Originally published by Space Intel Report on January 10, 2024. Read the original article here.

LA PLATA, Maryland — SpaceX asked US regulators to force transparency on recalcitrant constellation operators to reduce collision risk immediately after in-orbit separation from launch vehicles and to provide contact information on Space-Track.org to facilitate communications between operators.

Specifically, SpaceX said any constellation operator selling services in the United States should be required to file semi-annual constellation status reports to the U.S. Federal Communications Commission (FCC). These reports would include data on satellite failures and deorbiting.

At the behest of the FCC, SpaceX has been doing this for several years. The latest report, filed Dec. 31, covers the six-month period through Nov. 30.

“SpaceX cannot maintain long-term space sustainability unilaterally and without non-US firms participating,” the company said. “No operator, and indeed no country, can do so. SpaceX therefore pleads once again for other operators — including those that have chosen to license their satellites outside the US and claim not to be bound by US rules yet want to offer services here — to provide similar public disclosures about the performance of their satellites.”

The company said “very few operators” provide as much satellite-performance data as SpaceX — “with several even claiming that they do not want to disclose their true performance to investors. Yet even a small system can cause a big risk when operated irresponsibly or without transparency.”

With some 7,000 satellites in orbit, Starlink’s constellation status reports are always going to include eye-popping figures.

50,666 collision-avoidance maneuvers June-November 2024 but a lower maneuver threshold

Here’s one: “SpaceX satellites performed 50,666 propulsive [collision-avoidance] maneuvers” in the six months ending Nov. 30 — “averaging approximately 35 maneuvers per satellite per year.” Here too, SpaceX said all operators should be forced to provide this data.

SpaceX argues that it performs more collision-avoidance maneuvers per satellite than other operators because it applies stricter risk-assessment criteria. Whereas the NASA-created industry standard is to move when there’s a one-in-10,000 chance of collision, SpaceX moves its satellites when there’s a 1 chance in 1 million.

The company said that other operators maneuvered their satellites to avoid Starlink, after coordination with SpaceX, fewer than 10 times in the six-month period.

Space situational awareness and satellite-tracking companies have long complained that too often it takes days or longer for groups of satellites to be catalogued individually after separation from their rocket.

SpaceX, which with its ride-share service for third-party fleets and its own Starlink launches puts more satellites into orbit each year than anyone else, said it pre-arranges a set of temporary catalogue ID numbers and uploads them to Space-Track.org “as close to deployment time as is possible.”

“Unfortunately, many satellite owner/operators do not pre-arrange the use of temporary catalogue identification numbers, nor do they screen ephemerides as quickly as is practical post-deployment.”

The US Space Force’s 19th Space Defense Squadron screens satellites for possible “conjunctions,” or collision risks, using the US Space Force’s ground- and space-based Space Surveillance Network. But it cannot perform this function for satellites whose owners have not shared their ephemeris data.

Even less comprehensible is the refusal of some satellite operators to share contact information on Space-Track.org. SpaceX said it does its best to find that information elsewhere. “But if SpaceX cannot contact the operator… SpaceX assumes maneuver responsibility and its satellites maneuver to lower the risk.”

SpaceX officials have often argued that there’s no need for tighter space-traffic regulation because operators should be willing to act in concert, in their mutual interest, to maintain space safety. Apparently that is not happening so far.

SpaceX said it took 14 satellites out of operation during the six months ending Nov. 30. But all of them retained their collision-avoidance capability after being taken out of service. All 14 were removed less than five years after they began commercial operations.

During the same period, 73 Starlink satellites reentered the Earth’s atmosphere— seven in June, 34 in July, 13 in August, 10 in September, three in October and six in November.

One satellite suffered a failure that prevented its standard disposal through atmospheric reentry. The satellite — Starlink-32386 — suffered a suspected power failure due to “sensitive components [that] have been identified and removed from future designs.”

The company estimated that would take just 17 days for the satellite to reenter the atmosphere from its 388 km by 406 km orbit, inclined 53 degrees relative to the equator. Using NASA’s Debris Assessment Software (DAS), SpaceX calculated the satellite’s area-to-mass ratio of 0.075. It ultimately took 19 days to reenter.

SpaceX operates an automated collision-avoidance system on the Starlink satellites, which operated nominally during the six-month period.

But there were outages of Space-Track.org conjunction-data messages, which are warnings of collusion risk sent to satellite operators. SpaceX said three incidents of CDM outages lasted between 9 and 24 hours. The company said it experienced a failure in one of its ground services that resulted in a 17-hour outage.

During these periods, SpaceX managed collision risk by using conjunction-data messages from other sources, including commercial provider LeoLabs.

SpaceX reported 100 outages on individual satellites that did not perform risk-mitigation maneuvers.

In 93 of these cases, the conjunction-data message arrived too late to perform the maneuver. Forty-seven of these cases involved non-maneuvering debris or satellites, and 25 occurred “during severe geomagnetic storms [such as on October 11] in which drag rapidly evolved over short time frames.” Another three involved satellites launched into orbits overlapping Starlink orbital shells.

On seven occasions, “non-cooperative” satellites maneuvered only late in the process. Eleven cases involved satellites whose owner-provided ephemerides “with poor predictions that did not reflect risk earlier when leading up to the conjunction.”

SpaceX said the remaining seen events were caused by “several types of degraded hardware-related issues, which prevented satellites from fully reducing collision probabilities.”

Originally published by Space Intel Report on January 10, 2024. Read the original article here.