Ya nadie duda que el espacio exterior es un campo de batalla. Uno en el que tendrán lugar, tanto para acciones físicas como virtuales.
Managing the Space Domain
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| La International Space Station, un emprendimiento ruso-norteamericano |
Eric Sterner | 17 May 2011
Debates over space policy typically concern three themes: national security, civil space and commercial space. National security discussions have historically focused on threats to space systems and the proper steps to either preclude, or respond to, those threats. Over the past several years, however, those discussions have grown more sophisticated, moving on to the broader issue of U.S. dependence on and use of space to enhance its military, economic and political power. In civil space, policy discussions address questions of resources and priorities: how much to spend and what to spend it on. Roughly every decade, civil space programs experience a soul-searching examination of their raison d'être, most notably in the United States. In commercial space, American debates typically start with the premise that commercial space activity is desirable and then proceed to discussions over what the government can, or should, do to enhance it.
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| Logo del Comando del Espacio de los EEUU. |
While a lot of creative thinking and policy analysis is involved in these existing debates, less attention has been paid to more basic functions, such as managing activity in the domain of space. Several factors contribute to this state of affairs. The demands on basic management functions have been relatively modest: Space is vast, and the number of spacefaring states was small. That is changing. The world moved from two spacefaring states in the 1960s to a handful by the 1970s and 1980s. That became a dozen or more of varying capability in the 1990s, and is in the dozens today. Nine countries -- including the 19-member European Space Agency -- have successfully launched payloads to orbit. More than 50 countries design, develop, deploy, own or operate satellites or portions thereof. An even greater number have access to space services and products, such as remote sensing data, communications links and launch opportunities. This is usually through contracts and cooperative ventures with established space powers and their commercial enterprises, or through membership in international consortia that pool resources to develop and offer such capabilities on an open market. In short, space has gotten more populated. It will only grow more so as more states discover the benefits of space applications and private entities field their own space systems.
Historically, existing space-management capabilities have been reasonably able to meet the needs for deconflicting routine space operations such as launches, satellite operations, spacecraft recovery and the like. When the occasional one-off situation presented problems, those arrangements were sufficient for working through them and adjusting accordingly. Some critics have raised concerns that those management capabilities are no longer up to the task of meeting growing demands. Against that background, a quick review of current mechanisms for avoiding and resolving such problems may be useful.
Historically, existing space-management capabilities have been reasonably able to meet the needs for deconflicting routine space operations such as launches, satellite operations, spacecraft recovery and the like. When the occasional one-off situation presented problems, those arrangements were sufficient for working through them and adjusting accordingly. Some critics have raised concerns that those management capabilities are no longer up to the task of meeting growing demands. Against that background, a quick review of current mechanisms for avoiding and resolving such problems may be useful.
Managing Physical Access to Space
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| Bandera de las Fuerzas Espaciales Rusas. |
Every space activity begins, at some point, with the launch of a spacecraft. A fair amount of domestic and international space law governs launch activities. The Outer Space Treaty of 1967 -- known formally as the Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer Space, Including the Moon and Other Celestial Bodies -- lays out several guidelines that nominally govern national space behavior. It makes states that are party to the treaty responsible for their activities and requires states to authorize and supervise the activities of private entities. Article VII makes state parties that launch, or procure the launch of, an object into outer space liable for damages done by that object or its component parts. Thus, in theory, states have a legal obligation and interest in ensuring that their launch activities do not conflict with the legitimate activities of other entities.
As a statement of principles, the Outer Space Treaty is useful. However, as a practical guide for behavior, it is not specific enough to be of much help. In 1972, to help address the situation, the major space powers signed the Convention on International Liability for Damage Caused by Space Objects. This treaty lays out roles, definitions and obligations for states that conduct space-launch activities and seeks to clarify the right of states to make claims against one another for damage done to them by a party's space objects. It also establishes an ad hoc claims commission to adjudicate complaints that cannot be resolved bilaterally.
The final pillar in international space law that governs movement to, in and from space is the Convention on Registration of Objects Launched into Outer Space, finalized in 1975. This treaty requires a launching state to establish a domestic registry of objects it launches, including a general description of their orbital behavior, and to notify the United Nations of the existence of such a registry. The treaty then instructs the U.N. secretary-general to maintain a central registry, open for inspection, based on the information provided. Indeed, the United Nations Secretariat has maintained such a registry since 1962 in accordance with a 1961 resolution of the U.N. General Assembly.
As a practical matter, each of these three treaties leaves it to the state parties to determine how they will comply. Historically, compliance has not placed excessive demands on launching states. Launch facilities were remotely located, with initial flight tracks -- where third-party damages in the event of an accident were most likely - directed over relatively unpopulated areas. States declared their launch windows publicly and announced exclusionary zones in order to warn air and sea traffic away from areas that might be affected by a launch gone wrong. This practice was already consistent with the implementing standards for the International Convention on Civil Aviation of 1944, which confirmed a state's sovereignty over its airspace and confirmed a nondiscriminatory right to create exclusionary zones.
Whether these regimes and practices will be adequate for the future remains to be seen. In addition to the nine entities that currently possess some launch capability, 11 countries have announced plans or intentions to launch their own payloads to orbit. While many of these will not materialize, growth in the number of countries launching payloads to orbit is likely. Even so, the existing regimes have proven effective because they reflect the self-interest of launching states in conducting safe launch activities.
Deconflicting Maneuvers
As a statement of principles, the Outer Space Treaty is useful. However, as a practical guide for behavior, it is not specific enough to be of much help. In 1972, to help address the situation, the major space powers signed the Convention on International Liability for Damage Caused by Space Objects. This treaty lays out roles, definitions and obligations for states that conduct space-launch activities and seeks to clarify the right of states to make claims against one another for damage done to them by a party's space objects. It also establishes an ad hoc claims commission to adjudicate complaints that cannot be resolved bilaterally.
The final pillar in international space law that governs movement to, in and from space is the Convention on Registration of Objects Launched into Outer Space, finalized in 1975. This treaty requires a launching state to establish a domestic registry of objects it launches, including a general description of their orbital behavior, and to notify the United Nations of the existence of such a registry. The treaty then instructs the U.N. secretary-general to maintain a central registry, open for inspection, based on the information provided. Indeed, the United Nations Secretariat has maintained such a registry since 1962 in accordance with a 1961 resolution of the U.N. General Assembly.
As a practical matter, each of these three treaties leaves it to the state parties to determine how they will comply. Historically, compliance has not placed excessive demands on launching states. Launch facilities were remotely located, with initial flight tracks -- where third-party damages in the event of an accident were most likely - directed over relatively unpopulated areas. States declared their launch windows publicly and announced exclusionary zones in order to warn air and sea traffic away from areas that might be affected by a launch gone wrong. This practice was already consistent with the implementing standards for the International Convention on Civil Aviation of 1944, which confirmed a state's sovereignty over its airspace and confirmed a nondiscriminatory right to create exclusionary zones.
Whether these regimes and practices will be adequate for the future remains to be seen. In addition to the nine entities that currently possess some launch capability, 11 countries have announced plans or intentions to launch their own payloads to orbit. While many of these will not materialize, growth in the number of countries launching payloads to orbit is likely. Even so, the existing regimes have proven effective because they reflect the self-interest of launching states in conducting safe launch activities.
Deconflicting Maneuvers
In some ways, the situation in space is more challenging. Compared to the number of launching states, or even the number of states that own and operate satellites, the number of objects moving around the planet is immense. United States Strategic Command's Joint Space Operations Center (JSpOC) follows roughly 22,000 objects, from as small as 10 centimeters across, in space. There may be more than 300,000 individual pieces of smaller debris. Collisions are expected, if not always predicted. Each one produces yet more objects and potential sources of collision. In other words, debris grows geometrically, and while a 10-centimeter piece of debris may not seem very big, when traveling at 10,000 miles per hour it is lethal.
The JSpOC does not continually track each object in space, as U.S. space surveillance capabilities are not up to that task. Rather, it uses a predictive technique, combining measured data points with the rules of physics to conduct massive computational exercises that predict where each object will go. It then acquires new data points and compares them against its computed predictions. The end result is a massive catalog of objects in space and the ability to predict possible collisions, or "conjunctions," as the Air Force calls them.
While some orbits are more popular than others and space is growing crowded, "crowded" remains a relative term. Space is still vast enough to accommodate its users. Between the United Nations registry mentioned earlier and information made available by the United States and some other countries voluntarily, it is possible for a responsible space actor to design orbital activities that minimize any risk of collision.
It bears noting that the United States does not play the role of "traffic cop" in offering its services. It merely offers the benefits of its capabilities to other spacefaring entities on a reimbursable basis. Participation in the program is voluntary, requires information sharing and is subject to prescreening for national security purposes. There is no requirement that an entity, once warned of a possible conjunction, take avoidance measures, although one could argue that existing treaties create both obligations to take reasonable precautions not to harm others and liability for any damages caused by negligence.
Conjunctions with discarded or abandoned spacecraft are a different matter. In those cases, liability for a collision still exists, but the ability to do anything about it may not. Again, early in the space age, such conjunctions were not a major concern, as there were simply not enough objects in space. However, as the number of objects in orbit has grown, discarded satellites have come to represent a regular navigation hazard. As sources of orbital debris, they contribute significantly to the growth of a threat to all spacefarers.
As often as not, spacecraft that reach the end of their useful lives are simply turned off and left in the orbits in which they performed their missions. Alternatives include using fuel to re-enter the earth's atmosphere, where the spacecraft simply burns up, or boosting the spacecraft into a so-called graveyard orbit, where it is expected to remain out of the way. Problems exist with all three approaches. Turning satellites "off" and leaving them in their pre-assigned orbits increases the number of objects in space. Depending on the orbit, such dead spacecraft will still be subject to the earth's magnetic fields, solar weather, radiation belts and even the planet's atmosphere, each of which will contribute to the satellite's physical decay, exacerbating the debris problem.
Destruction through atmospheric re-entry is possible, but satellites are not designed for aerodynamic flight. Thus, their decaying orbits can be erratic and unpredictable, creating further hazards. Moreover, the spacecraft may contain toxic chemicals that might be spread into the atmosphere, and enough of the spacecraft may survive re-entry so as to represent a hazard as it plummets through someone's airspace. These latter hazards may be so small as to be disregarded, but they warrant some consideration.
The Federal Communications Commission now requires owners to boost their geosynchronous communications satellites into a graveyard orbit at the end of their lifespan as a condition of getting a license to use the electromagnetic spectrum. The requirement, of course, only applies to U.S.-licensed satellites. Even then, such orbits are not a perfect solution. Graveyard orbits are still subject to the vagaries of the space environment, which will affect these orbits in unanticipated ways over the course of time. For the foreseeable future, the risk may be small, but objects in space may well stay there for centuries. Ultimately, banishing satellites to a graveyard orbit does not permanently decide their fate.
The Electromagnetic Spectrum
The JSpOC does not continually track each object in space, as U.S. space surveillance capabilities are not up to that task. Rather, it uses a predictive technique, combining measured data points with the rules of physics to conduct massive computational exercises that predict where each object will go. It then acquires new data points and compares them against its computed predictions. The end result is a massive catalog of objects in space and the ability to predict possible collisions, or "conjunctions," as the Air Force calls them.
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| Cohete chino listo para ser lanzado. |
The United States developed these space-surveillance capabilities at considerable expense to serve its own national security interests. However, it recognized that tracking and predicting the movement of objects in space could help other spacefaring states reduce the vulnerability of their own spacecraft to collision. Consequently, it shares this information with trusted partners around the world, enabling them to maneuver spacecraft out of the way of approaching objects. Private groups also perform similar data analysis and prediction. The newly formed Space Data Association, for example, aims to provide effective support for satellite operators for "controlled, reliable and efficient sharing of data that is critical to the safety and integrity of satellite operations." In 2010, the JSpOC conducted 7,000 conjunction screenings, which resulted in 126 collision avoidance maneuvers, a 10 percent increase from 2009.
While some orbits are more popular than others and space is growing crowded, "crowded" remains a relative term. Space is still vast enough to accommodate its users. Between the United Nations registry mentioned earlier and information made available by the United States and some other countries voluntarily, it is possible for a responsible space actor to design orbital activities that minimize any risk of collision.
It bears noting that the United States does not play the role of "traffic cop" in offering its services. It merely offers the benefits of its capabilities to other spacefaring entities on a reimbursable basis. Participation in the program is voluntary, requires information sharing and is subject to prescreening for national security purposes. There is no requirement that an entity, once warned of a possible conjunction, take avoidance measures, although one could argue that existing treaties create both obligations to take reasonable precautions not to harm others and liability for any damages caused by negligence.
Conjunctions with discarded or abandoned spacecraft are a different matter. In those cases, liability for a collision still exists, but the ability to do anything about it may not. Again, early in the space age, such conjunctions were not a major concern, as there were simply not enough objects in space. However, as the number of objects in orbit has grown, discarded satellites have come to represent a regular navigation hazard. As sources of orbital debris, they contribute significantly to the growth of a threat to all spacefarers.
As often as not, spacecraft that reach the end of their useful lives are simply turned off and left in the orbits in which they performed their missions. Alternatives include using fuel to re-enter the earth's atmosphere, where the spacecraft simply burns up, or boosting the spacecraft into a so-called graveyard orbit, where it is expected to remain out of the way. Problems exist with all three approaches. Turning satellites "off" and leaving them in their pre-assigned orbits increases the number of objects in space. Depending on the orbit, such dead spacecraft will still be subject to the earth's magnetic fields, solar weather, radiation belts and even the planet's atmosphere, each of which will contribute to the satellite's physical decay, exacerbating the debris problem.
Destruction through atmospheric re-entry is possible, but satellites are not designed for aerodynamic flight. Thus, their decaying orbits can be erratic and unpredictable, creating further hazards. Moreover, the spacecraft may contain toxic chemicals that might be spread into the atmosphere, and enough of the spacecraft may survive re-entry so as to represent a hazard as it plummets through someone's airspace. These latter hazards may be so small as to be disregarded, but they warrant some consideration.
The Federal Communications Commission now requires owners to boost their geosynchronous communications satellites into a graveyard orbit at the end of their lifespan as a condition of getting a license to use the electromagnetic spectrum. The requirement, of course, only applies to U.S.-licensed satellites. Even then, such orbits are not a perfect solution. Graveyard orbits are still subject to the vagaries of the space environment, which will affect these orbits in unanticipated ways over the course of time. For the foreseeable future, the risk may be small, but objects in space may well stay there for centuries. Ultimately, banishing satellites to a graveyard orbit does not permanently decide their fate.
The Electromagnetic Spectrum
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| Modelo del europeo Ariane 1. |
For the near term, conjunctions are actually not the most significant challenge for spacecraft operating in orbit. Space remains vast enough, and spacecraft small enough, that collisions are still relatively rare. A larger challenge presents itself, however. Spacecraft in orbit use the electromagnetic spectrum to communicate with the ground and sometimes with each other. To travel the required distances, the signals these spacecraft use must be very strong. At the same time, radio signals propagate like waves, meaning they spread out as they move away from their source. At the distances involved in space, they can cover quite a large three-dimensional area.
As a result of these basic properties, the potential for interference with other satellites' use of the electromagnetic spectrum always exists. Such interference can effectively limit a spacecraft's ability to perform its functions. In order to avoid inadvertent interference, the world relies on an international organization, the International Telecommunication Union (ITU), to coordinate use of the electromagnetic spectrum across national boundaries. While the ITU was created 145 years ago to manage terrestrially based telecommunications, it has grown and adapted with the changing state of technology and the world. Currently an office within the United Nations, the organization has 192 member states and more than 700 private-sector members and associates -- including private firms, nongovernmental organizations and observers. The ITU essentially manages the electromagnetic spectrum by allocating orbital "slots" for geosynchronous communications satellites and dividing up the electromagnetic spectrum for various uses.
Every few years, the ITU convenes the World Radiocommunication Conference (WRC), at which members vote democratically on various ITU policies, such as the division of separate electromagnetic bands. The agenda for the organization's 2012 conference, for example, includes aeronautical mobile-satellite services, the use of the spectrum for unmanned aerial vehicles, a discussion of technical updates in the use of particular bandwidths and the protection of bandwidth for scientific users, among a host of other issues. Past conferences have dealt with spectrum for use by space-based radionavigation systems, such as the Global Positioning System. Indeed, these decisions stood to affect the evolution of GPS as much as, if not more than, specific decisions about satellite design and contract awards.
Although its decisions are often made as much for political reasons as for sound technical reasons, the ITU/WRC process generally works well. It has provided the regulatory framework and predictability needed to enable the growth of a healthy communications-satellite sector, the enhancement of national capabilities through the use of space-based platforms such as weather satellites, and the innovation in new space goods and services that have made them part and parcel of the global information infrastructure.
That said, the process is not well-suited to dealing with fast-breaking events or changes. For example, in 2010, the private owners of the Galaxy-15 communications satellite lost control over their newly launched spacecraft. Although the satellite's communications payload continued operating, Galaxy-15's owners could not issue the station-keeping commands used to maintain its ascribed position or turn off the satellite's communications payload. Consequently, the satellite drifted, creating a de facto hazard for other spacecraft, particularly by threatening to interfere with their signals. Because this "zombiesat," as some wags dubbed it, was a first-of-its-kind event, there were no established procedures for managing the problem. Roles and relationships had to be worked out in real time on an ad hoc basis.
Fortunately, the owners of other spacecraft in the area were able to take precautionary measures, and interference with other satellites turned out to be minimal. Intelsat, which owned Galaxy-15, eventually regained sufficient control over it to conclude the episode. Nevertheless, the incident highlights a shortcoming of existing rules in dealing with sudden developments. At the same time, however, the successful communication and interaction among affected parties demonstrates that existing relationships are flexible enough to enable cooperation among affected parties.
Conclusions
Most of the existing regimes and practices governing space launch and in-orbit behavior presume, and benefit from, the self-interested, candid and voluntary cooperation of space actors. It is less clear how these regimes could withstand assault from an intentionally bad actor. Some states have interfered with the spacecraft of others in peacetime -- Iran has reportedly jammed American and European communications satellites -- or behaved in a reckless manner, as in China's 2007 anti-satellite test. The international community, such as it is, has not sanctioned these actors, other than to issue diplomatic demarches through normal diplomatic channels. Similarly, there is some question whether Iran is complying with its obligations regarding the operations of the Zareh-2 communications satellite. The ITU is not prepared to deal with actors that disingenuously represent their actions to the organization, nor is it clear how to resolve disputes between the ITU secretariat and a state.
Even so, it should be clear that outer space is not the Wild West, a lawless area of chaos and risk, as some advocates of more explicit rule-making for space have suggested. In fact, quite the reverse is true. Principles governing space behavior are established in international law. States have cooperated to establish more-specific guidance and regulatory regimes, such as that which governs the electromagnetic spectrum, where they have been necessary or useful. New practices, such the U.S. effort to improve general world space situational awareness, and cooperative ventures, such as the Space Data Association, have also been developed to aid space's occupants.
In effect, people have learned to drive on the right side of the road without specifically being told that they must, suggesting an underlying strength and flexibility that serves spacefaring actors well. It is eminently feasible to improve the process by enhancing the cooperative mechanisms that exist, while states consider more proactive measures -- such as forceful, consistent diplomacy and sanctions -- to supplement the liability regime in dealing with disingenuous, uncooperative or reckless space actors. In other words, states can use the tools already at hand to adjust to the growing number of spacefaring entities, modifying them as necessary.
Collectively, these measures have enabled a rapidly growing number of entities to use space for the benefit of mankind, whether to promote international security, enhance global economic growth, improve the quality of life or simply enhance the sum total of human knowledge through peaceful scientific and exploratory activities. While any set of rules can be improved, it will be critical to ensure that new efforts do not undermine this track record of success.
Eric Sterner is a fellow at the George C. Marshall Institute. He was a senior professional staff member on the House Armed Services and Science Committees and served in the Office of the Secretary of Defense and as NASA's associate deputy administrator of policy and planning.
As a result of these basic properties, the potential for interference with other satellites' use of the electromagnetic spectrum always exists. Such interference can effectively limit a spacecraft's ability to perform its functions. In order to avoid inadvertent interference, the world relies on an international organization, the International Telecommunication Union (ITU), to coordinate use of the electromagnetic spectrum across national boundaries. While the ITU was created 145 years ago to manage terrestrially based telecommunications, it has grown and adapted with the changing state of technology and the world. Currently an office within the United Nations, the organization has 192 member states and more than 700 private-sector members and associates -- including private firms, nongovernmental organizations and observers. The ITU essentially manages the electromagnetic spectrum by allocating orbital "slots" for geosynchronous communications satellites and dividing up the electromagnetic spectrum for various uses.
Every few years, the ITU convenes the World Radiocommunication Conference (WRC), at which members vote democratically on various ITU policies, such as the division of separate electromagnetic bands. The agenda for the organization's 2012 conference, for example, includes aeronautical mobile-satellite services, the use of the spectrum for unmanned aerial vehicles, a discussion of technical updates in the use of particular bandwidths and the protection of bandwidth for scientific users, among a host of other issues. Past conferences have dealt with spectrum for use by space-based radionavigation systems, such as the Global Positioning System. Indeed, these decisions stood to affect the evolution of GPS as much as, if not more than, specific decisions about satellite design and contract awards.
Although its decisions are often made as much for political reasons as for sound technical reasons, the ITU/WRC process generally works well. It has provided the regulatory framework and predictability needed to enable the growth of a healthy communications-satellite sector, the enhancement of national capabilities through the use of space-based platforms such as weather satellites, and the innovation in new space goods and services that have made them part and parcel of the global information infrastructure.
That said, the process is not well-suited to dealing with fast-breaking events or changes. For example, in 2010, the private owners of the Galaxy-15 communications satellite lost control over their newly launched spacecraft. Although the satellite's communications payload continued operating, Galaxy-15's owners could not issue the station-keeping commands used to maintain its ascribed position or turn off the satellite's communications payload. Consequently, the satellite drifted, creating a de facto hazard for other spacecraft, particularly by threatening to interfere with their signals. Because this "zombiesat," as some wags dubbed it, was a first-of-its-kind event, there were no established procedures for managing the problem. Roles and relationships had to be worked out in real time on an ad hoc basis.
Fortunately, the owners of other spacecraft in the area were able to take precautionary measures, and interference with other satellites turned out to be minimal. Intelsat, which owned Galaxy-15, eventually regained sufficient control over it to conclude the episode. Nevertheless, the incident highlights a shortcoming of existing rules in dealing with sudden developments. At the same time, however, the successful communication and interaction among affected parties demonstrates that existing relationships are flexible enough to enable cooperation among affected parties.
Conclusions
Most of the existing regimes and practices governing space launch and in-orbit behavior presume, and benefit from, the self-interested, candid and voluntary cooperation of space actors. It is less clear how these regimes could withstand assault from an intentionally bad actor. Some states have interfered with the spacecraft of others in peacetime -- Iran has reportedly jammed American and European communications satellites -- or behaved in a reckless manner, as in China's 2007 anti-satellite test. The international community, such as it is, has not sanctioned these actors, other than to issue diplomatic demarches through normal diplomatic channels. Similarly, there is some question whether Iran is complying with its obligations regarding the operations of the Zareh-2 communications satellite. The ITU is not prepared to deal with actors that disingenuously represent their actions to the organization, nor is it clear how to resolve disputes between the ITU secretariat and a state.
Even so, it should be clear that outer space is not the Wild West, a lawless area of chaos and risk, as some advocates of more explicit rule-making for space have suggested. In fact, quite the reverse is true. Principles governing space behavior are established in international law. States have cooperated to establish more-specific guidance and regulatory regimes, such as that which governs the electromagnetic spectrum, where they have been necessary or useful. New practices, such the U.S. effort to improve general world space situational awareness, and cooperative ventures, such as the Space Data Association, have also been developed to aid space's occupants.
In effect, people have learned to drive on the right side of the road without specifically being told that they must, suggesting an underlying strength and flexibility that serves spacefaring actors well. It is eminently feasible to improve the process by enhancing the cooperative mechanisms that exist, while states consider more proactive measures -- such as forceful, consistent diplomacy and sanctions -- to supplement the liability regime in dealing with disingenuous, uncooperative or reckless space actors. In other words, states can use the tools already at hand to adjust to the growing number of spacefaring entities, modifying them as necessary.
Collectively, these measures have enabled a rapidly growing number of entities to use space for the benefit of mankind, whether to promote international security, enhance global economic growth, improve the quality of life or simply enhance the sum total of human knowledge through peaceful scientific and exploratory activities. While any set of rules can be improved, it will be critical to ensure that new efforts do not undermine this track record of success.
Eric Sterner is a fellow at the George C. Marshall Institute. He was a senior professional staff member on the House Armed Services and Science Committees and served in the Office of the Secretary of Defense and as NASA's associate deputy administrator of policy and planning.
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