An Initial Conversation: Orbital Data Centers & Space Sustainability Implications
The Secure World Foundation (SWF) convened a panel discussion on the space safety, sustainability, and policy implications of orbital data centers (ODCs), bringing together perspectives from government, industry, and the technical community. The session was moderated by SWF’s Alex Shi, Senior Program Analyst for Space Safety, and the panelists were:
- Ronald Birk, Principal Director, Space Enterprise Evolution Directorate, The Aerospace Corporation
- Matias Cava, National Space Policy Lead, Policy, Advocacy, and International Division, Office of Space Commerce (OSC), U.S. Department of Commerce
- Ezra Feilden, Co-founder and Chief Technology Officer, Starcloud (virtual)
- Jeff O’Neil, Director of Government Affairs, Planet Labs
This discussion took place amid a rapid increase in proposed ODC systems worldwide, including multiple applications by U.S.-based entities to the Federal Communications Commission (FCC), ranging from tens of thousands to as many as one million satellites. These systems would, if fully deployed, multiply the current total of operating satellites several times over. If this level of activity comes to fruition, it would not be merely an incremental expansion of existing low Earth orbit (LEO) operations; rather, it raises novel technical, environmental, and governance considerations. ODCs are being proposed primarily to support AI and other compute-intensive applications. But deploying them at scale without adequate frameworks and safeguards in place could threaten the stability of the orbital environment required for them to function. The panel focused on the central policy question of: As this potentially transformative space activity develops, how can space policy and safety measures help maintain a stable orbital environment while continuing to foster innovation?
Key Takeaways
- The proposed scale of ODCs represents a qualitative change in LEO operations
A recurring theme was that existing space safety and licensing approaches cannot simply be extrapolated indefinitely as satellite populations increase. ODC proposals could introduce tens or hundreds of thousands of additional spacecraft — many times the number of operational spacecraft today — and significantly increase the operational risk and complexity of parts of LEO. Ronald Birk emphasized the need to move beyond assessing individual spacecraft or even individual constellations and instead consider the interaction of the “set of constellations” and the evolution of the broader space ecosystem.
This suggests that traditional spacecraft-by-spacecraft or license-by-license assessments may become increasingly inadequate. The relevant unit of analysis for very large constellations may need to include cumulative collision risk, shared orbital capacity, traffic interactions, and the collective effect of multiple systems operating in the same environment.
- In managing conjunction risks, individual constellation design cannot substitute for coordination across operators.
The discussion highlighted that constellation design can help manage conjunction risk within individual systems, such that the number of conjunctions does not simply scale with satellite population as a simple extrapolation from current constellation architectures. Starcloud, for example, envisages operating in dawn-dusk sun-synchronous orbits (SSOs) designed to minimize intersections between orbital planes. Such architectures could accommodate larger satellite populations without collision risk increasing as rapidly as a simple extrapolation from today’s constellation designs might suggest.
However, the challenge becomes more complex when multiple operators use the same orbital regions. One consideration is the concurrent use of dawn-dusk and dusk-dawn SSO configurations, which could result in satellites travelling along closely overlapping trajectories in opposite directions and create a large number of high-relative-velocity conjunctions. At very large scales, therefore, safe operations increasingly depend not only on how individual systems are designed, but also on effective coordination and common operational conventions across operators.
- Need to develop “rules of the road” before ODC deployment reaches scale.
There was broad agreement that government regulation will not necessarily develop quickly enough to resolve every emerging operational issue. Matias Cava therefore encouraged operators not to wait for formal requirements, but to develop and follow responsible practices now, including by asking how they would want competing operators to behave in the same environment.
Jeff O’Neil viewed this as an opportunity for U.S. leadership. Drawing an analogy to the development of global air traffic control standards, he posited that the United States could help develop workable approaches for coordination of large constellations early — through collaboration between government and industry, and with input from the international community — and then support their wider adoption and interoperability globally.
These comments support a layered governance model in which regulation establishes minimum requirements, while operator-developed practices address rapidly evolving operational questions. Potential areas include conjunction response, maneuver coordination, information sharing, orbital-direction conventions, deployment practices, and end-of-life operations.
- SSA and conjunction-management practices must evolve with the scale of operations.
The discussion also underscored the importance of reliable space situational awareness (SSA) and direct coordination between operators. Jeff O’Neil highlighted both continued international cooperation on SSA data sharing and the development of rules that facilitate operator-to-operator communication.
At very large constellation scales, simply producing more conjunction data will not necessarily be sufficient. In addition, simply scaling today’s conjunction-management practices to orbital populations approaching a million spacecraft could create an impractically large number of collision-avoidance maneuvers. Coordination mechanisms will therefore need to provide operators with timely, actionable information and clearly understood processes for operator-to-operator communication and coordination when conjunctions arise. This reinforces the importance of initiatives such as the Traffic Coordination System for Space (TraCSS), OSC’s civil SSA system that provides basic SSA data and services to operators, while also highlighting that international and commercial information-sharing arrangements will remain necessary alongside U.S. civil SSA capabilities.
- ODCs expose current gaps in regulatory responsibility for novel in-space activities.
ODCs do not currently fit neatly within the traditional division of U.S. regulatory responsibilities among launch and re-entry, spectrum, and remote sensing authorities. The panel therefore discussed the OSC’s proposed Space Commerce Certification as one approach to providing a more coordinated pathway for novel in-space activities.
The broader point was that streamlining and regulatory clarity need to be accompanied by mechanisms capable of considering system-level safety and sustainability questions. These issues frequently span the responsibilities and expertise of several agencies. Since the event, the OSC has moved forward to issue a pilot phase of the Space Commerce Certification framework, explicitly identifying orbital computing and ODCs among the activities it is intended to address.
- Sustainability considerations extend beyond collision avoidance.
The discussion highlighted that the sustainability implications of ODCs extend beyond managing conjunctions between active spacecraft. One issue is long-term access to high-demand orbital regions. Matias Cava discussed the tension between accommodating concrete proposals from operators seeking access today and preserving opportunities for operators and uses that may emerge in the future. At the scale proposed for some ODC systems, decisions about the use of particular orbital regimes could therefore have implications well beyond the individual constellation, raising broader questions about how access to shared orbital resources should be managed over time.
The panel also considered whether established approaches to post-mission disposal remain sufficient at ODC scale. Ezra Feilden pointed to industry standard practices of leading large-constellation operators, particularly those demonstrated by Starlink, as useful benchmarks for collision avoidance, launch operations, and end-of-life disposal. Ronald Birk caveated that the systems today were nevertheless not designed for the volume, attributes, and characteristics of ODC-scale constellations — with a million spacecraft, the hundreds of thousands of annual collision avoidance maneuvers today could scale to half a billion. Another point to consider is how reliably operational safety practices would need to be: even very high disposal success rates could leave a significant absolute number of spacecraft in orbit, in the range of tens of thousands of satellites.
Finally, the discussion considered the atmospheric consequences of disposal by re-entry. While successful re-entry removes spacecraft from the orbital environment and prevents their long-term accumulation as debris, very large constellations could also result in correspondingly large quantities of spacecraft material re-entering and ablating in the atmosphere. The environmental effects of such activity remain an active area of research, making it difficult to determine what levels of mass re-entry would be sustainable at the scales contemplated for ODCs. The panel mentioned a recently announced initiative by Astroscale and Planet to encourage industry data-sharing on spacecraft materials.
Overall, the multitude of considerations discussed underscored that sustainability at ODC scale cannot be assessed solely through collision avoidance or compliance with existing debris-mitigation requirements. It also requires consideration of long-term orbital access, the aggregate performance of disposal systems, and the environmental consequences of how very large satellite populations are removed from orbit.
Summary of Insights and Implications
The panel highlighted several broader lessons for future policy development.
First, scale changes the nature of the constellation governance problem. Requirements and practices that have worked well for hundreds or thousands of satellites may not be adequate at the scale of the ODCs proposed.
Second, environment-level assessment will become increasingly important. Collision risk, orbital access, SSA requirements, disposal impacts, and coordination burdens can arise from interactions between systems and compound across the orbital environment. These effects cannot always be understood or addressed by assessing individual satellites or constellations in isolation.
Third, technical and governance solutions are interdependent. Good constellation design can reduce some operational risk, but its effectiveness may also depend on other operators following compatible practices. Technical standards, operational norms, information-sharing arrangements, and coordination mechanisms therefore need to evolve alongside spacecraft and constellation design.
Returning to the central policy question, the discussion suggested that maintaining a stable orbital environment while enabling ODC innovation would require policy and safety frameworks to evolve with the scale and characteristics of the activity. This means moving beyond spacecraft-level requirements where possible, accounting for cumulative and cross-system effects, and establishing common operational practices and coordination mechanisms across operators.
While ODCs remain at an early stage of development, there seems to be an appetite among both industry and regulators to move quickly, driven at least in part by perceived commercial and geopolitical competition. There is thus a narrow window of opportunity to put these policy elements in place before deployment reaches the scales currently being proposed. Governments, operators, and the wider space community should prioritize the development of common safety metrics, operational practices, and regulatory approaches before large-scale deployment creates difficult-to-reverse operating patterns, regulatory precedents, or cumulative impacts on the orbital environment.
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