The United States Air Force (USAF) has long handled space situational awareness (SSA),which is the monitoring of satellites and debris in orbit around Earth. As the number of objects in space has increased, the job has become more difficult, and the USAF has increasingly had to warn commercial and foreign satellite operators about potential risks to their satellites. Passing off non-national security SSA duties to a civil agency would free up defense resources for other space-related goals, according to the Department of Defense. The Federal Aviation Administration (FAA) wants the job, recently estimating that it could do the job for under $100 million. However, before the U.S. government passes off the role of commercial space monitoring to the FAA, it should consider all possible options.

Why SSA for FAA?

Why does the FAA want the task of SSA for non-national security satellites? Its Office of Commercial Space Transportation already handles licensing for U.S. launches and reentries. The FAA also has experience working internationally, providing technical assistance abroad and working with foreign aviation agencies to coordinate travel. This combination does provide the FAA with a decent argument to handle the SSA the USAF might pass off.

However, there are more aspects to consider than just current licensing and international relationships. Contrary to popular comparisons, outer space is not like domestic airspace or even international waters. There are several key complexities that require review.

Do as we say …

There are concerns about the legitimacy of extending a domestic agency’s situational awareness into non-territorial space. While there are likely many companies and countries that would appreciate FAA assistance in keeping track of objects in space, there is the risk that some would find it an act of overreach. China, for example, has been reticent towards working with the United States on space debris issues, despite the recognition that space debris poses a problem. Would the FAA, as an American agency, be able to form the trusted connections it needs to with China? While it may find better cooperation internationally than the U.S. military, it is not clear how much of an improvement the United States will see.

… Not as we do

There may also be good reasons to keep the licensing and situational awareness parts of outer space policy separate. With difficult dynamics between concerns over national security, commercial interests, civil space exploration, and international relations, the combination of SSA with the authority to license launches and reentries might introduce conflicts of interest.

For example, if the United States moves to license in-orbit operations (currently not licensed), the placement of SSA in the FAA would mean that the agency would be managing not only what was authorized to happen in space, but also the public information about what was happening in space. As the single point of contact for all things space, the FAA would be more vulnerable to regulatory capture by dominant industry players—tilting both licensing permission and rulings on in-orbit risks towards heavy lobbying interests. A company arguing a FAA ruling on in-orbit operations would either have to invest individually in SAA capabilities, or use the FAA’s own data. For ease of such reviews, it may be preferable to have real-time SSA information separate from the licensing agency.

Many eyes are better than one

Additionally, embedding SSA in a government agency may reduce the number of non-governmental or foreign entities that can contribute to observing actions in space. This is not to say that the FAA wouldn’t be able to bring in outside actors to assist in SSA, but it may very well limit an optimal number of relevant stakeholders participating in the process. The best solution to the SSA problem would bring in as many observers as possible.

Towards a better solution

There may be a better solution for the full range of SSA problems. Establishing a multi-stakeholder, non-governmental entity that collates orbital data could ease international concerns, mitigate conflict of interest issues, and pull in a large number of contributors.

The U.S. government will still want to monitor in-orbit objects and actions, so this is not to say that a government agency would not be actively undertaking SSA. However, this multi-stakeholder, non-governmental entity would pull in data from a range of sources—including government agencies, universities, companies, and foreign SSA entities. That data would likely catch more possible problems, and also mitigate concerns of conflicts of interest or an American extension of sovereignty to orbit.

This is not a new idea, either. In 2009, the Space Data Association was created to provide collision warnings to participating satellite operators. Today, the association manages information for over 350 satellites.

An American version would be based in the United States, and would work to include significant U.S. stakeholders. It could even coordinate with already existing groups, such as the Space Data Association. This entity would not handle any licensing or regulatory issues, so would not have decision authority on American action in space. Instead, it would focus solely on situational awareness and help inform regulators and companies about the state of Earth’s orbital environment. It could also provide a forum through which numerous companies, governments, and non-government organizations could discuss the growing number of objects in space.

Such a multi-stakeholder entity would not solve some of the deeper issues in space policy; namely the debates over how to regulate commercial actors. It would, however, pull together numerous groups and people for whom keeping space safe is a vital need. That would be one good step forward in an increasingly difficult policy area.