On Friday, TechFreedom submitted comments in response to the White House’s Office of Science and Technology Policy’s (OSTP) Request for Comment on the Orbital Debris Strategic Plan, first published in January, 2021. In these comments, TechFreedom explains why the Plan is far too narrow in scope and addresses only technical research areas, instead of addressing the critical legal and policy issues surrounding space sustainability.

“‘Policy’ is in OSTP’s name, yet this Plan is just a wish list for more government research programs,” said James E. Dunstan, TechFreedom’s General Counsel. “This ‘stovepiped’ approach to finding technical solutions to increased orbital debris ignores the critical big picture issues that this administration must address.”

“First and foremost, we must stop ASATs,” Dunstan continued. “The data clearly show that the largest jumps in orbital debris come not from the introduction of more operational satellites, but rather from collisions. The worst of those come from anti-satellite weapon (ASAT) tests. Just last month we saw Russia blow up one of its satellites while testing an ASAT, producing thousands of pieces of new debris. Until we get serious about outlawing ASATs, other efforts on space sustainability are useless.”

“The Strategic Plan also envisions a ‘top-down,’ governmentally run approach to combating orbital debris, which will be prohibitively expensive,” Dunstan concluded. “Unless we harness private sector innovation and the reductions in costs pioneered by companies like SpaceX, it will continue to be cheaper to just ignore the problem and hope it goes away, as we have for half a century. Instead, OSTP should leverage these advances through commercial programs to further Active Debris Removal (ADR) technologies.”


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