ARCLab Statement on Orbital Carrying Capacity for Policymakers

ARCLab believes that environmental impact should be considered by both mission designers and regulators when designing and approving missions. Anticipated growth in the active orbital population over the coming decade is sufficient to implicate capacity-based concerns, particularly given evidence that background debris levels will already experience growth, even with no further launches.

Carrying capacity is best viewed not as number, but rather a set of potential solutions compatible with a particular set of modeling assumptions and technical criteria that define constraints to capacity. The concept of capacity encompasses multiple types of analysis including: 1) assessing the relative efficiency of a mission versus a reference case; 2) calculating a mission’s marginal effect on the space environment; and 3) determining whether inputs will exceed environmental threshold conditions.

We believe there is a need to build technical consensus in several areas:

1. The values or range of values to be used for technical studies assessing capacity including solar cycle assumptions, reference launch profiles (and demand models), post-mission disposal rates, collision-avoidance capabilities, and fragmentation events.
2. Definitions of constraints to capacity associated with stakeholder-permissible outcomes for long-term environmental trends, operational collision avoidance burden and expected mortality, and intrinsic capacity. Additional potential capacity-limiting constraints include access to spectrum, impact on astronomical observations, ground casualty risk, carbon emissions, and material deposition in the upper atmosphere during re-entry.
3. Building community familiarity with, trust in, and capacity to use one or more verified, open-access (ideally open-source) modeling frameworks. Consensus modeling techniques and assumptions can be used to rigorously identify and condemn bad faith weaponization of sustainability for market exclusion purposes.

In parallel with work to build technical consensus and capacity, there is a need for policy-level discussion about management models to ensure authorization decisions reflect carrying capacity limitations.

We believe existing fixed per-spacecraft rules are insufficient to ensure long-term sustainability, that a regulator needs organic technical capabilities to implement effective, considered management, and that adversarial notice and comment rulemaking is ill-suited to achieving stakeholder support and consensus necessary for durable, efficient, and rational space environmental management.

Instead, we believe that stakeholders should investigate implementing forms of adaptive management and adaptive governance. Adaptive management seeks to mitigate inherent scientific, behavior, and ecological uncertainty through the integration of modeling and adaptation to observed environmental responses in policy. Studies in multiple domains show that adaptive management is better able to achieve environmental management goals, while providing additional flexibility to stakeholders, particularly for systems involving stakeholders with multiple types of equities. Adaptive management improves regulatory predictability and certainty versus fixed rules, particularly when models and decision-rules are public and for systems subject to low probability, high consequence events. Adaptive governance recognizes that adaptive management is fragile and may fail if stakeholders are not represented, if management goals are disconnected from stakeholder interests, or if management decisions are made using decision-rules that are unacceptable to stakeholders. Adaptive government focuses on creating processes that ensure management practices remain aligned with stakeholder needs. Doing so leads to more durable, rational outcomes for resource management.