Uncontrolled Re-Entry is Not Disposal, It's Abandonment
October 6, 2022
Last Thursday, the Federal Communications Commission (FCC) voted regarding its new policy requiring defunct low-Earth orbit satellites be disposed of through uncontrolled atmospheric re-entry – the movement of an object from outer space back into Earth without being navigated – no more than five years following the end of its mission. This is a change from the current requirement of 25 years. When satellites stop working, they are effectively abandoned in orbit, becoming space debris in the act. This adds to the over 30,000 human-made space objects currently being tracked around the Earth, crowding orbits and putting vital satellites at risk of collision. It is ultimately insufficient to achieve the long term sustainability of space, working against space environmentalism and creating more pollution.
Uncontrolled re-entry is not disposal, but rather abandonment with the hope that Mother Nature will come to the eventual rescue and burn the abandoned object during the re-entry process. Environmentalism and sustainability are not achieved by hope. Imagine if we were all dumping an increasing amount of manufacturing waste into water sources, saying that’s an acceptable method of disposal because eventually, the waste will break down and decompose or become diluted in the water. This is exactly what happened to the Cuyahoga River, and nobody rectified this travesty until the river caught on fire over a dozen times. Near earth orbital rivers are our Cuyahoga River equivalent.
Moreover, for controlled re-entries, the global community has accepted Point Nemo, the most isolated place on the ocean from land, as the intentional resting place for any space object that is likely to survive re-entry. Any way you slice it, this is still pollution and poor waste management.
But what does that mean for us here on Earth?
The Dangers of Uncontrolled Re-Entry
Uncontrolled re-entry results in events like the recent Chinese rocket body – the size of a school bus – that could have landed on a populated area, risking the lives of many. Another recent space object, at about 9 feet long, survived re-entry and was found on a farm in Australia. These are just two examples of many other similar events. While we are lucky these landed in unpopulated areas, we may not be so fortunate next time. In fact, there’s a chance someone will die from falling space debris in the next decade.
This is not a responsible method of space object disposal, and we need to bring that same mentality to satellites on orbit. We can’t rely on satellites burning up in the atmosphere, polluting it with tiny particles remaining from the re-entry process.
Shifting our Mindset to a Circular Space Economy
Our current linear space economy is reflected in the hundreds of satellites being launched every few weeks without a global space traffic coordination and planning process. We gather materials for satellites and rockets and throw them away after use, creating a take-make-dispose line. We tend to launch satellites into specific orbital highways, or the paths followed by satellites, not knowing the carrying capacity of any given orbital highway nor how much of this carrying capacity is already being consumed. Saturation of the orbital carrying capacity would result in orbits becoming unusable because our decisions and actions would no longer be able to prevent undesirable outcomes. This lack of joint and holistic orbital space resource management prevents space environmentalism and sustainability because it obstructs Mother Nature from providing us feedback on the unintended consequences of our actions in space.
The change in direction the FCC and others must adopt and implement is one that develops and maintains a circular space economy, eliminating waste and pollution such as space debris, circulating products and materials via in-space servicing and manufacturing (ISAM), and helping regenerate the space environment by minimizing anthropogenic effects and impacts. We must first focus on pollution prevention, then space object reuse and recycling, with disposal and abandonment being disfavored.
Placing Responsibility for Space Sustainability on the Producer
Within waste management frameworks there is an Extended Producer Responsibility (EPR) whereby responsibility for the end-of-life of a product falls upon the shoulders of those producing them. EPR for space would mean that satellite and launch providers would make these easily reusable and recyclable in the very design of the product. Satellite and launch providers could delegate this responsibility to third parties, called Producer Responsibility Organizations (PROs), such as orbital debris cleaning and satellite servicing companies. The FCC, being forward leaning regarding the desire to prevent orbital debris, should make EPR a requirement for licensing.
In order for EPR to be successful, there must be a way to measure and monitor for compliance, and where lack of compliance exists, implement an effective mechanism for enforcement. While not trivial, this is very much achievable, given an emerging space commerce community willing and able to provide space situational awareness (SSA) and ISAM services. The Department of Commerce should be the construct that aggregates the required data and evidence, helps coordinate and support the SSA and ISAM community, and underpins the development and maintenance of a circular space economy.
Hope of Sustainability
Until then, we do not have sustainable space object disposal without a consequence to the environment, and uncontrolled re-entries are not responsible disposal but rather abandonment left to chance and hope of sustainability. And we owe it to space and our planet to create better solutions.