Panel Discussion — Beyond Earth: Extending Spectrum Management to Deep Space and the Moon

Abstract

As space activity expands to the Moon and deep space, adapting traditional Earth-based spectrum management becomes a pressing challenge. Current frameworks like those from the ITU and FCC may not fully address the complexities of spectrum allocation, enforcement, and international coordination in extraterrestrial environments. This panel will explore the legal, technical, and geopolitical issues of managing radio spectrum beyond Earth, with input from experts across sectors.

Panelists

• David Reed (Moderator) — Senior Research Associate, University of Colorado Boulder
• Gerald Adams — George Sharswood Fellow, University of Pennsylvania Carey Law School
• Rob Frieden — Academy and Emeritus Professor, Penn State University
• Carolyn Kahn — Distinguished Chief Spectrum Economist, The MITRE Corporation
• Lynna McGrath — Deputy Associate Administrator, NTIA Office of Spectrum Management

Transcript

We’re gonna get. Try to get started here.

Let me try to get at least my panel under control here. Yeah well thank you very much for still being here at the conference. I think we’ve got a good

closing panel for you to think further about these issues. Actually we’re we’re divided into 2 basic areas of discussion. I’ve asked each panelist

exception of one who’s joined us on last notice here which we very much appreciate to do a brief presentation. And we have something novel for this conference. We actually have some slides and so we’ll go through and we’ll comment on that in the 1st half. Second half.

I have a few questions where we’re kind of hitting cleanup here on the conference topics and issues. So we’re going to cover some of those and then I’m going to turn it over to you for 15 min

to raise some questions that you might have from the presentations obviously or from the conference in general that you would like to get some reaction from the panelists on. So that’s the plan for this panel. I’m going to introduce my panel

1st here and just going right down the line here. I’ve got Gerald Adams who’s the Charswood fellow and resident scholar with the Center for technology innovation and competition at the University of Pennsylvania Carey Law School. We have Rob Frieden the Academy and Emeritus Professor of Telecommunications and law at Penn State University.

We have Carolyn Kahn who has been introduced before but she’s the distinguished chief spectrum economist at the Mitre Corporation. We have Linnae Mcgrath who is the deputy Associate administrator for spectrum management within the Ntia office of spectrum management who is the one who subbed in on late notice. So she has

the ability to say Hey I didn’t know I signed up for this and pass and then we have Scott Palo who’s the Charles Victor Shelke? Endowed professor in the smead department of aerospace engineering sciences at Cu Boulder. So our final panel here we’re going to be digging a bit deeper into this notion of different frameworks for spectrum management

and how they may need to differ between terrestrial and space communication systems. And we’re going to investigate this from an interdisciplinary perspective which is my favorite passion and and preferred methodology for investigation.

So I do have

our anchor so to speak. Dale Hatfield will recognize this. This is a

framework. Dale and I teach a class on spectrum management every Maymester and there’s twofold for that 1st is we get a lot of technical engineers who want to understand more about spectrum management.

and the second is that we have

Hatfield scholars from the Law School who are going most of them to Washington to work at some of the areas that you might be interested in you know places like the Fcc. Or the Ntia. In

those law school students. This is their 1st exposure to spectrum management and so they are spun up and they really hit the ground running. So I’m doing this in part as you know to let you know that if you’re interested in having law students or other Hatfield scholars they don’t have to be just legal right Dale. They can be technical.

Talk to Sarah Schnitgaard and get on the list because these students are really energetic and interested in the topic. And we have a 3 week boot camp.

and we’re covering all topics. Spectrum management and the feedback we get is they do hit the ground running. So

part of of what we cover with the students is to make sure they understand just

the basics of spectrum management. And we have 4 fundamental steps

here in what we call the spectrum management framework that we work through the course in. And this framework came from Dale Brian Tremont and others that have taught the course before I did. But we really try to stress these 4 fundamental steps hopefully they look familiar to you for those who are experts.

so I don’t need to go through and and define each one of them. But at the top level obviously spectrum allocation is just who gets

particular bands. The technical and service rules are really the constraints that are put on it in terms of how it’s used.

The spectrum assignment who gets it and then the enforcement is without enforcement. What does steps one through 3 mean? Right?

And so

I’ve asked the panelists some to be cognizant of these categories because sometimes within these conferences you get

statements that seem that converge various enforcement steps with spectrum allocation decisions. And so I’m trying to use this as a way to help you as a tool to organize your thoughts about with all these problems or issues that we’ve covered here within this transition to more usage in space. This is a nice framework to help anchor you on what these different issues imply.

So we’re going to start with Gerald and I’ll turn it over 5 min.

Thanks David.

So I think just to start because we’re batting cleanup here just to recognize that this discussion is at least partially emblematic of a broader theme that’s been brought forward throughout the last 2 days which is you know.

this quote is coming from the Financial Times article back in March essentially recognizing. You know.

the commercial space age is here commercial filings for lunar spectrum. In particular the context that we’re reviewing

has surpassed those of space agencies and governments. The figures themselves are a little bit misleading. This is showing cumulative filings but nonetheless if you look at the spikes themselves we see you know fairly market jump by commercial actors and there’s at least some

projections that you know these spikes are going to get even more significant. It’s going to continue throughout the the foreseeable future to the point where we’re having hundreds of filings.

And so the question is okay well what do those filings actually entail. This is representative of the commercial Lunar Payload Services initiative that NASA is doing so. It’s somewhat of a public-private partnership.

Where exactly are these payloads being placed.

I think for our folks on the radio astronomy side. The middle figure is probably slightly concerning

The one I want to emphasize is actually on the South Pole where this is just providing an indication of commercial operators contracting through. NASA has no discussion of the broader international actors that are also going to try to occupy and use the South Pole for various reasons.

And so this is just a tiny sliver of what the the actual kind of occupancy and environment’s going to look like.

am I quiet? Sure? Yeah. So

the question is okay well now that we’re in this new arena.

it’s not necessarily a new problem. But it is a new environment for facing that problem. What do we need to do? And right now the the kind of

the management regime is a Band-aid is the way that I would phrase it right? So my understanding is most the operators that have put payloads out on the moon.

They’re operating under experimental licenses. I know. Maybe Jennifer will correct me. I think you shot your shot for a blanket license. I don’t know how that went.

But nonetheless it’s not providing any sort of security of expectations here right like.

if we have to continually ask for experimental licenses and waivers that seems somewhat problematic. There’s also the lack of allocations at least in the bands that folks want to occupy. And so you have everybody operating under 4.4 where it’s a non-interference basis.

And so we want to try to provide some semblance of security. We want to have some sort of management framework. What does that entail and I think it gets to the title of our panel which is extending right. And there’s been some at least arguments or proposals that we just take the terrestrial frame and extend it out into space.

And so we look at the frequencies themselves. We already have space research frequencies but nonetheless they’re probably insufficient

for commercial operators that want to economize on the antennas and the payloads that they have. It makes a lot of sense. The things they want to use for space to Earth operations work for space-to-space operations.

We’re going to need some updated service rules based on kind of the idiosyncrasies of the environment that it’s operating in right? The path lost environment somewhat different. But nonetheless we’re kind of pulling the same moves that David recognized at the outset. Right? We looked at allocation. We looked to assignment service rules and we recognize that because this is

use of space and often satellite services there’s a degree of governance involved here. Right? This is shared spectrum. So there’s some degree of you know registration both domestically along within the through the Itu and then a degree of cooperation and coordination between the entities themselves.

What I want to get to is a little bit more of the provocative point which is that

that outlines governance and I think we’ve done a good job of presenting governance over and over here. But it’s a little bit of a hand wavy theme to just say you know we do. Governance and governance occurs through the Itu.

1st come 1st serve. You have priority and just make nice with all the people that are ahead of you.

I don’t know if that necessarily provides the rigor that we’re looking for here and so

just using the terrestrial frame as a foil here and looking to space.

What we kind of run into and what I think is the problem from an academic perspective is

on Earth. We kind of have the crutch of what I call cocium proxies which really what I’m saying is there’s some moderate degree of exclusion that’s available

right

which is on earth. We do have sovereign boundaries. There is some degree of exclusion involved because the interference is happening at the receiver that on a country by country basis

there is a little bit of leverage to come up with robust management regimes and I look to even the Us. In particular which is yes we have kind of this in the backdrop itu coordination procedure and regime that’s existing. But when people talk about satellite coordination particularly on the fixed satellite services side.

we’re talking about the Us’s regime with the processing grounds

and the entire framework for spectrum sharing between systems within a processing round and between multiple processing rounds. Right? That is the structure. That is the rigor of what governance actually looks like.

But the 1st step of it is there has to be a defined boundary and usually that boundary has some degree of exclusion.

I don’t wanna

jump ahead of your question David but this is well known. Right like this is this is the Eleanor Ostrom frame. If you go through the 8 requirements that she has for common pool of resources and governing them.

the very 1st step is clear boundaries.

The 1st step is some degree of property on the outside and then we do the commons on the inside.

And so it provides some degree of what I’m saying is a gatekeeper right? And an Enforcement hook. The thing that we really need for governance

on the moon. We don’t have that right

for the orbits around moon. We also don’t have that

article 2 is very candid and clear that we don’t have appropriation or declarations of sovereignty on the Moon

post Tongasat. Whoever brought that up yesterday right in theory. We don’t have that for orbits around celestial objects either.

And so

we’re kind of missing. I know a lot of people. David Goldman probably isn’t here anymore. A lot of satellite operators complain that getting market access in countries is a just horrible pain and frustrating experience and it’s somewhat idiosyncratic and it varies country by country.

but it provides a crutch here like

the borders are the crutch for our governance regime from earth to space and space to earth.

And we don’t have that in the lunar context. We don’t have that in the cislunar context.

And so we have to really come up with some sort of more robust uniform governance regime that actually does the moves rather than just saying we’re going to coordinate and hope on best practices in good faith.

Maybe I’m wrong. I just don’t have a lot of faith that that’s sufficient.

And so what does that require? Well it’s going to require some degree of consensus.

Our hope and dream is that it’s something emblematic of multilateralism from the sixties and seventies.

I’m not sure that’s necessarily going to happen.

I wish Kathy was here. But she essentially had said well you know we do pre-coordination. We have things like the Space Frequency Coordination group. We have these procedures that exist.

They’re all based on an outdated regime though right? Like they’re all baked on the idea that this is a few nation States engaging in coordination with one another and that’s no longer the world that we live in which gets back to my 1st slide.

We have a myriad of private actors with various interests that are operating under flags of multitudes of countries

that need to have some sense of security of what coordination is going to look like what governance is going to look like and whether there’s any sort of security of expectation here.

and that seems to be markedly lacking at the moment. So that’s the work we should be looking towards. That’s the thing we should be trying to fix.

Give you a couple extra minutes you were on a roll. I’m sorry. No no it’s good. Any comments or reactions from

yeah. I mean I’m just thinking with what you’re saying with property rights. And you know do we do we take space which is very different like you pointed out to on Earth and make define property rights on space? Or maybe there’s a new model or the model needs to evolve to fit space.

Yeah I. So

I think property rights is one form of getting what I’m calling some sort of exclusionary baseline or

boundary regime. Right?

That would be the traditional economist Demsetsian kind of characterization of how we would go about and do this

I don’t know. Maybe that’s how we structure it is. We essentially establish some quasi entitlements on the moon or in the orbits around it and then assign folks to them.

or it’s just providing a more robust procedure where we’re a little

more rigid. And who’s let into the club and who’s kept out of it in certain sequences.

so I’ll I’ll dive back in on the the spectrum management piece of it when you started off. And you said the commercial operators are all operating on an experimental basis.

Well you go. Well why is that? Well let’s go look at the Us. Regime most of the time. They’re operating in space research allocations.

Historically those have been federal.

So you look at what those bands are.

They’re federal exclusive.

So given our frequency management process here in the Us.

They’re operating on an experimental basis.

We’re seeing that regime change space operator or space research is not just

the purview of governments anymore. It’s now becoming the purview of commercial industry.

And do we need to look at changing that? And do we as you said do we have enough space research allocations to support that? That’s a question the Itu is looking to tackle.

But then whose spectrum do we take to do that in?

And a lot of the times when you see space research allocations there’s also a load of other allocations on there. So you’ve got all the other Federal users doing other sorts of space space-based activities or even terrestrial activities that we’re trying to coordinate around.

So we’re we’re kind of looking at that.

The world we knew where this was the purview of governments has moved to commercial industry. And then yeah you’re very much right. How do we change the regulations? We have to support the world we’re dealing with today. So the reason it’s in flexibility is one observation. Is it fair to say it’s because it’s the most flexible framework that was available that allowed that to happen within.

It wasn’t necessarily all experimental mission based or things like that. Right? So. But that’s what was the path of least resistance. I think a lot of times you’re you’re dealing with companies that are trying to use existing hardware which is optimized to operate in those bands. And

please start. I don’t have my table of allocations in front of me. Would someone please find me the non-federal space research allocations?

Right?

We don’t have them. So we have innovative companies trying to do things.

and we don’t have regulations. And the the current setup doesn’t fit. So we’re trying to fit the square peg into the round hole using the tools we have today.

Okay alright.

So I have another question and I’ll touch back on this a little bit more. But you know this notion of the Commons is something that I think is a key economic characteristic that we haven’t talked about so much in the conference. So far we’ve kind of said we need to have cooperation and things like that so we’ll circle back. But Rob Nate can we get a black screen here for. Go ahead.

Thanks David. I appreciate it. I’ve got lots of slides quite frankly with the time available. One slide would take the entire time but I encourage you to take a look at my website just research the name. And I’ve got a wealth of slides particularly for your students. Speaking of slides I want to shout out to Dale. I’ve used his spectrum management slides for decades with attribution.

and the fact that I’ve been able to do that at least speaks to some of the sustainability of the structure. Now I’m going to talk

how the structure is its own worst enemy in a way but I do want to gently push back at a comment that was mentioned today

that the Itu was quote totally irrelevant I’m going to push back on that and suggest that the Itu. And let’s add the United Nations is at risk of losing legitimacy and that’s already leading to the prospect and the advocacy for a sort of go it alone. Unilateralism. Some scholars have titled that or captioned that framed that as polycentric governance.

and we already can do some sort of a case study in the notion of polycentric governance or unilateralism and that case study would be on the Artemis accord which quite frankly in conjunction with a subsequent Executive order

disassociates the United States officially with the 1979 Moon Agreement an agreement that quite frankly has failed 1979 and has only about 18 accessions. National accessions.

the Us. Government officially disassociates with the concept of shared commons particularly insofar as asteroid prospecting extraction of resources

and colonization of celestial objects.

and that is creating pressure yet more pressure on the Itu process and the UN. Process that has as a baseline consensus view of a shared commons going to your comment about shared Commons.

Let me suggest this. Let me present you with a worst case scenario.

Okay and not to disparage anybody and I certainly don’t want to be flamed on social media by suggesting that space advocacy which by the way had a slide showing Messrs. Musk and

Bezos having had it in the court of public opinion and social media sort of working. The Refs. In this case working the Fcc. Refs. But arguably a worst case scenario would be that

private ventures ascribing to the move fast and break things. Credo

have lost patience have lost trust in the status quo in the Itu process in the UN process.

and they move forward unilaterally or they create ad hoc affiliations. They have a polycentric view of the world. Let me give you 2 examples where maybe that wasn’t a good idea. Maybe that model isn’t so robust and and sustainable and something we want to embrace

in 2008 the Fcc. Fined a company called Swarm $900000 which was a chump change to this startup venture which by the way then sold itself for 524 million dollars to Spacex

for kind of forgetting to secure launch authority for for cubesats small satellites. I mean these things happen right? Well there is something to be said for a process where you

advance publish your frequency use advanced publish your orbital slot use advanced publish your orbital plane. Use. Put people on. Notice that that’s where you want to be and engage in coordination. It’s a slow process. It’s an incremental process. It highlights a 4 year cycle through world radio conferences for spectrum management which doesn’t work on Internet time admittedly.

But

put it this way if you don’t know who’s operating where particularly when you’ve got microsats that are so small that can’t necessarily be tracked and monitored. That registry is really really important.

In 2003 dish was fined

$150000 for failing to move a decommissioned satellite

far enough out into a graveyard orbit where it isn’t necessarily likely to decay wobble and start interfering with the geostationary geosynchronous orbital slots or become yet another large piece of space debris.

So

my view is I appreciate the notion that particularly Internet. Time is fast. 4 years is a long time. Consensus building is tedious and incremental and difficult but I go back to 2021 when Messrs.

Musk and bezos were working the reps. They were working the Fcc. But working within the rubric of the Fcc. Process which follows and executes the consensus or takes an exception reservation to the Itu process.

They were willing to sort of recognize the legitimacy of the the International Forum and of the Domestic Forum and it was just a question

narrowly whether an amendment of your license application shifting your orbital plane usage would put you in the prospect of having to resubmit? Or was it just a substantive amendment to your existing application? So in summary.

I appreciate that this process is tedious incremental slow and the treaties don’t even recognize commercial actors they are non-enforceable

and have all sorts of flaws. Lastly in the

I’ll take the license here because we have product placement for silicon flatirons and if this were at the Penn State University that would be beer and not water. Just saying I want to call your attention to my latest product. It’s called Dangers from regulatory Vacuums in outer inner and near space. It’s in the current edition of the Journal of Air Law and Commerce.

It’s tedious. It took a long time. It can take hours to finish one. Footnote but that’s my contribution to the literature as a retiree. Thank you.

So a question for you then Rob are you?

You know you were saying this is a defense for the Itu and the UN.

So you’re thinking that’s reformable so to speak for the scalability issues that Gerald’s talking about.

I don’t know if it’s reformable and I know that you’ve got treaties that were executed in the sixties and a lot has changed and they haven’t been able to muster the resources to reach consensus to build trust to study and find nothing more than recommendations. So I appreciate that. That’s a very tall order to reform and move them into Internet time. But my

concern is consider the alternatives and the alternatives don’t look so swimmingly better in my estimation.

Okay we’ll go if if we can come back on Nate and we’ll have

Carolyn Carolyn you ready? Sure?

Do you need to click.

Well it’s been great to be at this conference. Thank you. I’m learning a lot really enjoying the discussion and really excited that the students are so involved in asking such great questions. So you know we’re talking about kind of where we’re at if and how do we apply spectrum management that we use traditionally here on Earth to space.

you know hearing different notions you know. Are there kind of little bandages or tweaks or do we take you know try to fit a square peg into a round hole or vice versa? Or is there something revolutionary versus evolutionary?

These are important questions how do we with the treaties and how do we evolve that to be more applicable and productive in space? So some unique qualities that makes space different from spectrum management? The huge amount of distance in space so could make something like the commons

work there because there’s just more area. But as there’s more more objects get into space that you know. What will that congestion be? And would that still be viable in those types of situations?

Also the frequencies that we need to use it. And how do we work within these long distances with attenuation latency those delays the mobile and dynamic environment we talked about with the leos the lunar orbits.

additional space launches and many more expected. And a big complication is the stakeholders just compared to traditional spectre management where there are even on Earth so many different perspectives and points of views that are important and then it just

extrapolates exponentially when we take it to to space. So how do we work with other countries what can be agreed on? What rules will be followed? What won’t be? What are the the consequences or how can they be enforced?

And then the resource scarcity and how economics can help to allocate the scarce resources? Do we make things equitable? Is it? 1st come 1st serve and this is a very competitive environment where there is a lot of interest in being the 1st mover there.

So some

highlights with the economics in this space it is so strategically important. Great power competition different nations wanting to be that 1st mover although in economics being a second mover or close follower has its advantages because you learn from the 1st mover. The 1st mover may often invest a lot more money and funding

so so more expensive but makes mistakes so that

second mover can leverage what they’ve learned from the 1st mover and sometimes capture more of the market. So there’s advantages there. These are global markets.

the international players the coordination that’s required. I mean it’s it can’t. No single nation can do it on its own because space is is everywhere and

requires that international coordination we talked about throughout the Conference externalities and space debris for instance. And so the unintended consequences. And how are those dealt with?

We need better ways to deal with those externalities and whether it’s policy and rules or incentives or agreements or kind of how do you take care of the issues after the fact and then the collective action that’s needed across countries so that we can have these frameworks. And there’s so much

common interests. So what do we have in common and what as Jennifer Manor pointed out you know best practices what best practices can be established and worked toward.

How do we want to deal with equitable access. And you know these are

different policy issues and philosophical goals about what countries will have the rights? Do we want to make it equitable versus the first.st Come 1st mover advantage.

But 1st come first st mover. You know those are the ones that often have the resources to provide the funding to use that 1st and then limited flexibility because it is such huge distances in space. And once decisions are made. And David Goldman talked about it too with even the regulatory process. But decisions are made early on and a lot of funding and money is invested in it.

So then once ready to launch or even once something is already launched and say the technology changes or things change. There is limited flexibility to adjust as compared to using spectrum on Earth economic drivers new business models. Some will be successful some won’t you know learning to

see where the the funding is? And and how can we provide the funding. So it’s it’s it’s companies but also governments different countries. So is there a way to to work together to

pull some of that funding the knowledge the innovation to achieve more and better. What incentives are there what incentives are needed and just how it can benefit the whole? Everybody on earth as well as reducing the risks there

in space so high costs much more expensive with the big distances. So you do have those significant upfront costs which often take longer to recoup.

and then the the greater complexities increased risks. So spectrum management on Earth is is very challenging on space even more so.

Thanks Caroline and and I’m going to jump in from a moderator’s prerogative here on the value of this slide that she’s put together for you is

often as many of you here know there are calls for regulation.

calls for new laws cause for calls for new treaties. But you really you need to have

a justification for those new rules and regulations. And so

this provides a nice list of market failures or regulatory failures. Right?

One of 2 things usually is happening there. That is causing the problem.

And so instead of just a reflexive from a stakeholder perspective saying we need to regulate this.

you can get much more targeted and specific to the exact market failure or regulatory failure

that is causing some kind of a harm or your problem all right. And and so this is I teach an Internet policy class. And

when I get the question from the student why do we regulate

right? You need to break it down and have a good reason that you’re just not reflexively trying to regulate everything. So there’s a nice slide that you can take to identify what applies and what doesn’t apply.

So I took the questions on your do you want to react to that at all? Or do you?

Yeah thank you. I mean this is unknown space. And so

I mean there’s there’s legal legal risks technology risks. It is truly multidisciplinary. But like I mean I do like how you mentioned. You know the regulatory failures versus the business failures and you know are there things that can be done incrementally? So it’s not so like you know. You put it. You don’t want to put all your eggs in one basket but kind of maybe experiment or try. Try different approaches and see how they work.

Okay we’ll go on now Scott if you want to give Scott the so David said we had 5 slides so being a good faculty member I made 10 and I thought what I really wanted to do is get across a couple of key points here really about aerospace Macros. Maybe help set the stage. You know the assumption is everybody knows what’s going on with regards to aerospace and dynamics.

Before doing that I wanted to make an unabashed plug for spectrumx. So if you’re not aware of spectrumx you can go to spectrumx.org. But we were founded about 4 years ago under the National Science Foundation Spectrum Innovation initiative and really focused to be the largest academic hub for technology economics and policy around spectrum issues.

So I wanted to kind of back up and give sort of a macro view of aerospace to people some of you. This may be very familiar some of this you know. Maybe you haven’t seen much of but if we start from the surface of the earth at the bottom here and move up in altitude really about 100 kilometers is where space starts and you can see there’s a plot in the bottom there the blue plot that’s atmospheric density. It falls off

exponentially. And we talk about being in the vacuum of space although you really still have atmospheric drag. So above 100 kilometers we sort of transition into space. We talk about the low Earth orbit regime that you’ve heard a lot about where a lot of the near Earth objects are flying. There’s a really interesting regime below that let’s say from about 200 to 400 kilometers.

called very v leo very low Earth orbit where there’s a lot of interest there with hypersonic vehicles and ongoing developments. I know we’re talking about lunar so I’m going to you know keep moving out. But I just wanted to sort of point out some interesting things. 400 kilometers. You see there is roughly where the space station and the space shuttle fly.

So one of the things that maybe is always assumed people know something about orbits right? So I think the point I like to try to make is

you can’t just drive around in space like you drive your car. You can’t go anywhere you want to. You’re really constrained by physics. And there’s a couple of sort of basic concepts here right? And the 1st one here is that your spacecraft typically flies in either an elliptical or circular orbit. So the easiest thing to assume is we’re flying in a circle and up at the top left. There you can see the plane of the circle

as an equatorial plane. We refer to that as an equatorial orbit. The middle one is a polar orbit where that plane of the spacecraft it’s flying over the pole. And then we have inclined orbits on the right. And so a lot of the Leo orbits we’ve been talking about

are these circular orbits tend to be inclined or polar orbits? So you think about there’s

more popular places you want to be where you’re operating in space. There’s you know call it beachfront property as we’re going and down in the lower right over here you can see on the bottom row. We move from low earth orbit up in altitude to geostationary orbit and the key about that is that spacecraft is moving at the same rate as the earth. So you’re saying over the same space in Earth right? The same

geographic location. So these Leo spacecraft.

they’re orbiting the Earth every 90 min they’re coming over. They may be overhead for 5 or 8 min and then they’re gone and then the next one comes over. And so this is not to scale but it sort of gives you an idea of the orbits with the earth. The Leo orbits here out to 2000 kilometers the Geo orbits. You heard a little bit about graveyard orbit. That’s how we dispose of things in Geo. You move them out to Super Geo. And get them out of the Geo orbit because they don’t come back and

Deorbit into the earth’s atmosphere. The things in Leo. We wait for those to come down and ablate and burn up as they come back in the Earth’s atmosphere. I think one of the interesting things also think about is we don’t just fly everywhere in space we have to think about these other macros. One of the important ones you have to think about is we have radiation belts. We have a natural particle accelerator

that makes some of these orbits very challenging to operate in. It causes you know spacecraft’s upsets and events. It makes those spacecraft very expensive. So you typically see we operate in Leo where we don’t have to deal with these things. And then Geo is you know out above the luckily out above the outer belt.

And so this what I wanted to start thinking about here is looking at where the spacecraft are located and thinking about distance as we’re talking about. You know how does distance impact the ability to operate and then think about distance in terms of something called space loss? Right? So

space loss is the attenuation you have in your signal over distance and so you can see as we go from Leo out to Meo and Geo. The difference between Leo and Geo is about a thousand times of attenuation in terms of space loss or 30. dB

we go out to the lunar environment. That’s at 300000 kilometers. So we have another 20 dB. Or a factor of 100 of attenuation. You go out to Mars depending on where Mars is relative to the earth. You’re somewhere between 50 and 400 million kilometers away. And I think one of the interesting things from the regulatory standpoint

is that the Itu finds deep space as any region of distance. It’s 2 million kilometers or greater from the earth’s surface. So you’re thinking about you know almost 8 times 7 times farther than the Earth moon distance before you’re getting into deep space. So think about you know from a regulatory standpoint the lunar environment still in the you know near Earth Cis lunar ecosystem from a

regulatory perspective. There’s also things to think about that there are more interesting places to be in space. There are Lagrange points where you want to put your spacecraft in the Earth Moon system or the Earth Sun position because it doesn’t take a lot of propulsion to stay there. So again thing to point out is as we go from

low Earth orbit out to the you know into the earth moon earth sun system. There are orbits that are of more interest and are more valuable than others just something to be taking into account when thinking about where people are going to be operating.

and then I think the you know one of the things we haven’t talked about at all something that I’m super excited about and Bullish about. I think optical communications are really the the place we should be thinking about and heading when we’re thinking about operating in in cislunar and deep space.

There’s been a number of great demonstrations. The Llcd. Demonstrated 622 megabits per second from the moon to the earth. Now granted that was done on a Lincoln lab budget using superconducting nanowires on the ground. But it shows you the fundamental capability that you can achieve with optical communications.

and you have no atmosphere to deal with. So when you’re thinking about the future I think we need to be considering optical communications. And then fundamentally this is just an eye chart from the Space Development Agency within the Dod and they’re leaning heavily into optical communications for networking of low Earth orbit satellites. And one of the things I don’t think David talked about is that all of the Spacex starlink spacecraft have optical intersatellite links

to connect those spacecraft. So I want to do kind of just a quick fly by and give some context here and then think about you know as we’re thinking about the you know the spectrum ecosystem you know I think as we think about you know back here with the distance and the impact that has and sort of how we might think about the neighborhoods as we go and what’s happening on the lunar surface versus the let’s say the backhaul links between the earth and the moon. And as we go farther out.

panelists have any comments or reactions.

So I love this slide and I’ll kind of pick on it. One of the things when we start talking about doing lunar is and we start talking about doing lunar spectrum management. What’s the basis of doing spectrum management

propagation models?

Where’s the propagation models for lunar.

Actually that’s 1 of the things being developed right now in the Itu

where the Itu the Itu is doing it. They’re working and its is one of the folks working on developing the P. Lunar model. And a lot of this is we’re missing. In some cases the fundamental science to do this right.

And we’re we’re learning as we go. But these are kind of setting up some of those basic things because we think we know how things are going to operate in space from an Rf propagation perspective. But we’re not totally sure yet.

So we’ve got a lot of things to learn. And as we go I think that’s going to be having to build into our regulatory models of sometimes we just might not have the right assumptions to start with.

Okay no I think that’s exactly right. And it’s vital that we have accurate prediction models because it gets back to one of my initial points. And what was just presented which is.

some places on the lunar surface are going to be more congested and more compelling than others. Right? Think South Pole and all of the bases and other payloads that are going to be placed there. Some orbits are going to be much more compelling than others. Specifically the Lagrange points that you point out.

And so you know the the impetus behind. What I’m trying to stress here is that

it’s because of that environment and those characteristics that we need some sort of robust management framework that’s embedded around clear understood technical principles rather than at least what seems to be kind of the cursory point at the moment which is okay. Well.

we’ll just go through it. Coordination procedures and people will figure it out. I’d like to see something a little more formal and robust than just that reliance. So Scott can you go to your chart that had the different

inclines of the orbits because one of the there was Cyclopedia Britannica. Yeah 1 1 of the comments and I can’t remember who it was. I don’t know if it was you Milo or somebody was talking about. Maybe there’s room

for tightening up what the existing allocations are in terms of the orbit. You know that

it’s like 6 to 8 degrees or or 2 to 4 degrees. Do you see room

in kind of for at least like the the Leos and Geos

room for improvement in additional capacity by using newer technology and being able to tighten that up.

I think it’s I mean I think when you think about you know the spectrum management challenge. I know I like the term. I don’t know if Al you were the one that talked about it or you know other colleagues but of electro space right? Where it’s you know separating you know you can separate things in frequency. You can separate things in time. You can separate things in coding. You can separate things in position right? If you’re thinking about how we manage. And so

I guess what you’re saying is can we tighten up the orbital dynamics? I mean you can fly very precise orbits. I mean we do that. I’m not sure how much value that brings to addressing

problem right? The the challenges. Well if if the problem is overuse or having you know too much if you can get a bit more capacity more spectrum efficiency.

then it’s something that that’s useful. The other question I had for you. Since

you’re you’re probably tracking. It is

how well you know. We then had some earlier comments about you know more and more debris and the different size of the debris. There’s a lot more like over millions of really small particles. And

is there research going on that is allowing us to track that better. And and you know like with AI and the like to be able to predict that much more is that going to be an area of concern for quite a while yet?

I mean you think about there’s sort of there’s the

the detection we can use radio radar or optical techniques to detect those things. There’s a limit on how far you can go in terms of you know on the radar side it’s just the Radar cross section. How much power you’re using right at some point you know to get the data into your predictive models. You can only get so far down in size.

Then you have the problem that you have space weather. So I talked about we didn’t get into space weather but that density curve. There it gets really small.

It has a huge impact. When we have a solar storm the atmosphere expands a bit. Then the spacecraft aren’t where we think they should be based on our basic Keplerian orbital elements. And now you have to retrack all those things again to find them and get them back into the into the system. So it’s

it’s just a fundamental challenge of a having the data. And then B understanding the physics of the atmosphere well enough and understanding how those physics impact the objects and how and where to find them. Okay.

so well we’ve got 15 min here and I promised that I

I can go on for a while and I probably the panelists can. We can ask each other questions here. But we we start with the wiser rule obviously. And any students that

remaining or Brad if you see some I’ll let you. I like to.

I’ll keep an eye out. But that’s that’s what it is okay.

There’s questions.

Hello John from Capella. So Scott I want to thank you for hitting on some of the optical stuff that’s coming up. But given the fact that

the regulations are written very heavily right now on the R. Spectrum. But there’s not a ton necessarily in the optical realm. Where do you see this going as we’re about to see a large boom in kind of the optics that are going up into orbit.

Yeah I think it’s 1 of the things to think about is why do we have the regulations in the Rf spectrum? And it’s manage interference right? It’s to manage the users so that you’re not negatively impacting each other. You know one of the benefits of optical is just how narrow those beam widths are. And you know I think at some point when you get to a sufficient density of optical users it.

I think it will be something that has to be considered and how we manage that. So I think it is

in near term. I think it’s less of an issue than it’s going to be downstream. I think there’s also a question that I don’t know. The answer to is you know when you have tens of thousands of optical transmitters how does that affect optical astronomy? Right? So there’s I think some of these some of these things that

we’re dealing with in the radio spectrum. We can get out in front of them with regards to to optical spectrum and how we manage it.

So do I have a crisp answer. I don’t. I think we’re so early in the stages that some of those things I don’t think have really been coming to the forefront. It’s more about can we actually make things work in space optically?

And I just would raise with optical that emerging new technology. It’s not just space

that you know. For example in the broadband deployment area middle mile is a real problem and particularly getting permits you know because of various regulations about going you know over wetlands and the like. And

guess what you know with an optical middle mile link. You don’t need a permit.

You need it maybe perhaps where you’re locating the facilities on each end. But it really can speed

up your ability to deploy on terrestrially as well.

Questions.

I’ll ask one. My name is Nicole Ila. I just graduated from law school here and I worked in the aerospace engineer in aerospace engineering before law school.

I have a question about

in thinking about the future of lunar spectrum management. How would you approach the enforcement of any regulations with the example of swarm. I remember when that happened when I was working some of my coworkers looked at what they did and thought wow! That was terrible and a few people looked at it and thought that was an insane risk but it paid off in the form of an acquisition.

So.

thinking that there will always be a certain number of people who are willing to disregard the norms of the regulations.

What would you propose for the future of lunar management.

Okay I’ll I’ll start

I’ve thought about that and I am of 2 minds. My number one says it’s high time that we recognize the stakes of allowing inertia and obsolescence in the space treaties to fester. There are just too many problems. There are chronic problems and there are emerging problems. So either you’re going to get serious

or you will get serious because there’ll be some sort of calamity and a calamity could be a tragedy of the Commons the so-called Kessler syndrome where a very expensive satellite becomes inoperative because it collided with space debris or asat anti-satellite testing technology the weaponization of outer space

results in a proliferation of space debris. So one scenario is a clarifying moment a catastrophe a calamity forcing the nations of the world to get serious.

The alternative is this polycentric necessity is the mother of inventions. Sort of strategy. The problem with that is you get Balkanization. You ignore common principles that were consensus driven like the Commons and you get 1st mover advantages. What you’re seeing in

manganese nodule prospecting may be a good example of 1st mover opportunities. How much can you extract without establishing property dominion and control? So I’m

as you could see in favor of the former. But I recognize that you know they’ve had 50 years to get serious about it and they haven’t so far a viewpoint of you know marketplace sort of driven

gold rush frontier kind of 1st mover opportunities sounds very compelling. But then the nations of the world especially the developing nations of the world will rally against that.

All right. Thank you Nicole. Nicole is actually a graduate of the spectrum management class. We had another question over here.

No no okay. I would suggest I think policy research and economic research is needed with technology research and innovation. I mean policy regulation can can innovate along with the technology.

And again data is helpful. We need more science and modeling. But we can also model economics. We can model policy based on data and assumptions. So working together I think could help develop a solution for that.

And also I think you you asked one of the the fundamental questions and one of the things that makes this so difficult. The Itu relies on the sovereignty of each nation to to handle that enforcement within their but their own boundaries.

What happens when we don’t have that? So I will. I’m the engineer. I will defer to the lawyers to solve that problem. Oh no I mean this was in my slides right? This is a fundamental problem. I frankly am not sure how to fix it right.

But yes the crutch we have always had is sovereignty.

because the interference interference occurs at the receiver right? So we enforce it on the ground based on whatever particular nation wants to do to manage

co-interference between satellite operators. We don’t have that luxury here.

It it becomes significantly more difficult to put a robust.

uniform governance regime in place that everyone respects and wants to abide by. That is really really hard. And I appreciate what Rob’s saying. I lack the same amount of faith that multilateral I mean might take it further I don’t think multilateralism is going to be the way forward. I have no faith that it’s going to occur

but it becomes concerning because then you’re getting into

you call it polycentrism. I’m going to be

even more harsh and say it’s borderline attributed lawmaking by private entities engaging with their particular governments to create norms that eventually accumulate into custom. I don’t know if we have the time to allow that to occur. The Flip side is Balkanization. I mean it worked for Yugoslavia. Is it going to work for space policy.

Okay? Another question.

Thanks for interesting panel David. And just because I can I’ll just tell you that I too am a veteran of Dale and Brian Tremont’s version of the spectrum

class the Maymester.

I want to. Just as an engineer say there are these things called initial conditions.

and terrestrially I have a lot of knowledge about fixed wireless and terrestrial wireless policy and experience direct experience using it.

The thing I also wanted to say about those initial conditions whether it’s terrestrial or orbital.

You have a scenario where you’re looking at a moving window of spectrum use and policy. And as more use happens more things occur over time. That was probably one of the most important lessons that the you know the Maymester teaches the students.

My question is and and Carolyn sort of started going down that direction.

How does data-driven policy and registration systems

accomplish the ability to in some fashion or form after the initial conditions are sort of established. Is there a way to track over time.

use of spectrum and be more proactive or ex ante in your regulation? It’s an open question. We don’t know what we don’t know but I figure it’s a worthwhile discussion. Yeah I mean I think that would be great to look at the data and so kind of the policy that’s in place.

What’s worked well what hasn’t worked? What are the externalities and then leveraging? You know what’s worked well to kind of tweak

and try to make things better over time. But then that does get into operators that have a lot of sunk costs and investment and it’s not easy to change things up in space. But we can work toward incremental policy improvements based on data and using AI machine learning to make it easier.

Just one little quick comment very quick. Ashley mentioned an operational data repository.

That’s a really great idea. If everybody that’s a stakeholder. And if you look at it as a multi-stakeholder opportunity.

Maybe there’s a cost to it. Maybe there isn’t. But everybody benefits. So the incentives might be there. Okay thanks Dan. Last question.

Hello! I’m Jillian Quigley from Wiley. I saw on one of the earlier slides that there were only a few of the satellite bands represented

in the list. So I think it said like XKUC. Band are there certain bands that are better on the moon and the one like which are the ones that we should be using and which are the ones that we shouldn’t be using?

Great question. I’m not in working party 7 B. So I’m kind of pulling secondhand. What I’ve been told someone that is probably can tell you better. My understanding is.

folks want to economize on the bands they’re already using with their payloads. Right? And so Z. Band is one X band Ku. I think the one that

correct me please the one that seems the most concerning from an outsider’s perspective is my understanding is the Chinese have proposed using S band and that seems very problematic for the radio astronomy folks on the dark side.

Yes so it’s 1 of them of the the Sfcg. Does have a lunar frequency plan.

So that’s out there and a lot of the and that is based on using the existing space research allocations. So it’s trying to fit this new paradigm into the existing set of regulations.

That’s another topic of conversation of if that’s a good idea or not. But given that’s the current framework we have. That’s what it’s built on. So most of the world as noted through Sfcg has adopted it. China is looking to go in a different direction but

everyone’s got 4.4 rights and S-band has all sorts of anyone who has dealt with S-band understands all the issues that come with S-band.

and I will not spend. How much time talk about how much time we spend doing s-band coordination. But it’s it’s 1 of them of.

I think everyone’s trying to figure out. How do we do this? And it’s the last frontier brave New World pick whatever favorite sci-fi phrase you want to use to describe this we’re all trying to figure it out. And we’re using the frameworks and tools we currently have. And I think the very accurate question is is does that make sense for where we’re going in the future?

Anybody else?

When?

Well we are just right on time and I want to make sure you get to lunch here or the the other session. So please join me in thanking the the panel here for some excellent comments.