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Comments to the FCC on Regulation of Space Debris

The Federal Communications Commission (FCC) is seeking comments on economic approaches that might be feasible and effective in reducing the negative impacts of orbital debris in space. We submitted comments offering initial suggestions for what the Commission might consider in choosing a market-based regulation. We also recommend that any impact assessment of the regulation takes into account the full range of direct and indirect benefits.

The Commission raises the ideas of indemnification, bonds, and other liability- and insurance-based requirements. We affirm that such market-based alternatives could help efficiently internalize the effects of orbital debris at the lowest cost. Orbital debris creates a special kind of externality, such that regulations to reduce orbital debris will generate benefits beyond the most straightforward kinds of direct benefits to U.S. space operations. Our comments describe some of the direct and indirect effects that the Commission should weigh when selecting a regulatory alternative. In upcoming reply comments, we will more fully explore ideas for market-based approaches and how to best evaluate their impacts.