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Reply Comments to the FCC on Mitigating Space Debris

The Federal Communications Commission (FCC) called for input on possible market-based approaches to regulating orbital debris, like small but dangerous fragments from the launch, operation, and disintegration of satellites. We previously submitted comments that included an initial discussion of what the FCC might consider in choosing a market-based regulation. Our reply comments expand on this discussion, outlining specific steps the FCC can take to assess implementing a market-based solution.

In our prior comments, advised the FCC that market-based alternatives could help efficiently internalize the global costs of orbital debris. Our reply comments encourage the FCC to evaluate the role that different liability rules, marketable permits or offsets, and regulatory fees could play in achieving its policy goals. We provide information on each alternative and how it might be applied within the context of orbital debris. Our comments also explain how the FCC can best assess the impacts of regulation. Orbital debris creates a special kind of global externality, and the FCC should make sure to account for various direct and indirect benefits that capture the wide-ranging impacts of debris reduction.

Additionally, we submitted our comments to the Department of Commerce, which called for input on best practices for safety standards, traffic management, and other space activity issues.