Technical standards were key to accelerating the initial development of CubeSats. But CubeSats’ impact on research and education is contingent on regulatory standards that are accessible to new players in space exploration.
CubeSats are small satellites with a standardized sizing system of a 10 cm3 unit. Roughly the size of a Rubix Cube, it is this technical standard that earns them their name. What sets CubeSats apart from other small satellites was the implementation of technical standards at the start of their development. These technical standards serve as blueprints that make CubeSats easy to build, customize, and launch. Although technical standards are key to CubeSats’ success, current regulatory processes that enforce broader space standards can be complex to navigate for new players and serve as a barrier. To enable the long-term success of CubeSats, standards must keep space exploration accessible to new players and innovative practices.
CubeSats are accessible to design, build, and launch because they adhere to a standardized sizing system of a 10 cm3 unit, which became an ISO standard in 2017. CubeSat technical standards act as open blueprints that anyone can download, which can avoid reinventing the wheel with respect to certain features—saving designers time and money. Not only do technical standards serve as a guide to CubeSat design, but they are simple enough that they provide designers with flexibility for customization. The modular framework gives CubeSats a LEGO-like quality, which makes it easy for designers to mix and match different components and features, whether it be adding in a spectrometer for astrochemistry applications or imaging technologies for earth observation. In a Wilson Center event on low-cost tools and open source tools, CubeSat developer Dr. Zac Manchester, Assistant Professor of Robotics at Carnegie Mellon University, described how these standards made CubeSats design so accessible, “because you know what to do, you can go get the specification, it’s open, it’s downloadable, so that's been a focal point for collaboration and innovation.”
Launching payloads is expensive, so small satellites often have to catch a ride on government or industry launch vehicles. CubeSats’ standardized size units allow for easier communication about size requirements with launch services. In fact, CubeSat units, or “U”s can be stacked, like blocks, to build larger cubesats (e.g. 2U, 3U, 6U). Unlike other small satellites which vary in size from design to design, CubeSats use a standardized deployer system. The standardized deployer also has standardized electrical and mechanical features that reduce launch integration costs and timelines. Additionally, CubeSats are subject to uniform safety requirements such as ISO 19683:2017, which outlines testing requirements and methods to ensure reliability once CubeSats are in orbit. These standards make it so CubeSats can easily be swapped for one another on a launch vehicle, instead of having to create a new deployer system or redesign reliability requirements for each new satellite. This makes CubeSats interoperable with government and industry launches—reducing launch costs and increasing launch opportunities.
In production, these technical standards were accelerators in CubeSat development. The modular framework provided by these standards allows for enough flexibility in design, allowing easy incorporation of off-the-shelf parts. Over 1500 CubeSats have launched around the world since 2003, which can largely be attributed to the technical standards that shortened development timelines, drove down costs, and increased launch opportunities, which consequently accelerated the proliferation of this technology.
Barriers to Expanding Use
CubeSat-specific technical standards broaden who can participate in space exploration. However, to be launched, CubeSats must adhere to a number of regulatory standards that aim to protect satellites and the space environment by preventing the contamination of space (by Earth objects), ensuring orbital safety, and efficiently managing space resources. They do so through governing orbital debris mitigation, spectrum usage, cybersecurity, remote sensing, and rendezvous and proximity operations standards.
Although indispensable to a safe space environment, the complexity of satellite licensing requirements clashes with the streamlined technical standards embraced by CubeSat projects. The enforcement of these regulatory standards is complex and time-consuming. CubeSats are designed to have a short concept to launch cycle, ranging from about 9 months to 2 years. Timelines for obtaining licenses often are much longer than CubeSat development. For example, it can take about 2 years to register a CubeSat’s radiofrequency with the International Telecommunication Union, which is only one step of radiofrequency licensing.
Not only does the licensing process delay CubeSat launch, but the mismatch in timelines can also lead to additional setbacks with design or licensing. Regulators may find issues with a CubeSat after the design process has been completed, or vice versa. Regulators also require mission details like elevations and inclinations that developers cannot provide till later on in CubeSat lifecycle—further delaying or prohibiting launch (Communication Architecture and International Policy Recommendations Enabling the Development of Global CubeSat Space Networks). CubeSat developers that lack institutional connections, such as hobbyist or citizen science groups, may struggle more with navigating licensing processes and setbacks to launch. The licensing and regulatory process in the U.S. can be a barrier to launch and broader participation in space exploration.
Thinking Differently about CubeSat Standards
There is an opportunity to shift the approach to standards to accommodate rapid development timelines and new participants in space exploration. Given the importance of interoperability in CubeSat development, new standards and regulatory processes should prioritize technological interoperability, whether for new communication infrastructure or cybersecurity protection. Interoperability can help reduce timelines and cost in the enforcement of technical standards. In addition, reforming standards to make decision deadlines shorter for commercial launching licensing protocols can help shorten timelines.
Another step toward accessible standards for CubeSats would be to apply regulatory processes only when necessary. Many standards and regulations lack guidance or proper definitions to address future challenges, such as cybersecurity, in an increasingly commercialized space environment. The creation of clear definitions on licensing requirements will avoid lengthy remote sensing or cybersecurity licenses when not necessary for a CubeSat’s missions and will fill in gaps where guidelines are lacking for commercial satellites.
One example the U.S. can look towards is Luxembourg’s regulatory framework. Luxembourg is known for having a robust regulatory environment for commercial space players. Their standards on registration of space objects and financial support tools could serve as a basis to improve barriers related to radiofrequency spectrum management and access to resources for CubeSats.
Creating standards that protect space is about more than addressing future challenges in an increasingly complex space environment. It is about sustaining access to space, which appropriate, accommodating, and accessible standards can help accomplish.
Standards have both accelerated and hindered CubeSats from broadening space exploration, which, according to the MIT Media Lab, “is ultimately about building and contributing to healthy, self-sustaining ecosystems.” Their standardized size has made access to both government and industry launch vehicles accessible, allowing new players to explore space. The current state of regulatory standards creates barriers by requiring specialized institutional knowledge to navigate them. By examining the current regulatory standards and looking towards other countries' regulatory frameworks, barriers to use could be decreased, thus broadening use.
The Science and Technology Innovation Program (STIP) serves as the bridge between technologists, policymakers, industry, and global stakeholders.
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