LEO Satellite Constellations: Why Smart Sharing Rules Matter in Space

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From hosting organization New America:

Please join FCC Commissioners Geoffrey Starks and Nathan Simington, as well as a panel that includes representatives of the two U.S. industry leaders (Amazon’s Project Kuiper and SpaceX’s Starlink) and noted policy experts, to discuss the key regulatory debates that will shape the industry’s future.

Keynote Remarks:

Commissioner Geoffrey Starks
Federal Communications Commission

Commissioner Nathan Simington
Federal Communications Commission

Discussion Panel:

Julie Zoller
Head of Global Regulatory Affairs, Amazon’s Project Kuiper

David Goldman
Senior Director of Satellite Policy, SpaceX

Whitney Lohmeyer
Assistant Professor of Engineering, Olin College of Engineering

Harold Feld
Senior Vice President, Public Knowledge

Spectrum Rights in Outer Space: Interference Management for Mega-constellations

Published at SSRN, August 2, 2022
Authored by: Randall Berry (Northwestern University), Pedro Bustamante (University of Pittsburgh – School of Information Sciences, Students; Carnegie Mellon University), Dongning Guo (Northwestern University), Thomas W. Hazlett (Clemson University), Michael Honig (Northwestern University), Whitney Lohmeyer (Franklin W. Olin College of Engineering), Ilia Murtazashvili (University of Pittsburgh – Graduate School of Public and International Affairs), Scott Palo (University of Colorado), Martin B. H. Weiss (University of Pittsburgh – School of Computing and Information)

Abstract (brief): The rapid increase in low earth orbiting, non-Geostationary (NGSO) communication satellites raises concerns related to the coordination of radio frequency access across competing NGSO systems. Responding to an April 2020 petition by SpaceX, the FCC issued a Notice of Proposed Rulemaking NPRM (FCC 21-123) aimed at updating its NGSO spectrum sharing rules in the relevant frequencies (which involve ten distinct bands between 10 and 51 GHz).2 In this paper, we examine the rights regime proposed by the FCC and, guided by empirical evidence, propose alternatives that may better resolve the challenges confronted. Spectrum policy for satellite systems has been a topic for regulators for several decades, and the new satellite system, radio technologies, and spectrum sharing approaches make the topic ripe for reconsideration. (Cont’d on publication.)

DOI: https://dx.doi.org/10.2139/ssrn.4178793

Jonas Zmuidzinas

A native of Southern California, Jonas Zmuidzinas received his B.S. in physics from Caltech in 1981 and his Ph.D. in physics from UC Berkeley in 1987. He was a postdoctoral fellow at the University of Illinois in 1988-89 and then joined the Caltech faculty as an Assistant Professor of physics in 1990. He became Associate Professor in 1995, Professor in 2000, Merle Kingsley Professor in 2010, and Director of the Caltech Optical Observatories in 2018. Concurrently, he has held positions at NASA’s Jet Propulsion Laboratory (JPL) and has collaborated closely with JPL scientists and technologists, including serving as a JPL Senior Research Scientist (2006-11), Director of the JPL Microdevices Laboratory (2007-2011), and JPL Chief Technologist (2011-16).

His research interests center on astrophysics at millimeter through far-infrared wavelengths, including the development of the technology needed to fully exploit this portion of the spectrum. He has constructed instrumentation for ground-based, airborne, and space telescopes, including invention and development of several types of superconducting detectors and devices as recognized by NASA’s Exceptional Technology Achievement Medal in 2013. He has served as a reviewer and advisor for NASA, NSF, the National Radio Astronomy Observatory, Sandia National Laboratories, other U.S. government agencies and international science agencies, and is author or co-author of over 250 scientific articles.

Rick Reaser

Rick Reaser is an independent consultant on spectrum, satellite navigation, space and electronics technology.  He provides continuing consulting services to U.S.-CREST and a variety of other clients.  In the Spring of 2021, he provided independent consulting services Cerberus Operations and Advisory Company in the performance of technical and market due diligence to assess the viability of an aviation innovation.  He provided independent consulting services to the National Aeronautics and Space Administration (NASA) through the Aerospace Corporation with a systems engineering program assessment of the Artemis program in Spring 2020.

From 2006 to 2019, Mr. Reaser led Raytheon Space and Airborne Systems’ Spectrum Management and Electromagnetic Environmental Effects Department.  He was an Air Force Officer from 1978 to 2006 when he retired as a Colonel. While in the Air Force, Reaser served in the Air Force’s Navstar Global Positioning System (GPS) Joint Program Office (JPO) twelve years across three duty tours as a satellite engineer, satellite contract manager, chief engineer, and deputy system program director.  While serving as the Defense Department’s deputy director of spectrum management, he was detailed by the Deputy Secretary of Defense to the White House and the State Department as a technical advisor to the U.S. Ambassador to the World Radiocommunications Conference (WRC). In the late 1990s he was selected as U.S. spokesperson and leader of the interagency effort to prevent GPS spectrum encroachment. He helped the US and Europe obtain new international spectrum for GPS and Galileo at two World Radio Conferences (2000 and 2003).  He negotiated the technical agreement between the Europe Union (EU) and the United States to share spectrum between the two systems in 2004. He led the design efforts for three new GPS civil signals L1C, L2C and L5 as well the new military signal called M-Code.

Mr. Reaser was appointed by the Secretary of Commerce in January 2009 to the Commerce Spectrum Management Federal Advisory Committee as a Special Government Employee where he served for a decade.  In 2015 he was selected by the National Research Council (NRC) to serve on a Congressionally-directed committee that provided scientific, technical and management recommendations regarding Commerce Department’s telecom labs.

Mr. Reaser is currently serving on a Congressionally-directed National Academies of Sciences, Engineering and Medicine (NASEM) committee reviewing Federal Communications Commission order FCC 20-48, which authorized Ligado Networks LLC to operate a low-power terrestrial radio network adjacent to the Global Positioning System (GPS) frequency band.

Whitney Lohmeyer

Whitney Lohmeyer is an Assistant Professor of Engineering at Olin College and a Research Affiliate at MIT in Aeronautics and Astronautics. She leads the Olin Satellite + Spectrum Technology & Policy (OSSTP) Group, and manages and contributes to the field of satellite communications systems. She also works closely with industry to advise on end-to-end system design, antenna systems, RF power amplification, radiation tolerance and spectrum strategy. Whitney is passionate about enabling affordable Internet access in order to generate economic growth and improve healthcare and education. Whitney was the first engineer hired at OneWeb, a company launching hundreds of low earth orbit communications satellites to provide global broadband and bridge the digital divide. While at OneWeb, she held a variety of roles both technical and policy-focused. As a Systems Engineer, she designed the RF Link Budget, and worked on the end-to-end communications system design, focusing on the LTE waveform and the user terminal antenna. In addition, she actively contributed to policy reform at the United States Federal Communications Commission (FCC) and United Nations (UN) International Telecommunications Union (ITU), and represented OneWeb on the U.S. Delegation to the 2015 World Radio Conference, the culmination of a three-year regulatory review cycle. Prior to joining the OneWeb team, she worked as a hardware engineer at Google, and spent time in technical roles at Inmarsat and NASA. Whitney received her Ph.D. in Aeronautics and Astronautics from MIT in 2015, and her M.S. in Aeronautics and Astronautics from MIT in 2013, both funded by a National Science Foundation (NSF) Graduate Research Fellowship. She earned her B.S. in Aerospace Engineering from NC State University in 2011, as the only female in her class of approximately ninety students, and now currently serves on the board of North Carolina State University’s Mechanical and Aerospace Engineering (MAE) Department. She has been invited to speak at a variety of events including NC State’s 2018 MAE Commencement Ceremony, the UN Women’s Gender Equality and Mainstreaming (GEM) The Internet of Women: Challenge or Opportunity? and the UN’s and ITU’s Women’s Leadership Workshop on Empowering Women in Radiocommunications Negotiations.


  • Satellite Communications
  • Wireless Communications
  • Satellite Systems
  • International Spectrum Policy
  • Principles of Wireless Communications

Frank Lind

I was born near Portland, Oregon. After attending high school in Seattle, I studied at the University of Washington, where I received a Bachelor of Science degree in Physics and a Bachelor of Science degree in Computer Science in 1994. I then joined the UW Geophysics Program and pursued studies leading to the Doctor of Philosophy in Geophysics in 1999. My work there focused on passive radar observations of the aurora borealis. Currently, I am a Research Engineer at MIT Haystack Observatory, where I develop and operate ground- and space-based radio science instrumentation.

My research focuses on radio science, advanced radar and radio arrays, space plasma physics, software radar, novel sensors and signal processing, and satellite instrumentation.

Keith Gremban

Data and Machine Learning Project Team Lead

Focus Area:

Remote Sensing, Earth & Space Science


PhD, Computer Science, Carnegie Mellon University
MS, Computer Science, Carnegie Mellon University
MS, Applied Mathematics, Michigan State University
BS, Mathematics, Michigan State University

Professional Experience:

2020 – Present, Program Manager, 5G-to-NextG Initiative, Office of the Undersecretary of Defense for Research and Engineering, US Department of Defense
2020 – Present, Research Professor, Aerospace Engineering Sciences, University of Colorado Boulder
2020 – Present, Senior Fellow, Silicon Flatirons Center, University of Colorado Boulder
2019 – 2020, Research Professor, Technology, Cybersecurity, and Policy Program, University of Colorado Boulder
2015 – 2019, Director, Institute for Telecommunication Sciences, National Telecommunications and Information Administration
2014 – 2015, Founder, Shavano Systems LLC
2011 – 2014, Program Manager, Strategic Technologies Office, Defense Advanced Research Projects Agency (DARPA)
2009 – 2010, Director, Computer Systems Research, SET Corporation, a Science Applications International Corporation Company
2007 – 2009, Director, Denver Advanced Technology Division, SET Corporation, a Science Applications International Corporation Company
2006 – 2007, Assistant Vice President and Division Manager, Science Applications International Corporation
2002 – 2006, Senior Scientist, Science Applications International Corporation
1998 – 2002, Senior Research Engineer, SRI International, Englewood, CO
1997 – 1998, Senior Systems Engineer, Computing Devices International (CDInt)
1995 – 1998, Senior Scientist, CTA Incorporated
1988 – 1995, Graduate Student and Research Assistant, School of Computer Science, Carnegie Mellon University
1980 – 1988, Staff Engineer, Martin Marietta Corporation

Awards (Selected):

Senior Fellow, Silicon Flatirons Center, University of Colorado Wolf School of Law

Research Interests:

RF noise measurement and analysis
Spectrum monitoring
Spectrum sharing
Internet of Things

Phil Erickson

I am an associate director at Haystack (2020; previously assistant director from 2015), Principal Research Scientist at MIT, and I also lead Haystack’s very productive Atmospheric and Geospace Sciences Group.  I conduct fundamental research on the near-Earth space environment, primarily through radio-based experiments and data analysis using a variety of remote sensing techniques involving ground- and space-based data.

I am the lead principal investigator for the community-oriented Millstone Hill Geospace Facility (MHGF), a prime North American space science observatory sponsored by the National Science Foundation for mid-latitude ionospheric remote sensing and scientific analysis.

Recently, the Group has initiated direct measurements from low Earth orbit for ionospheric physics.  I am the principal investigator for the forthcoming Auroral Emission Radio Observer (AERO), a NASA Heliophysics funded small satellite mission led by MIT Haystack.  I am also a co-investigator on the Haystack-led and simultaneously launched NASA Vector Interferometry Space Technology using AERO (VISTA) small satellite mission.

I am a co-director of the education and public outreach efforts at MIT Haystack, spanning undergraduate research programs, graduate student interactions including graduate student committee membership, K-12 classroom units and outreach, and public Observatory tours and lectures.

I am an active member of the HamSCI collective for amateur-professional activities and research, engaging the 750,000+ amateur radio operators in the United States for fundamental ionospheric citizen science. This includes active amateur radio participation (call sign W1PJE).

I serve as a journal reviewer, public lecturer, workshop session convener (CEDAR, GEM, AGU Space Physics and Aeronomy), and member of various space science committees. These include the Committee on Radio Frequencies (CORF), convened by the National Academies of Science, Engineering, and Medicine (NAS) Board on Physics and Astronomy. CORF considers the needs for radio frequency requirements and interference protection for scientific and engineering research, and coordinates the views of U.S. scientists. In general, CORF acts as an important channel for representing the interests of U.S. scientists in Earth science and radio astronomy passive and active remote sensing matters.

My training in ionospheric physics and Thomson/incoherent scatter radar theory and practice (B.S. 1987; Ph.D., 1998) came from the seminal Space Plasma Physics group within Electrical Engineering at Cornell University, where my principal advisors and mentors were Donald T. Farley, Michael C. Kelley, and Wesley E. Swartz. I have been a Haystack staff member since 1995.

I grew up in Schenectady, NY, home of General Electric’s seminal Research and Development Laboratory, where both my mother and father worked (microbiology and metallurgy, respectively) and where the great Irving Langmuir, coiner of the word “plasma” for 99% of the known universe, conducted research. I live in central Massachusetts with many hobbies including music, photography, history of technology, and keeping up with my son James and art historian wife Sarah.