities in space. Now the US is doing this but as activities get more innovative more more interesting [snorts] um those that framework which is fragmented right now gets harder and harder um it gets harder and harder to maintain our treaty obligations right so with that in mind the certification is tested with two things one streamlining author authorizations for inspace activities and two authorizing activities that are not clearly or straightforwardly uh regulated at the time. Now I've already listed kind of where different agencies authorities lie. The way that the space commerce certification will operate right now um because it is derived from an executive order executive order 14335 is that it will leverage FAA and FCC statutory authority. Now, what does this mean? Okay. Well, for the for an an applicant, let's say an ODC applicant, they will apply to for a space commerce certification and the office of space commerce will act as kind of a clearing house for the most kind of important question, which is will the US government authorize this activity in space, right? And in order to do so, it'll work with the FAA to ensure that uh the applicant can satisfy certain parts of the FAA's uh regulatory requirements. And I'm thinking in particular about payload requirements. Uh and for the FCC, we're talking non radio frequency requirements, right? And in order to do so, this means bringing in DO for national security matters, uh, Department of State for foreign policy, international obligations, and NASA for long-term viability, right? in order to satisfy FA and FCC regs and to ensure that the applicant only has to go through one review of those equities, national security, foreign policy, international obligations, longterm viability. As you can tell, I've said that a lot. Um, we want to kind of be the organizer, right? to ensure that earlier in the process than let's say the day before launch an operator can say publicly look the US is going to approve our plan in space now that does there are certainly limits though without statutory authority right what about activities that don't clearly implicate those equities that I listed um but the US nonetheless wants to ensure um it is continuing to supervise, right? Things fall through the cracks eventually in a fragmented system. So again, to plug those holes, um I guess the refrain is we need congressional action. >> Thank you very much for that. Um so I think I I wanted to maybe touch on a related point here. Um so in these you know FCC applications and the comments that uh we filed for many of the reasons that Matias mentioned um we had a proposal to essentially look at a parallel notice of inquiry process where we can tap on the inter agency to uh kind of first identify uh you know assess and then maybe manage some of these potential externalities of um orbital data centers um from a whole of government kind of approach. So I think you know you might have addressed a little bit of that but um I think in our comments we also you know saw some of the uh responses come from companies and here I want to thank you know StarCloud um just for supporting our suggestion on this um and I wanted to maybe build on that to ask uh you know Ezra um that you know if such a process were to go ahead what you know in your view or who in your view should be involved in such a process is it the you know same agencies that Matias mentioned anyone else you want to um involve um but also um what role can industry play uh in that and you know Jeff feel free to jump in as well. >> Cool. Yes. So I think the most important thing is um space safety right is uh is is absolutely paramount that other other externalities um do require some thought but space safety should be absolutely top of of everyone's um of everyone's priorities. Um, and the the FCC is well placed to to evaluate the the safety of the constellations which it approves and that that historically has has sat within the purview of of the FCC. Um, and um and I believe it will continue to to do so. Um so yeah, StarCloud um supports and is is willing to participate in a a process which can holistically evaluate um all of the ODC proposals together rather than rather than one by one. Um and you know that's that's likely to involve input from from NASA um on on space safety as aspects. Um in with that in mind um we believe that aggregate risks can can be lower um conditionally lower than than many have have suggested. For example, uh Ron Ron mentioned the um you know half a billion maneuvers per year which which we could see with um with with the numbers that are being deployed. those those those analyses assume that the number of conjunctions scales with the number of satellites to the power of two. So it's an n squ kind of relationship. Um and and that assumption holds when the satellites are um have conjunctions among themselves um as as most communications uh satellites do today. Um that assumption does not hold if the constellation is co-orbital. So if the satellites are all orbiting um in in one circular orbit um without intersect without multiple planes intersecting. Um so um I I think I think the the FCC should absolutely take time to to look at some of these aspects and to acquaint themselves with um with uh the implications of these um of these factors um and in particular look at dawn dusk sunsynchronous orbits as a as a special case in a way um so dawn dawn sso is is a very special orbit. is the only low earth orbit which has the potential to receive continuous sunlight for for most if not all of the year. Um and so it has this very special property and it's um and it's going to be most of the ODC um proposals target this orbit with with one small exception but almost all of the ODC constellations will be deployed exclusively into dawn dusk sun-synchronous orbits. Um and so given the density of satellites that are going into this orbit and the the very special properties of this orbit, I think um we should start to look at it in a similar way that we look at um in a in a similar vein that we treat geostationary orbits as this very special orbit with a high density higher than usual density of satellites which requires a different framework to to to to coordinate. Um, so that's something that I'm uh I'm very passionate about. Specifically in in uh in StarCard's case, we are very enthusiastic about coordinating all of the users of this orbit um to or to to into either dawn dusk or dusk dawn. If we if we have a mix of dawn dusk and dusk dawn then we have a we have the potential for a huge number of um conjunctions. Whereas if if all of industry can decide at least in some altitude bands that um all the satellites that will be deployed in that band will be co-orbital. So let's say either dawn dusk or dusk dawn and not a mixture of those two then that can be that can that can enormously eliminate the number of conjunctions um that we'll see. And I think that's something that the FCC and and others can can be very helpful in um in uh in supporting and coordinating um following a um uh a review of of of all these proposals in in aggregate. >> Thank you Ezra. I think um yeah maybe R you want to add to >> Yeah, thank you Alex. Thank you Ezra. Um just something to really highlight, right? Really shine a spotlight on that Ezra just just said um is the importance of not only looking at each um individual you know deployment not only of individual spacecraft which is what our legacy um is all structured for. uh but and not even just the constellations but the set of constellations. Um we are clearly seeing an evolution of space ecosystems. Uh we haven't used that word yet in this session. U but it's something that is clearly happening. Um and in the context of um the volume that we're talking about for ODC's where in the context of a larger global community of over 12,000 space companies um that are all deploying different kinds of capabilities all of which have to be taken into consideration. So I just wanted to sort of highlight u and resonate with the point that it's really important to have a viable and trusted model of how all of the systems will operate together um in order for the owners and operators to be able to interoperate together um in just from a practical operational perspective as well as for the government to have that information to be able to inform their decisions. Yeah, thank you. >> Thank you, Ron. >> I just had a point maybe slightly different, but back to sort of the governance piece and and sort of the agencies involved and and we appreciate OSC has sort of taken this role of um being the clearing house, I think was the term you used, right? And and having one to the inner agency that's going to uh involve a lot of opinions. Um important to that process though is sort of the timeliness to how industry operates, right? And so, you know, I think we've we've heard this a lot and as we're thinking about sort of what Congress is looking at providing to, you know, OSC as well. Um, there are firm timelines involved, uh, so that we can get answers and it's not just this continual we're going to keep looking at it, we're going to keep looking at it. Uh, it should be either a yes or a no within certain time frames. And then we need the transparency about why there may be concerns on something. And it gets a little difficult when you have, you know, we've seen this in the the Krill world where, you know, there's an inter agency process that happens and we don't know everything that happens behind closed doors. That's that's for the government to do. Uh but we do need that transparency to industry so that we can know what is uh sort of the the best practices that government is comfortable with and that they can work on the time scales that we need to launch our spacecraft. So, you know, as much as uh you know, we Kris has been doing a lot better job on it. Um you know, FCC has been doing a lot better job, everyone's adopting these timelines as well. Uh so I think the as we're thinking about how we set these up and we still rely on the responsibilities of FAA, FCC, KRESA, NASA and State Department and others, we still need to also um maintain that there is a single leader who's responsible for it. So having commerce responsible for that is great. uh and uh having them sort of shepherd through uh the process as well because I think that's going to allow as you see you know constellation operators and you know Ezra and us you're going to see us iterate as well and so there's going to be you know slight differences of you know our v2 versus our v1 um and that's going to be a different review process uh from the government perspective and so if we're innovating that fast so that we can actually uh scale appropriately we need the systems to be in place um with the feed back in order to help us continue to to innovate. >> Thank you. Thank you very much. Do you want to >> Well, I I guess I would just agree that transparency is really important and also we're committed to real timelines, timelines that are uh that everybody knows going into the process. Right now I should say also that the the delays that arise in the current system are not the product of anything malicious. Right? Um you have different equities looking at the same operator's application at different times for different reasons. Right? uh state department looks at an FAA's launch uh license in so far as there's a payload review and then separately we'll look at that same license when the operator goes to the FCC. Um now that that's a duplicative process, right? Not intentional. It's just the it's just the natural product of a system that has developed over decades rather than through one administrative act. Um that said, have ensuring that that review does only happen once and h maybe [clears throat] happen sooner in the I suppose the licensing lifetime is uh something we're committed to. >> Yeah, it's a it's a great point of you know the more we can compartmentalize and say okay this is the approval you need or these are the standards you need for everyone that can then rely on for the different different pieces to it it's going in the right direction. Uh, I just think it's it's a great way to save time on the on the government side and on the industry side too. >> That's right. I mean, and I should say that it's like it's it's not the lack of expertise in the government, right? The problem is siloing and that's that's a problem. >> Yeah, exactly. It it those um sort of books need to be opened up, right? The transparency concept, right? But that that particular kind of information needs to be available for the enterprise. um not not even only restricted to um sort of bilateral arrangements. >> Yeah, thank you. So yeah, I'm catching you know quite a few pieces that we think are important here in this process. So there is that coordination between stakeholders at the real-time level when multiple stakeholders are operating um very large constellations similar orbits. There is also that kind of like oversight at the mission authorization level instead of you know looking at each of these um as they come in to have some sort of like you know oversight on all of these um applications at the same time. Um and of course you know coordination within government breaking down silos and on top of that two things transparency um as well as consistency those are I think coming out as as important pieces in this conversation. Now I wanted to kind of at this point maybe also bring one of the audience questions that we have which um um we can try to answer but um a lot of what we've been talking about here is kind of you know how we can manage it within perhaps US entities right so there's a question about how you know there we also see interest um internationally right from different um countries from operators overseas and and you know for some of these players we might have slightly different dynamics in our relationships with them so when it comes to that coordination piece beyond the US maybe internationally um what can we do or what are we doing is there is there something else something different that we need to be thinking of um again I think the question is for anyone who's who's game to answer >> so this is in the thinking about uh category um uh so one of the one of the approaches that is used in other industries um to be able to coordinate multiple parties and how they act and interact um is uh using or applying the elements the tenants of a industrial metaverse. Um and um that may or may not be familiar to this audience. I'm I'm not not sure. Uh but essentially it's an environment where the community does have access to transparent information um including planning uh information uh so that they can take it into account relative to their plans. uh that is an approach uh that can be adopted um in the space enterprise. Um and by virtue of um the allowance for all of the operators and players in the world to participate uh that could be accommodated. That said um it it has so many governance uh um issues or or I um considerations that will have to be dealt with. But we do find ways for international aviation uh to work effectively um across borders uh safely uh so and maritime um so there are uh benchmarks there are ways of learning uh from these other domains. >> Okay. Um >> yeah I >> if I can jump in there. >> Yeah I I I I agree with Ron here. Um and um I think there's there's one very specific area where international collaboration will be will be extremely important. Um I touched on it in my my my last comment and um yeah I'd like to reiterate this this point the with so many satellites going into dawn dusk or dusk dawn um sun-synchronous orbit um the densities are going to be enormously high and um we we need to decide which side of the road the great the analogy that I use here is we need to decide which side of the road we're going to be driving on so we We can either be driving on dawn dusk which is you can think of the satellites orbiting clockwise um or dusk or dusk dawn where the satellites are orbiting anticlockwise in in a very similar regime. Um if we if we choose just one or the other then all of the traffic can can flow together if you like. If if half of the operators internationally choose one and the other half internationally choose the other, then it's going to be like a like a highway with the traffic without without us deciding which side of the road the the the traffic goes on with an an enormous number of um head-on collision um risks conjunction conjunction risks. If we can all decide on one regime or the other, then the the traffic can flow together and we can enormously reduce the number of conjunctions that we have in this this very special orbit. Um this is this is a topic that's very close to my heart and um you know StarCloud um as you know like like everyone doesn't want this this very special orbit to be put put at risk um with with these very special properties. So I think that will take a significant amount of international coordination. I do not have any concrete suggestions for how to achieve that. Um but I I think that's something that um we should be looking at very closely. >> Yeah. And maybe just to foot stomp uh something Ron said uh sort of he alluded to the air traffic control um you know system right globally air traffic control uses English right? uh the US uh sort of English uh operators helped create a system and then worked to uh get that adopted globally and so it sort of uh serves as a a standard for how it needs to be. We've been talking a lot about this in terms of SSA um where the US has this opportunity um and has been sort of taking advantage of that through through tracks in the office of space commerce to create these systems that they can then go and share with the rest of the world and figure out how to interoperate. Um that's that's how uh sort of the US continues to lead is is uh we can get to some of these answers you know early with with the right inputs from the global community um with with industry and government figuring this out together so that we can then sort of scale that and think about it as our you know space diplomacy or whatever it may be uh sort of what how we work around the world with with other operators too. It's a, you know, Ron mentioned it, but it's just, it's worth uh emphasizing. It's a perfect example of how I think we can set the right rules of the road um for for everyone. >> Um, so we do have a government rep here. I don't want to put you on the spot, but just wondering if there's anything you can speak to that. Um, >> well, I guess I should say first of all that mission authorization, which is what I work on, is uh at this time it's only for US uh operators, right? So the international aspect is not exactly in my wheelhouse. I will point to two treaty obligations though that I think uh are really important here. One is the free use and exploration of outer space, right? And the other is non-inference. Both of these arise under the outer space treaty. And together uh when we're thinking about constellations, one could make the argument that they require uh intergovernment coordination. >> Okay. Yeah. Thank you very much. Um so I mean I think on this point I'm also looking through the audience questions. We have about you know five to 10 minutes left and I want to maybe roast some of them in. So um one of the questions that I think I also originally wanted to ask is you know we we look at ODC's as one type of uh novel space applications right so as we assess the need um uh for orbital access or ODC's how do we kind of from a policy and governance perspective you know balance that access against uh access by current as well as future actors because there may be new novel users that may also want um orbits or sun-synchronous orbits or even current ones So for instance, suns synchronous orbits are also very useful and sought after by uh earth observation satellites which which planet operates. So I'm just wondering you know from that perspective um what what is our thinking on on kind of maintaining that sort of access for current and future needs? >> Yeah, I mean it's it's something that we're thinking about hard at the office of space commerce. I don't know that I have a satisfactory answer. I so on the one hand we recognize certainly that orbital space is a finite resource right on the other it is it's very hard to countenance denying one applicant who is real now on the basis of some hypothetical future applicants uh potential use for an orbit right now how we balance those interests it remains an open question. I think at the heart of that is that the person who's first in space isn't necessarily the best person in space. But it does very much, if I may, um, it very much goes to the sort of the the tenant or the the the fact that the outer space treaty um, favors the precedence-based um, operator, the precedence-based provider. Um, and that that basically sets the stage for everything that comes after, which is a major driver for why it's so important for US leadership uh, to to to to take that spot. I have that uh have that pool position. Um just a a a an an interesting uh fact right relative to the density that we're talking about um is that if you were to according to a back of the envelope comp uh calculation I did right if you took the a million70 meter wide satellites um and put them toeto toe or shouldertosh shoulder um they would at 600 kilometers they would wrap around the earth 1.7 times. So I think it's it's important to have figures of merit like that just to appreciate um the incredible scaling uh that we're talking about. We're going from an environment a legacy environment where space was very large relative to the to the deployed access and now we're looking at a future where there actually may be significant density in certain orbital shells. Um resonating with points made earlier. >> Thank you. Yeah, you know, I I sort of make the parallel a little bit to there being shared opportunity. You know, our public lands in the US, you know, you have people that are just recreationists, campers, you have hunters and fishers, and you have all these shared activities that that we've found a way to to do together. Um, I think that's sort of a very similar way to to think about it um with with where we're going in space. And I'm also just drawn and it's not really a part of the question [music] but for some reason I'm thinking about it um of like why we're also talking about doing this in in general. And so as we think about planet's mission to you know image the earth and then you know get that data in the hands of people who can use it. Um speed matters and so you know we're we're putting on our next generation systems uh you know onboard compute that will have you know limited you know space and number of milliseconds that it can run something right uh that then could sort of transmit a uh an answer down instead of an image more quickly. Um eventually we may want to process the whole image uh in space because once we actually communicate our images down to the ground, we still have sort of a processing timeline that we can do here. If we can speed that up um in space and uh then get better um sort of real imagery or real time insights into you know our customers hands whether we're talking about disasters or we're talking about defense and intelligence uh whether we're talking about you know these wildfires that that we're seeing right now um those are also just the interconnected in terms of how it's being used. So, it's as much as we've been talking about this from a, you know, oh, we're a space, you know, companies that are doing these things or where we're trying to um, you know, work on how to regulate and how to sort of structure these governance pieces. It's also really connected to something real in terms of the capability that we're we're all trying to provide. Um, again, the orbital data centers can be a key part of that, you know, for the for the Earth observation industry and what we process, how we process, and how we deliver to our customers. Um, and then there's also, you know, teenth other, uh, opportunities that I'm sure, you know, Ezra and others can talk about, too. But, uh, it's really helpful to sort of draw that connection to what it's not just on paper, right? Uh, we're actually trying to deliver something to to to customers. >> Yeah. And yeah, StarCloud is Starcloud is is doing that today. Uh so we're contracted to perform essentially cloud compute in in orbit for a number of government users on uh both the vehicle that we have in orbit today StarCloud one and the vehicle which we're launching in a few months starcloud 2. Um so even before we get to this uh the larger scale um con constellations which which we've been talking about today um there are very real and very precient um and use cases many of which are important to national security which can be served with smaller ODC constellations. So that's the first point. The second point to uh to on with regards to coexistence of um ODC's with with other um other users of low earth orbit. I think an important point to note here is that unlike Earth observation constellations, ODC's can be relatively flexible with regards to altitude. um the uh the latency difference um between a 600 km um SSO and a 1,00 km SSO um assets is um not so significant I'd say um for for for most use cases that ODCs are being um are being uh um proposed for at the m at the moment. Um so for for that reason um ODC's can fit in with existing um within with existing users of of space um quite quite neatly um and and not occupy altitudes which are currently heavily used for earth observation for example um and uh I I think altitude is really the the one knob which we can turn quite easily um to uh to to to coordinate ODC's with with existing users. >> Thank you as so um we're almost at time and I think you know I've managed to wrap uh weave in some of the audience questions along the way. So I just want to ask one more audience question before we wrap up. Um I do have a question on um deorbiting. So we have talked you know about mission authorization stage. We've talked about the co coordination stage when in when the satellites are in orbit. There is of course also the question of postmission disposal in de-orbit. So if you're looking at you know above a million satellites um that kind of de-orbiting that kind of re-entry activity is not something that we have uh we have test or witnessed before. So my question is you know to any of the panelists you know is there something we need to be aware of? Are there studies that are going on that we should uh we should know or within government are there efforts kind of look at some of those things to see whether that's that's an area to take note of. Yeah. Um I offer that there are there's a recognition that studies need to be conducted uh for each of four uh types of de-orbit solutions. U for atmospheric re-entry um really studying the impacts um of atmospheric chemistry and composition uh from uh burnups in in uh in re-entry. um as well as studying the ramifications of a need for more like n9% reliability or complete burnout um than 0.90 which is more more current. Um the second um area is in terms of graveyard u u essentially deployment of of u of spent uh systems um in dealing with the potential uh for impacts in the graveyard orbit and what that would mean uh to from a cascading perspective. A third area in the area of heliocentric um disposal um is really understanding um with certainty uh that those um released um uh systems would not return uh to the earth moon uh environment uh at any point in the future which is um would be absolutely critical to to to to u get exactly right. Um and the fourth is um in the context of reuse um and being able to essentially apply ISAM related uh capabilities uh to be able to redeploy or reconfigure uh the systems that are deployed uh in in that context. >> Thank you. [laughter] >> Excuse me. >> Yeah, I think adding that extra lay layer of flexibility in terms of ISAM is an important part of this, right? not just relying on orbitable orbital debris plans, not just relying on orbital decay, but also having the capability to fix problems as they arise, right? Um, and you know that's an ongoing effort. But as we see the space economy grow and more and more operators in orbit, it's important to think about transitioning from a purely venture into space mentality to an upkeep mentality as well. And that I think is the ISAM aspect of that. And I'll just add something to to Ron's first point on the atmospheric piece because uh Planet just joined uh Astroscale actually a couple months ago maybe I I think it's called an the airs initiative but essentially we're we're trying to work with researchers that are trying to do some of this you know atmospheric research and get them uh more of the data they need from operators to help do their research more effectively. So uh we just announced that because we we do think it's important for us to continue to leverage those uh opportunities to learn more so that as we iterate on the technology we can iterate on the best practices um of how we do it and I think the same thing can apply towards uh you know dark and quiet skies and brightness as well. >> Thank you. Thank you. Yeah, I I completely agree. Um the the the atmospheric effects of uh of this this the levels of mass which we're talking about de-orbiting per day is is not fully understood. Currently we we have about 100 tons per day coming from micrometeorites. Um and the ODC proposal proposals which we are discussing uh will be launching many hundreds of tons. So it it is it definitely warrants uh greater study. It's relatively poorly understood um to today and we we absolutely support further further study and and evidence-based policy that comes from that. Um the the other aspect of uh so we full demise I think is extremely important and um um from a from a safety standpoint. Um and I I mentioned at the beginning that um controlled re-entry should be taken. um we should we should take a a very close look at whether that's an an appropriate um means of disposal um as some ODC applications have have relied on controlled re-entry um as their as their primary means of disposal which would require a uh a very high reliability um high thrust high delta V propulsion system to operate um yeah extremely reliably after many years in orbit which which I think is um needs to be considered very very carefully before before granting. So um in in the absence of that I think we should um we should essentially mandate full full demisability. >> Thank you. Thank you Ezra. So um we're at time I want to end just maybe on a quick fire round. Uh you know we've heard a lot today about the considerations about what we could do. Um but if I could just ask each panelist to maybe name one concrete step or action that you think we can and should do now um so that we have the best chance of setting you know this ODC development onto a path that supports a stable and sustainable uh future in orbit what would be so maybe 30 seconds each please >> okay I'll start with um in increasing our knowledge um and the availability of a knowledge base that is um applicable for the enterprise so that we can accelerate ate um adding to our eyes and ears in space. Um actually add brains in space. >> Uh I think I would say that you know the government is taking a lot of actions to update the way that it authorizes activity in space. I would encourage operators to not wait for government action to develop and abide by best practices. Right? best practices. Uh we see them in the ISAM context coming out of conference and cosmic. Um this should be the way that the the object that determines how regulations develop anyway. Uh so before those regulations come out, I suppose are released, I guess I would encourage operators to think about how they would want their competitors to act in space. I uh I'm thinking kind of back to something I already said around uh SSA sort of real- time SSA capabilities and and Ronnie also mentioned the uh sort of maneuver intent of where you're going to go. So where where you are now uh the transparency for operators of of how we you know get that data out there, the systems we put in place now and uh declaring our intent to where we're going to be. So, where we are, where we're going to be. >> Yeah. >> Yeah. For me, I'm I'm going to come back to my uh my favorite topic, that is deciding which side of the road we want to drive on. You can imagine the chaos that we would have if um if we had traffic uh heading head, you know, head head on to to to one another um without a clear delineation of we're driving on the left side in this direction, then we're driving on the right side in this direction. I think that analogy is very apt and is absolutely applicable to to dawn dusk versus dusk dawn um sun-synchronous orbit. I think today we need to decide which side of the road we're going to be driving on. Is it dawn dusk or dusk dawn at and at which altitudes that applies. >> Thank you Ezra. Thank you all. So I mean we've certainly given us a lot to think about. I know that there's still a number of audience questions uh that I didn't manage to get through, but the good news is that we do have a lunchon that's to follow and three of our panelists will be able to join us for that. So, you can send your hardest questions to them in person. Um Ezra, thank you so much for taking the time to join us virtually. We really appreciate it. Hopefully, we'll have the chance to, you know, host you in person sometime when you're able to make the trip. Um but other than that, I would like to invite you to join me in giving a round of applause to our panelists. Thank [applause] you for your time. Thank you. and lunch is outside. Thank you. Thank you so much. >> Thank you so much for your time.