Space Standards, Rules, Innovation, and Inhibition

1. Space Standards, Rules, Innovation, and Inhibition DAVID FINKLEMAN CENTER FOR SPACE STANDARDS AND INNOVATION ANALYTICAL GRAPHICS INC. AAS 05-198 COPPER MOUNTAIN, COLORADO JANUARY 23-27, 2005

2. OVERVIEW INTRODUCTION • Purpose: To introduce the astrodynamics and space operations community to the role of international standards, the implications of standardization, and current thrusts in space standards. • Overview • Structure of the international standards community and its entry into the space enterprise. • Legal, ethical, and competitive implications of standardization • Orbit determination and estimation • Communication with and among satellites • Satellite navigation and precise positioning • Current initiatives within the International Standards Organization (ISO) Orbital Debris Coordination Working Group (ODCWG) • Orbital data exchange for mitigating collisions and resulting space debris • Conclusions

3. THE INTERNATIONAL ORGANIZATION FOR STANDRADIZATION (ISO) • ISO is a network of the national standards institutes of 146 countries, on the basis of one member per country, with a Central Secretariat in Geneva, Switzerland, that coordinates the system. • ISO is a non-governmental organization: ISO occupies a special position between the public and private sectors. • International Standards are achieved through consensus agreements between national delegations representing all the economic stakeholders concerned. • International Standards provide a reference framework, or a common technological language, between suppliers and their customers - which facilitates trade and the transfer of technology. • ISO standards are voluntary. ISO has no legal authority to enforce their implementation. A certain percentage of ISO standards has been adopted in some countries as part of their regulatory framework. • ISO develops only those standards for which there is a market requirement. The work is carried out by experts on loan from the industrial, technical and business sectors which have asked for the standards, and which subsequently put them to use.

4. THE AMERICAN NATIONAL STANDARDS INSTITUTE (ANSI) • ANSI promotes the use of U.S. standards internationally, advocates U.S. policy and technical positions in international and regional standards organizations, and encourages the adoption of international standards as national standards where they meet the needs of the user community. • The National Technology Transfer and Advancement Act of 1995 (P.L. 104-113) (NTTAA) and The Office of Management and Budget Circular A-119, virtually mandate that government agencies use ANSI voluntary consensus standards developed by the private sector • ANSI has delegated the responsibility for space standards to the AIAA. • Does this delegation give the AIAA the right to determine space standard policy for the US?

5. NIST IMPLEMENTATION OF NTTAA

6. DOD STANDARDS ENTERPRISE

7. MANDATED USE OF CONSENSUS STANDARDS • MEMORANDUM FOR STANDARDS EXECUTIVES • SUBJECT: Guidance on Reporting the Use of Voluntary Consensus Standards • FROM: Mary H. Saunders, Chair Interagency Committee on Standards Policy • This memorandum provides additional guidance from the National Institute of Standards and Technology (NIST) to Federal agencies on how to report their use of voluntary consensus standards to NIST under the requirements in the National Technology Transfer and Advancement Act of 1995 (NTTAA) and the Office of Management and Budget's (OMB) Circular A-119 (the Circular). This guidance is intended to facilitate both reporting by individual agencies and consistency of reporting across agencies. • According to Paragraph 9 of the Circular: • As required by the Act, your agency must report to NIST, no later than December 31 of each year, the decisions by your agency in the previous fiscal year to use government-unique standards in lieu of voluntary consensus standards. If no voluntary consensus standard exists, your agency does not need to report its use of government-unique standards. In addition, an agency is not required to report on its use of other standards. Your agency must include an explanation of the reason(s) why use of such voluntary consensus standard would be inconsistent with applicable law or otherwise impractical, as described in Sections 11b(2), 12a(3), and 12b(2) of OMB Circular A-119 (Circular). Your agency must report in accordance with format instructions issued by NIST. • Your agency must report to NIST, no later than December 31 of each year, information on the nature and extent of agency participation in the development and use of voluntary consensus standards from the previous fiscal year. Your agency must report in accordance with format instructions issued by NIST. Such reporting must include the following:(2) The number of voluntary consensus standards the agency has used since the last report, based on the procedures set forth in sections 11 and 12 of this Circular."

8. OMB Circular A-119 - Federal Participation in the Development and Use of Voluntary Consensus Standards and in Conformity Assessment Activities "The use of [voluntary consensus] standards, whenever practicable and appropriate, is intended to achieve the following goals: • Eliminate the cost to the Government of developing its own standards and decrease the cost of goods procured and the burden of complying with agency regulation. • Provide incentives and opportunities to establish standards that serve national needs. • Encourage long-term growth for U.S. enterprises and promote efficiency and economic competition through harmonization of standards. • Further the policy of reliance upon the private sector to supply Government needs for goods and services."

9. WHERE SPACE STANDARDS FIT • ISO Technical Committee (TC) 20, Aircraft and Space Vehicles • Subcommittee (SC) 6 develops the Standard Atmosphere • SC 8 standardizes aerospace terminology • SC 13 - Space Data and Information Transfer System • JPL (Adrian Hooke) • The Consultative Committee for Space Data Standards (CCSDS) is the most active space related standards body. • More than 250 missions fly voluntarily with CCSDS protocols and approaches to space qualified hardware and software. • The Space Assigned Numbers Authority (SANA) a subgroup of TC20/SC13/CCSDS standardizes spacecraft identification and elements of data streams within data transfer protocols SC 14 - Space Systems and Operations • SC 14 – Space Operations • AIAA (Craig Day) • The Orbital Debris Coordination Working Group (ODCWG) spans all SC’s whose subject areas affect the generation, mitigation, and response to debris. • ANSI and members of SC’s 13 and 14 have initiated the bureaucratic process of forming a new technical committee just for Space.

10. WHAT SHOULD BE STANDARDIZED? • Criteria • Is the health, safety, or welfare of the world affected? • Is commerce or productive collaboration promoted? • Is National security affected, or might a standard compromise National security? • Are creativity and progress encouraged or inhibited? • Examples in which standardization meets the criteria positively • Earth and planetary potentials • Atmospheric parameters • Timing • Earth Rotation and Inclination

11. WHAT SHOULD NOT BE STANDARDIZED • Standards should enable comparison among diverse approaches not restrict the manner in which stakeholders perform their missions. • What should not be standardized. • Physical hypotheses and approximations • Different phenomena matter in different orbit regimes and for different missions • Numerical Techniques • Discretization and computational architecture must be well matched to the physics and the data • Data or observation densities and frequencies • Different phenomena occur on different temporal and spatial scales, some need be sampled frequently others only occasionally.

12. STANDARDS CHANEL DEVELOPMENT • Collision of legal issues and competitive issues, • short-term and long-term factors • Ethical responses • Global “good citizen” behavior • US “good citizen” behavior • Short-term profits. • Three examples: • Orbit determination and estimation, • Communication with and among satellites • Satellite navigation and precise positioning.

13. SPACE SURVEILLANCEPL 108-136, SECTION 914 • ESTABLISHMENT- “The Secretary of Defense shall carry out a pilot program to provide eligible entities outside the Federal Government with satellite tracking services using assets owned or controlled by the Department of Defense. “ • ELIGIBLE ENTITIES- “The Secretary shall prescribe the requirements for eligibility to obtain services under the pilot program. The requirements shall, at a minimum, provide eligibility for the following entities: • (1) The governments of States. • (2) The governments of political subdivisions of States. • (3) United States commercial entities. • (4) The governments of foreign countries. • (5) Foreign commercial entities.” • CONTRACTOR INTERMEDIARIES- “Services under the pilot program may be provided either directly to an eligible entity or through a contractor of the United States or a contractor of an eligible entity.” • NONTRANSFERABILITY AGREEMENT- “The Secretary shall require a recipient of services under the pilot program to enter into an agreement not to transfer any data or technical information, including any analysis of satellite tracking data, to any other entity without the expressed approval of the Secretary.” • We interpret this to restrict products (e.g., analysis of satellite tracking data) provided by Space-Track, not subsequent analysis based on Space-Track products.

14. SPACE SURVEILLANCE STANDARDIZATIONIMPLICATIONS AND ISSUES • Sharing observations or products derived from observations leads to legal, ethical, competitive, and diplomatic issues. • If a private or national organization provides satellite observations to others and an expensive anomaly can be attributed to the quality of those observations, who is liable? • If a satellite owner/operator has more precise information about another owner/operator’s satellite, should he withhold that information for competitive advantage. • If a precise knowledge of a satellite’s state of motion could enable hostile acts against that satellite, should observations be intentionally corrupted or shared at all? • How do standards help resolve these questions? • By allowing the space industry to state acceptable norms without resorting to the imposition of legal definitions from external bodies. • This could be what The National Technology Transfer and Advancement Act of 1995 (P.L. 104-113) (NTTAA) and The Office of Management and Budget Circular A-119 require. • Once ISO standards exist, Government agencies may be required to use them • This is a great incentive for the Astrodynamics community to expedite such standards.

15. INTRA-SATELLITE COMMUNICATION • The Internet Engineering Task Force (IETF) is an element of the ISO. • It is the governing body for terrestrial internet communication and for the interaction of space missions with the terrestrial internet. • TCP/IP is not well suited for long delay, high bit error rate, asymmetric bandwidth conditions that characterize communication with distant nodes, such as high altitude aircraft or satellites.[1] • TCP is an end to end protocol, negotiating feedback between sender and recipient. IP is responsible for carrying data across the network hop-by-hop. • TCP is encapsulated within IP datagrams. • TCP is a “reliable” protocol, one whose exchanges assure that each data packet is received completely accurately. • IP is an “unreliable” protocol, since there is no assurance that a packet was received accurately after it is released. • “Reliable” protocols must wait for distant end feedback before routers can remove copies of recently transmitted packets from buffers. • To reduce latency, most protocols transmit several packets in succession, the payload of each buffered. • Buffered data is purged when the recipient of any packet within the sliding many-packet windows acknowledges correct receipt. • The minimum window size to fully use a link is the bandwidth of the link (bits/sec) multiplied by the round trip delay time (sec), called the bandwidth-delay product. • Space communications have long round trip delay times (500 msec for GEO), minutes to hours for true space vehicles • Each transaction (for example, just acknowledgement, not necessarily sending data) may “time out,” the sender inferring that the recipient did not receive the interaction sending the same thing again and again. [1] Satellites and the Internet, Challenges and Solutions, DC Palter, SATNEWS publishers, 800 Siesta Way, Sonoma, CA 95476, 2004(ISBN 0-936361-36-0)

16. INTRA-SATELLITE COMMUNICATION(Continued) • Adhering to the long-held TCP/IP standard inhibits progress and commerce. • The greater native bandwidth of optical links will not be used very effectively within the scheme of old, internet protocol based data transfer. • Issues • Who will develop these standards in the face of the monstrous installed internet compatible base? • Who would adopt those standards without assured payback? • What would be the legal and competitive implications of the Government imposing such standards? • Is it ethical for a few large space organizations and companies to impose a growth restrictive communications architecture on a global industry? • What internal and external competitive risks is the US space industry willing to accept in expanding future markets? • Can two communications architectures be created and allowed to and compete in a single standards regime?

17. SATELLITE NAVIGATION AND POSITIONING • Emerging missions, such as tightly coupled sparse apertures, demand an order of magnitude better precision and bandwidth than current GPS-based schemes provide. • Dilutions of precision are less favorable than on the Earth and are often changing very rapidly. • GPS reception and onboard temporal resolution are affected by large Doppler shifts. • GPS transmissions may traverse more of the ionosphere and atmosphere in the limb of the Earth. • GPS is nearly co-altitude or below many important Earth satellite orbits. • The universe of Earth orbiting satellites benefit greatly from transmissions higher in the electromagnetic spectrum than GPS, (smaller antennas, freedom from multipath, atmospheric refraction, and scattering, and extremely precise stellar references). • This would facilitate greater mission efficiency • More effective use of densely populated orbital bands • Precise and nearly continuous satellite state determination • Reduced likelihood and enhanced response to potential encounters • Issues • Should we exploit the opportunity to establish standards in advance of firm concepts? • Who should sponsor developing such standards? • What are the legal and diplomatic implications of a new navigation scheme that might render current techniques undesirable? Should this be pursued cooperatively, internationally despite National security implications. • Is it ethical not to pursue such advances?

18. CURRENT SPACE STANDARDS INITIATIVES • ISO New Work Item Proposal (NWIP) 318, “Routes to Compliance and Management for Debris Mitigation” • describes goals and processes for debris mitigation, leading to specific standards in contributing technical areas • encompasses minimizing objects released during normal operations, preventing on-orbit breakups, removing mission ended systems from useful orbital regions (protected areas), minimizing the risk posed by reentries • Principles developed by the InterAgency (Space) Debris Coordinating Committee (IADC), a non-governmental group including representatives from all space-faring nations • control of debris released during normal operations • control of debris generated by accidental explosions • control of debris generated by intentional breakups • limiting debris generated by on-orbit collisions • post-mission disposal of space structures • limiting risk from debris surviving reentry • control of collision hazards of tether systems • Federal Communications Commission (FCC) Report and Order (FCC 04-130, June 2004) • Requires all who wish to communicate with the United States from orbit to submit plans for minimizing and mitigating orbital debris that might result. FCC rules are generally consistent with IADC and NASA guidelines. These are just abstract guidelines. Quantitative and specific standards are required

19. ISO FORM 4, NEW WORK ITEM PROPOSALCOMMON DATA FORMAT FOR COLLISION ASSESSMENT

20. COMMON DATA FORMATMARKET RELEVANCE

21. OUTLINE OF COMMON ORBIT DATA AND INFORMATION EXCHANGE STANDARD

22. SUGGESTED ELEMENTS OF A COMMON DATA FORMAT FOR EXCHANGINE ORBIT INFORMATION • Avoiding collisions requires common, trustworthy approaches for exchanging orbital data so that stakeholders can collaboratively understand the threat and plan mitigations. • A prescribed rigorous definition of the vector type, reference frame, units, digits-of-precision, and other essential information. If any stakeholders choose to operate in a different manner, they must still exchange data in the prescribed common reference frame. • Covariances should be required and the covariances should be captured in the TNW frame (T=tangential to osculating orbit, N='NADIR-like' and W=Orbit Angular momentum vector direction).  Sharing error matrices in this frame allows a rapid examination and breakdown of the in-track, cross-track and radial errors by inspection, together with ready access to the cross correlation terms.  • The rigorous reference frame should be LDBARV or Earth-Fixed Greenwich (Longitude, Declination, Beta=Inertial flight path angle measured with respect to the radius vector, Azimuth=inertial flight azimuth, Radius and Velocity). • In addition to fundamental orbital data, the following information should be exchanged for more complete understanding of predictions from different sources: • Physical models or simulations with which that data was employed to predict the potential collision • Numerical and computational information necessary to reproduce results • Practices and Procedures through which data, models, and numerics were employed to produce the collision estimate.

23. COMMUNITY INFLUENCE AND PARTICIPATION • We need feedback from the Astrodynamics community • Relevant documents are available • Inputs are required by April, in advance of the ODCWG meeting in May dfinkleman@centerforspace.com

24. CONCLUSIONS • The International and National Standards Communities are pursuing space standards aggressively. • The Astrodynamics community must guide selection of subjects for standardization • There are ethical, legal, and technical implications • We should not standardize physics or numerics except for the purpose of comparison, understanding, and collaboration • Standards for mitigating space debris are the highest priority • There are International and National guidelines but no guidance. • PL 108-136, Section 914 has ominous implications • Once International standards exist Government agencies must use them.