Remarks By Michael Morgan, NOAA Assistant Secretary for Environmental Observation and Prediction At SmallSat 2023

Today Dr. Michael Morgan, NOAA Assistant Secretary for Environmental Observation and Prediction, delivered the Tuesday keynote speech at the SmallSat Symposium in Mountain View, California. Below are his remarks as prepared for delivery.

Good morning. It is a pleasure to be here in Silicon Valley to see and hear about all the exciting technological and business developments that are paving the way to our future in space.

I am representing the National Oceanic and Atmospheric Administration, or NOAA, part of the U.S. Department of Commerce. NOAA is an agency that enriches life through science. Our reach goes from the surface of the sun to the depths of the ocean floor as we work to keep the public informed of the changing environment around them. From daily weather forecasts, severe storm warnings, and climate monitoring to fisheries management, coastal restoration and supporting marine commerce, NOAA’s products and services support economic vitality and affect more than one-third of America’s gross domestic product.

As Assistant Secretary of Commerce for Environmental Observation and Prediction, I am responsible for providing agency-wide direction with regard to weather, water, climate, and ocean observations, including in situ instruments and satellites, and the process of converting observations to predictions for environmental threats.

My portfolio includes the Office of Space Commerce, whose mission is to foster the conditions for the economic growth and technological advancement of the U.S. commercial space industry. That office is responsible for coordinating space commerce related activities across the entire Department of Commerce, not just NOAA.

Strategic Objective 1.7

I’m sure this audience will be happy to hear that Secretary Gina Raimondo’s strategic plan for the Department of Commerce, issued last March, includes a strategic objective to “Advance U.S. leadership in the global commercial space industry.” As a result, NOAA and all the other bureaus of our Department are now engaging in efforts to promote this objective – 

• Publishing annual statistics on the growth of the American space economy [Bureau of Economic Analysis or BEA];
• Assessing the health of our space industrial base [Bureau of Industry and Security or BIS];
• Promoting minority business participation in our space supply chains [Minority Business Development agency or MBDA];
• Promoting cybersecurity for space systems [National Institutes of Standards and Technology or NIST];
• Analyzing patent trends related to space commerce [U.S. Patent and Trademark Office or USPTO];

…to name just a few.

The Office of Space Commerce is working to coordinate all these diverse efforts to apply the Department’s full range of tools and resources towards the promotion of American space commerce. We have established a new Commercial Space Coordination Committee, affectionately known as the CSCC or “sea-sick,” inside the Commerce Department. It is chaired by our Deputy Secretary, Don Graves, who is very engaged in this area.

Commerce’s strategic objective on space commerce aligns very closely with the U.S. Space Priorities Framework issued by Vice President Harris’s National Space Council. Both emphasize using space-based Earth observations to support action on climate change, fostering a policy and regulatory environment that promotes U.S. commercial space competitiveness, and improving space safety and sustainability.

Today, I will talk about both NOAA’s use of small satellites for weather and climate observation, and NOAA’s support for the smallsat industry through the Office of Space Commerce.

Weather and Climate Observations

Climate Ready Nation

Consider this:

• Two decades ago, for the 6-year period 1997-2002, there were about five billion-dollar disasters per year;
• For the period 2007-2012, there were 10 per year;
• 2017-2022 – about 17 per year.

Where we live, how we build, and how the climate is changing are affecting the location and intensity of extreme events.

At NOAA we are helping to build a Climate-Ready Nation, where “the Nation’s prosperity, health, security, and continued growth benefit from and depend upon a shared understanding of, and collective action to reduce, the impacts of climate change.”

What are the hallmarks of a Climate-Ready Nation?

Well one hallmark is that: The public and decision makers have equitable access to the climate information, products, and services they need, and a clear understanding of what this information means for their communities, economies, natural resources, and the built environment.

Another is that: The public and decision makers are empowered to take a range of adaptation and mitigation actions at the scales needed to systematically prevent or reduce the negative impacts of climate change, by utilizing socioeconomic, ecological, and other relevant information to build resilience, while considering trade offs of different pathways. 

NOAA will build toward a Climate Ready Nation by expanding its work with existing and new partners to equitably meet the needs of communities and businesses facing hazardous weather events and long-term climate impacts. 

NOAA is doing a great deal to translate our long term climate observations, research, and modeling projections  into decision support services and to go that last mile to get useful information into the hands of users.  

Fundamental to this effort are the observations that underpin NOAA’s science and services.

Future NOAA Satellite Architecture

To collect observations for weather forecasting and climate monitoring, NOAA flies the nation’s fleet of operational, civilian satellites. These include the GOES-R series of geostationary satellites and the JPSS satellites flown in polar orbits. Those are clearly not smallsats by any stretch of the imagination. They are evolutions of legacy spacecraft that have high capability but no risk tolerance, have decade-plus long development schedules, little flexibility to adopt new technology, and correspondingly high costs.

In the last few years, we have been reimagining what our future satellite architecture could look like if we broke from the paradigm of big government satellites and embraced the disaggregated, proliferated LEO model for certain observations. We have written specific guidance into our agency-level strategic plan to “Innovate space-based observations” and to “Expand Commercial partnership and new technology,” including “innovative small modular satellite technology.” We have been engaging with the community and issued study contracts to develop a more advanced and agile LEO architecture that will make technology, platform, and business model innovations operational on more rapid timescales. We are building in on-ramps for new technology and opening the door to more data purchases, rideshares, and hosted payloads.

QuickSounder

As a pathfinder demonstration towards a potentially disaggregated LEO constellation, we are developing the QuickSounder mission. This mission will function as a proof of concept for a potential future LEO smallsat constellation. QuickSounder will carry a microwave sounder to measure vertical temperature and moisture profiles, which heavily influence weather patterns, in order to feed the National Weather Service’s weather prediction models. (This has a direct effect on the everyday lives of every American/person around the world.)

For QuickSounder, NOAA will utilize an existing proven microwave sounder, the engineering design unit for the ATMS instrument currently flown on JPSS. But the instrument is not what’s important here – it’s the architecture, and the test of our ability to quickly react to an on-orbit need. What we are pathfinding is NOAA’s ability to purchase and develop small form factor satellite buses, and also to procure small launch services in a timeframe that was previously impossible. NOAA has traditionally used NASA as its procurement agent for satellites and launch services. We will continue to work with NASA, while also embracing a more commercial space industry approach. We plan to couple sensitive instruments with private industry’s commercial best practices to streamline development and schedule. We will be breaking new ground here, so we need to learn as we go. 

The QuickSounder mission passed its Milestone 2, the authority to proceed, in December 2022, and the Deputy Secretary of Commerce has given his green light for this smallsat program to go forward and launch in 3 years. In addition, we are moving out on a phase A development effort to develop the next generation microwave sounder for future missions after QuickSounder.

To be clear, QuickSounder is one small satellite in LEO. If it is successful, then the next step is to develop a group of LEO smallsats (modeled after the QuickSounder paradigm) and test how that goes. Ultimately, if all goes well, we could potentially replace large multi-instrument satellites like JPSS for some of NOAA’s core observations.

COSMIC-2

Long before we started to rethink our satellite architecture, NOAA was already working with smallsats. For example, NOAA collaborates closely with Taiwan on the operation of a six-smallsat constellation known as COSMIC-2 [Constellation Observing System for Meteorology, Ionosphere, and Climate-2].

Declared fully operational in 2021, COSMIC-2 uses the GNSS radio occultation technique to provide data on the temperature, pressure, and water vapor content of the atmosphere. COSMIC-2 contributes to a 6-8% error reduction of the total forecast improvement impact.

As its name implies, COSMIC-2 is a follow-on to the original COSMIC constellation that flew from 2006 to 2020. That was the mission that really proved the value of radio occultation data to NOAA’s weather forecasting models.

Commercial Weather Data Pilot – GNSS Radio Occultation

In 2016, at the same time that NOAA was planning COSMIC-2, we released our first Commercial Space Policy, which set a broad framework for the use of commercial satellite data and services as a complement to government owned systems like COSMIC. A few months later, with support from Congress, we issued contracts for our first radio occultation (RO) data buys. These were not for operational use, but for testing and validation purposes under what we call a Commercial Weather Data Pilot.

We ended up conducting two data pilots involving RO satellite data before concluding that commercial smallsats could meet government requirements for RO data in terms of usability and interoperability. As part of this effort, we used our newly developed cloud-based data ingest system to enable the secure ingest of external data into our operational forecasting models, which are critical to public safety.

Commercial Data Purchase – RO Data Buy IDIQ-1

In 2020, we awarded our first contracts to purchase RO data for use in operational weather forecasts. Smallsat operators GeoOptics and Spire Global received Indefinite Delivery, Indefinite Quantity contracts with a total contract ceiling of $23 million. Over the two-year span of the contracts, we awarded five sequential data delivery orders to one or both of the companies. In May 2021, we officially began using commercial RO data in our operational weather forecasts. In February 2022, we published a cost-benefit analysis confirming that data purchased under the contracts were similar in quality to that of governmental RO sensors, but at a reduced cost per occultation. The impacts on the forecasts were – as anticipated for a new and relatively low-volume data source – neutral to slightly positive.

One of the most notable features of the commercial data contracts is that they provided options to choose from various levels of data distribution rights with commensurate pricing. When smallsat companies first pitched their RO offerings to NOAA, they proposed a business model where they would sell the same data to multiple weather agencies around the world and charge each one a fraction of the cost to collect it. Who wouldn’t want to get satellite data at 1/10 the cost of building, launching, owning, and operating a whole satellite system?

As it turns out, that business model only works if weather agencies cannot share the commercially purchased data with each other. That may work for a local forecasting situation, but not for global modeling. NOAA routinely shares huge amounts of meteorological data with its international partners and receives their data in return, free of charge, consistent with international conventions and federal open data directives. We also share our data with other federal agencies and academia, who depend on free access to our data as they research ways to improve our weather and climate models.

Recognizing this, we structured our radio occultation contracts with nine optional levels of data distribution rights. These range from no distribution beyond NOAA, to distribution within the government, all the way up to a global license with unlimited distribution rights. Obviously, a global license costs the most, but we had the vendors price it out for us — knowing there were competing bids, so they couldn’t just ask for the Moon.

Over the two-year course of the IDIQ, we gradually increased the level of rights attached to the data we purchased. Our initial delivery orders were relatively small, intended for testing and development of our systems, and allowed distribution within the U.S. government only. Then we added the ability to share the near-real-time data with international weather bureaus, with no restrictions after the data is 24-hours old. 

Our fifth and final delivery order under this contract began in January of this year and reached the top of the nine levels – a global license. These near-real-time data are now available with no restrictions whatsoever. NOAA’s implementation of no-restrictions data sharing brings the Commercial Data Program into alignment with NOAA’s general policy for satellite observations.

That fifth delivery order went to Spire Global for a total of 3,300 RO profiles per day, for six months beginning on January 18, 2023. So, right now, anyone in the world can freely access the commercial RO data we are buying from Spire — in near-real-time with no 24-hour delay. You can use it not only for scientific purposes, but also in commercial applications. If you are a developer seeking new weather data sources to integrate into your commercial app or model, I encourage you to look into this. Your taxpayer dollars already paid for the data, so you might as well go ahead and take advantage of it. By the way, 3,300 profiles per day is only a subset of Spire’s full output, so they have capacity to continue to market to U.S. and international partners.

Commercial Data Purchase – RO Data Buy IDIQ-2

I mentioned that this was the final delivery order under the contract, but we are already in the process of establishing the follow-on contracts for RO data. We issued a request for proposals in July 2022 and expect contract awards to occur in the second quarter of calendar year 2023. This contract will reflect lessons learned from our first contracts: the period of performance has been extended to five years, but it will include on-ramps to qualify new vendors on an annual basis. It will refine the data rights provisions to reduce uncertainty and ambiguity. It will also reduce the data sharing options from 9 to 5. Our goal is to buy at least 20,000 RO profiles per day — which is a lot more than the 3,300 per day we’re currently getting. No guarantees on the data rights, but I have a feeling it will be difficult to dial them back once our partners get used to receiving near-real-time Spire data for free.

Commercial Weather Data Pilot – Space Weather

Based on the success of our atmospheric RO data pilots and operational buys, we continue to pulse the commercial community for capabilities that might meet other NOAA observational requirements. As a result of this market research, in July 2022, we awarded three new Commercial Weather Data Pilot contracts for the testing of space weather data. These went to smallsat operators GeoOptics, PlanetiQ, and Spire Global, although one was terminated early. These commercial data will provide insight into near-real-time ionospheric conditions that can impact a wide range of activities, including aviation, satellite operations, navigation, and communications.

The space weather data pilots are expected to last about 12 months. Upon completion and evaluation, successful pilot studies may lead to sustained commercial data purchases to support our operational forecasting endeavors.

General RFI for Future Pilots

In September 2022, we again issued a general Request for Information for any other existing or planned environmental satellite data and related capabilities that will be commercially available in the timeframe of fiscal years 2023 to 2030. This was the third in a series of general RFIs we have issued since 2018 to stay up to date on what is out there that might meet our diverse mission objectives. The RFI asked about commercial space services that could augment NOAA’s capabilities to observe: the atmosphere; cryosphere; land and surface hydrology; oceans, freshwater, and coasts; and space. We are currently evaluating the responses to inform a potential Commercial Weather Data Pilot project for terrestrial weather applications, as well as future pilots for space weather and other applications.

CRADA with tomorrow.io

One last initiative I would like to mention is our recent CRADA with tomorrow.io, a weather satellite startup. Tomorrow.io is developing commercial satellite-based radar instruments that will measure rainfall globally with high resolution, and possibly other important geophysical parameters like ocean surface winds, sea-ice fraction and snow cover.  NOAA has a keen interest in getting improved measurements of all these parameters. As such, we recently entered into a cooperative research and development agreement (CRADA) with the company in which they agreed to provide NOAA access to their data and models at no cost. In exchange, NOAA experts will use the government’s systems to assess the utility of, and provide feedback on, the company’s data. If successful, NOAA may be interested in obtaining such data operationally to complement our portfolio of observations. If any of you are interested in exploring a collaborative, but no-exchange of funds, partnership with NOAA, I would encourage you to talk to us about the possibilities provided by CRADAs.

Commercial Data Program – A Policy Success

As you can see, we have a very active Commercial Data Program consisting of both Commercial Weather Data Pilots and operational data buys. We have successfully engaged the commercial sector through a competitive process and acquired operational satellite data-as-a-service. Commercial RO data constitutes an important addition to NOAA’s portfolio that will help improve weather forecasts and provide risk reduction to the overall observing system.

Our Commercial Data Program is fostering the development of robust, commercial market ecosystems involving multiple vendors and customers. Even if one vendor fails or can’t deliver — which has already happened to us — we can turn to others to fill the gap. Beyond the direct benefits to NOAA, there are broader economic benefits as new market segments create American jobs and revenue. 

Much of this success is the result of groundwork laid by a National Space Policy issued over a decade ago. Among other things, that policy directed the U.S. government to:

• Purchase and use commercial space services to the maximum practical extent;
• Actively explore the use of nontraditional arrangements for acquiring commercial space goods and services, including data buys;
• Develop governmental space systems only when it is in the national interest and there is no suitable, cost-effective commercial service available;
• Refrain from conducting activities that preclude, discourage, or compete with U.S. commercial space activities; and 
• Transfer routine, operational space functions to the commercial space sector. 

Office of Space Commerce 

Policy Advocacy Role

Much of that policy direction originated with NOAA’s Office of Space Commerce, whose role is to support the commercialization of space and the growth of the U.S. commercial space industry as a means of promoting innovation, jobs, and economic prosperity. Let me now talk about this important office, which serves as your industry’s voice within the federal government on policy and regulatory matters.

Just a couple months ago, under the leadership of its director Richard DalBello, the Office of Space Commerce was reorganized to become part of the Office of the Under Secretary of NOAA. Originally, the Office of Space Commerce was purely a policy organization, advocating for commercial space industry interests within deliberations of national space policies, space-related rulemakings, and international agreements. The Office contributed to efforts such as the promotion of GPS as a worldwide standard, the removal of commercial communication satellites from the U.S. Munitions List of ITAR [International Traffic in Arms Regulations], and the development and implementation of NOAA’s Commercial Space Policy.

Operational Role – SSA

But in 2018, the Office was assigned a new, operational responsibility: to provide space situational awareness data and warnings to commercial space operators as Earth’s orbits become increasingly congested with traffic and debris. This is a huge mission area that is driving up the Office’s resource requirements by orders of magnitude. With support from Congress, including $70 million appropriated for FY 2023, the new organizational structure supports the Office’s expansion into this operational role.

Regulatory Role – CRSRA

Furthermore, the Office of Space Commerce has been given a third role to play in the space industry, and that is a regulatory one. NOAA reorganized its Commercial Remote Sensing Regulatory Affairs office to become a division of the Office of Space Commerce. So now, instead of just helping shape the regulations affecting commercial remote sensing satellites, the Office is responsible for issuing the actual licenses to the operators of those satellites, and monitoring their compliance. 

At this point, I would be remiss not to give a public service announcement about NOAA’s licensing requirements. If you are a U.S. entity planning to operate a private spacecraft with an imager on it, please know that you must comply with NOAA’s regulations. The government has certain national security concerns when it comes to satellite imagery, and these must be considered before authorizing space systems capable of imaging Earth. 

Having said that, not all imagers in space need a license. In some cases, imagers used primarily for mission assurance purposes may be totally exempt from NOAA licensing. 

For those needing a license, thanks to a 2020 rewrite of our rules, the vast majority of imagers may only need simple licenses, with minimal conditions. To promote transparency, most of the license conditions are identified in the governing regulations. Only the most advanced, novel imagers are potentially subject to additional operating conditions based on national security, and even those conditions are time-limited. 

I encourage you to review the NOAA rules on commercial remote sensing and to fill out an initial contact form to request a determination on whether a license is necessary for your proposed system. The form is for informational purposes only and is considered non-binding. Your information is considered to be proprietary and is only shared with trusted government agencies. 

I am proud to say that NOAA’s licensing of commercial remote sensing space systems has improved in terms of speed and efficiency. In 2022, the average time to process a new license application was 22 days, a 20% improvement over the previous year. Today, we oversee 92 licenses held by 70 licensees for 1,215 satellites. 415 of those are currently on orbit.

Regulatory Role – Mission Authorization

So that is the current regulatory role of the Office of Space Commerce – but there is an active conversation in Washington over whether this should be expanded beyond remote sensing operations. You may recall that Vice President Harris was here in Silicon Valley last August with members of the National Space Council. At that time, she announced the Administration’s ongoing work to develop a framework to replace outdated space rules, replacing them with a new rules framework that keeps pace with the pace of private sector innovation – in part to ensure they are conducted safely, efficiently, and sustainably. NOAA is actively engaged and strongly supportive of this process. We stand ready to support the best possible oversight of new commercial space activities in a way that promotes competitiveness and increases legal certainty for U.S. businesses.

As stated in the U.S. Space Priorities Framework, which is this Administration’s guiding document on space policy, “U.S. regulations must provide clarity and certainty for the authorization and continuing supervision of non-governmental space activities, including for novel activities such as on-orbit servicing, orbital debris removal, space-based manufacturing, commercial human spaceflight, and recovery and use of space resources.”

NOAA and the Department of Commerce view space mission authorization as critical to promoting competitiveness and increasing legal certainty for U.S. commercial space businesses. Through the Office of Space Commerce, we already play an important role in licensing commercial remote sensing satellites. Our regulatory approach is highly effective in promoting U.S. commercial leadership in space while protecting public interests. 

Space Situational Awareness

Speaking of public interests, NOAA is putting an extraordinary amount of effort into the space situational awareness program I mentioned a few minutes ago. SSA is absolutely essential to the preservation of the space environment for all humankind – whether for commercial, civilian, or national security uses. Flying a spacecraft without some type of SSA capability is like driving at night with no headlights. It’s not just risky for your mission, it’s irresponsible and threatens to worsen an already perilous orbital debris situation.

This is particularly true in low Earth orbit – the most congested zone of space – and even more so when we talk about smallsats with limited or no propulsion for maneuvers.

Today, the U.S. government provides SSA support to commercial and civilian operators through the Department of Defense using sensors from their Space Surveillance Network. Their system was designed to provide space domain awareness for warfighters, not customer support to commercial businesses. While I have not tried to use it myself, I am told it is not the most user-friendly system. 

Five years ago, the White House directed DoD to transfer its public SSA support functions to the Department of Commerce, which is better positioned to support industry needs, so that DoD can focus its resources on its national security mission.

Since that time, the space traffic problem has only intensified, with the number of active satellites more than tripling, and Russia’s irresponsible anti-satellite weapon test scattering over 1,500 pieces of debris in LEO.

SSA – TraCSS

The good news is that we at NOAA are making progress towards the fielding of our SSA system. You may have heard it referred to in the past as the Open Architecture Data Repository, but we recently rebranded it to the Traffic Coordination System for Space, or TraCSS [“tracks”]. TraCSS will have three distinct components:

• TraCSS-OASIS: A data lake for storing, sharing, and disseminating government, international, and commercial SSA data;
• TraCSS-SKYLINE: The SSA application layer providing collision alerts, warnings, and other services; and
• TraCSS-HORIZON: An R&D proving ground for future products and services.

TraCSS will use DoD’s data as a base layer, but we are taking the whole platform into the 21st Century. It’s going to be like going from Windows 3.0 to Google Earth. We are leveraging commercial innovation such as cloud computing and modern APIs to keep it on the forefront of technology, and to support the growth of commercial markets that generate new revenue and jobs for the nation. We will augment DoD’s authoritative catalog of space objects with layers of commercially available SSA data to form a more complete picture of the traffic flows in space and provide more accurate, actionable forecasts of potential collisions.

NOAA already has deep experience with this kind of data fusion and prediction in the context of weather. Every day, our systems ingest massive amounts of data from tens of thousands of sensors, share it on open data platforms, and perform computational analyses to generate safety alerts and warnings. We are leaning on that experience to help solve the SSA problem, and this will benefit not just the commercial space industry, but NOAA itself as a satellite operator.

SSA – GEO Pilot

Just this week, the Office of Space Commerce and DoD are wrapping up a two-month pilot project to demonstrate the capability of U.S. commercial data products, analytics, and services to provide holistic spaceflight safety mission assurance to select spacecraft in the GEO [geostationary Earth orbit] and MEO [medium Earth orbit] regimes. The pilot involves GEO space object tracking data obtained through five commercial contracts awarded in September 2022, plus SSA data analysis performed under seven contracts awarded in December 2022. 

To date, the GEO pilot appears to be a success, providing satellite operators with improved spaceflight safety services compared to what they normally get from DoD. You can expect the Office of Space Commerce to release an official report on the pilot in the coming weeks. We are now considering our options for doing additional pilots while the operational TraCSS system is in development.

SSA – RFI

Just two weeks ago, the Office of Space Commerce published a request for information in the Federal Register soliciting industry comments on the TraCSS program, including the set of basic services it will provide to satellite operators. In designing TraCSS, it is important that we strike the right balance between providing too much service and too little.

On the one hand, we don’t want to provide so much free capability that we undermine the ability of commercial providers to sell their advanced SSA services. 

But on the other hand, if we provide too basic a service, we risk ceding U.S. leadership to other countries. Furthermore, if we don’t make a certain amount of service available for free, then small scale operators like high school cubesat clubs, who might not be able to afford advanced SSA services, may end up flying blind and degrading the sustainability of the space environment.

If you are a satellite operator, or a provider of SSA services, or simply interested in SSA, I encourage you to look up our RFI and weigh in with your response to our proposed definition of basic SSA services. You can find a link to it on the Office of Space Commerce website, space.commerce.gov.

Recap

I know I have just delivered you a firehose of information, but I wanted to convey to you how truly important smallsats and space commerce are to us at NOAA. Allow me to recap:

• Space commerce is a top priority for the Department of Commerce.
• NOAA is looking to potentially replace legacy weather satellites with a disaggregated smallsat constellation.
• In addition to flying our own satellites, we now buy data from commercial smallsats and use it in our weather forecasts.
• Our Office of Space Commerce is your champion inside the government, promoting the economic interests of the U.S. commercial space industry.
• But if your satellite can image Earth, you still fall under NOAA regulations.
• Finally, we are making major strides in our effort to field an SSA system that will reduce the risk of catastrophic collisions that could harm our economic, scientific, and national security interests in space.

I thank you for your attention. I look forward to meeting with some of you over the course of the next day.