Rebooting the American Dream: Challenge Grants for Emerging Innovation Ecosystems

Summary

Rebooting the American Dream (RAD) is a proposed national challenge-grant program that funds “Regional Centers for Shared Prosperity” in emerging innovation ecosystems, with the intent of (1) accelerating startup creation, (2) developing the next-generation of talent, and (3) providing alternative capitalization models. It is expected that initially funding the program to award six regional challenge grants of $25 million each will yield at least a 3:1 return in private-dollar investments—for a total of $500 million—and create at least 21,000 jobs in underserved areas of the country. In light of the massive job losses induced by the COVID-19 pandemic, RAD grants will build momentum behind existing place-based initiatives and help surface the wealth of diverse human potential and innovation that exists across the United States. 

The RAD proposal aims to revive entrepreneurship across America by helping give every American, regardless of geography, race, gender, or socioeconomic status, the opportunity to build a competitive company. Advancements in internet capabilities, communication tools, and information technology have made entrepreneurship accessible to more people in more places than ever before. Yet massive job losses related to COVID-19 and ever-growing global competition require the United States to discover new ways to create sustainable jobs. Over the past decade, initiatives led by the federal government in partnership with academics and nonprofits have given policymakers a markedly better understanding of the issues facing entrepreneurs. RAD is directly informed by this body of knowledge. By supporting bottom-up, place-based investment and building a network of new ideas through RAD, the Biden-Harris Administration can simultaneously foster American dynamism and strengthen American economic competitiveness.

The Local Innovation Unit: Achieving National Goals Through Local Experimentation

Summary

The Biden-Harris Administration should create the Local Innovation Unit (LIU) to catalyze and coordinate decentralized, city and county-based experiments focused on the most urgent and complex challenges facing the United States. Traditional “top-down” methods of policy design and problem solving are no longer effective in addressing our nation’s most pressing issues, such as pandemics, climate change, and decreasing economic mobility. The nature of these problems, coupled with an absence of tested solutions or “best practices” and ongoing partisan gridlock, demands a more agile and experimental “bottom-up” approach. Such an approach focuses on empowering coalitions of social innovators at the local level—including local governments, private-sector businesses, community-based organizations, philanthropists, and universities—to design and test solutions that work for their communities. Promising solutions can then be scaled horizontally (e.g., to other cities and counties) and vertically (e.g., to inform federal policy and action).

The LIU will be a place-based policy initiative consisting of two primary components: (1) multi-city and county experimentation cohorts organized around common problems, via which local coalitions design and test solutions within their communities, and (2) a digital platform, housed in the Department of Housing and Urban Development (HUD), that will help LIU participants connect, exchange materials and resources, help participants collect and visualize data, evaluate solutions, and publish lessons learned.

Repurposing Generic Drugs to Combat Cancer

Summary

Cancer patients urgently need more effective treatments that are accessible to everyone. This year alone, an estimated 1.9 million people in the United States will receive new cancer diagnoses, and cancer will kill more than 600,000 Americans. Yet there are no targeted therapeutics for many cancers, and the treatments that do exist can be prohibitively scarce or expensive.

Repurposing existing drugs, especially off-patent generics, is the fastest way to develop new treatments. Hundreds of non-cancer generic drugs have already been tested by researchers and physicians in preclinical and clinical studies for cancer, some up to Phase II trials, and show intriguing promise. But due to a market failure, there is a lack of funding for clinical trials that evaluate generic drugs. This means that there isn’t conclusive evidence of the efficacy and safety of repurposed generics for treating cancer, and so cancer patients who desperately need more (and more affordable) treatment options are unable to realize the benefits that existing generics might offer.

To quickly and affordably improve the lives of cancer patients, the Biden-Harris Administration should create the Repurposing Generics Grant Program through the National Cancer Institute. This program would fund definitive clinical trials evaluating repurposed generic drugs for cancer. A key first step would be for President Biden to include this program in his FY2022 budget proposal. Congress could then authorize the program and related appropriations totaling $100 million over 5 years.

Strengthening the Economy, Health, & Climate Security through Resilient Agriculture and Food Systems

Introduction

For those who can afford to fill their fridge by clicking a button on their smartphone or walking around to the organic grocery around the corner, it is easy to forget how complex and fragile our food systems can be. However, for millions of Americans who suffer from poor health because of food insecurity, or farmers and ranchers whose yields are decreasing along with the nutrient density of their product, that fragility is felt every day. Sustainable food systems engender intricate connections and feedback loops among climate change, public health, food security, national security, and social equity. When one of these factors is overstressed, disaster can result.

COVID-19 has underscored the vulnerability of our food systems. The pandemic caused restaurants to close overnight, strained supply chains, and led to food rotting on land, in warehouses, and on shelves. Low-income and food-insecure families waited in lines that stretched for miles while producers and distributors struggled to figure out how to get supplies to those who needed them. Concurrently, generations of racial inequity and the coordinated disenfranchisement of Black, Indigenous, and other people of color (BIPOC) has crystalized as an issue that needs to be addressed at every level in our country, especially within our food and agricultural systems.

Addressing these issues—now and for the future—requires a coordinated response across sectors. Food security is deeply intertwined with public health and social equity. Un- and under- employment, the racial wealth gap, and increased financial hardships for certain communities result in increased malnutrition, obesity, metabolic diseases, and chronic illness, as well as particular susceptibility to severe impacts from COVID-19 infections during the present pandemic. The climate crisis compounds these issues. Farming practices that degrade soil health, reduce agriculture capacity, and compromise the well-being of small farms and rural communities prevent us as a nation from becoming healthier and more secure. As we look at opportunities to “build back better,” we must embrace paradigmatic shifts—fundamental restructuring of our systems that will support equitable and inclusive futures. Compounding crises require changes in not only what we do, but how we think about what we do.

A fundamental problem is that progress in modern agriculture has been implicitly defined as progress in agricultural technology (AgTech) and biotechnology. Little emphasis is placed on examining whole-systems dependencies and on how connections among soil health, gut bacteria, and antibiotic use in livestock impact human health, economic prosperity, and climate change. With such a narrow view of “innovation,” current practices will solve a handful of isolated problems but create many more.

Fortunately, alternatives are ripe for adoption. Regenerative farming, for instance, is a proven way to combat future warming while increasing the adaptive capacity of our lands, providing equitable access to food, and creating viable rural economies. Regenerative farming can also restore soil health, which in turn improves food quality while enhancing carbon sequestration and providing natural water treatment.

Transitioning away from dominant but harmful practices is not easy. The shift will require an inclusive innovation ecosystem, investors with long time horizons, new infrastructure, tailored education, economic incentives, and community safety nets. This document explores how the agricultural sector can support, and be supported by, policies that advance science, technology, and innovation while revitalizing living systems and equitable futures. We recognize that agricultural policy often overlooks interventions that are appropriately suited to advance these concepts with Black, Indigenous, people of color (BIPOC) communities and on tribal lands. To avoid this mistake, the concepts presented herein start from the ground up. We focus on the benefits of improving soil health and food security through regenerative agricultural activities, and provide examples of policies that could promote such activities in a variety of ways. Letting practice drive policy— instead of having policy dictate practice—will result in more sustainable, inclusive outcomes for all communities.

While agricultural policy can and should be shaped at the local, regional, state, and national level, this document places special emphasis on the role of the federal government. Building better food systems will require multiple government agencies, especially federal agencies, to collaboratively advance more equitable policies and practices. Most national agricultural programs are housed within the U.S. Department of Agriculture (USDA). But the interconnectedness of how we produce food and fiber (and the ways in which those practices impact our environment and nourish people) demands priority investment not only from USDA, but also from the Environmental Protection Agency, the Department of Energy, the Department of the Interior, the Department of Defense, and the Department of Health and Human Services—to name just a few. This document—based on a review of existing policy recommendations and current practice, development and refinement of new ideas, and identification of underleveraged roles and programs within the government— suggests what such investments might look like in practice.

Building Back with a Cleaner Power Grid for America

Achieving energy decarbonization in America will require a power grid supplied by renewable energy and backed by ample energy storage. The challenge is that many types of renewable energy provide power intermittently depending on factors such as the time of day or weather conditions. To maintain grid reliability while working towards a nation powered by 100% renewable energy, the Biden-Harris Administration should accelerate adoption of distributed energy resources and expand transmission capacity to create a more unified national power grid. These efforts will increase equitable access to clean energy, accelerate investment in renewables, and create thousands of long-term, high-skilled jobs in a robust American energy sector.

Challenge and Opportunity

The U.S. power grid was built in—and designed for—a previous energy era: one in which on-demand, regionally located energy supplies (such as coal-fired power plants) are delivered to thousands of customers along one-direction transmission lines and managed by public utilities that operate as local monopolies.

But as our nation pushes to replace fossil fuels with cleaner sources of power, the energy landscape will look quite different. Many types of renewable energy provide power intermittently depending on factors such as the time of day or weather conditions. Supplies of such energy sources cannot be ramped up easily (or at all) during periods of peak demand. Meanwhile, smart-and-distributed-energy technologies—such as smart thermostats, rooftop solar, and electric vehicles—have led to an increasingly dynamic and complex power grid. 

The policy response to these rapid changes in the way we generate power has mostly constituted a patchwork of efforts at the state and regional level. Federal attention to renewables has focused largely on tax incentives and on regulation via orders from the Federal Energy Regulatory Commission (FERC). For instance, FERC’s recent order opening wholesale energy markets to distributed energy resources is an important step towards increasing the share of renewables in the U.S. energy sector. Incentives to increase adoption of renewables and investment in research and development (R&D) to improve performance and utility of renewables are essential as well. But to realize a quick and smooth transition to a clean-energy future, concerted action is needed to tackle the intermittency challenge that renewables pose.

Such action can proceed via two complementary pathways simultaneously. The first pathway is using technology advances like vehicle-to-grid (V2G) integration, demand response, smart thermostats, and energy storage to flexibly shift load demand. These technologies help guide certain discretionary types of energy consumption (e.g., running a load of laundry) to occur during times when renewable-energy supply is high but demand is low, and can even enable consumers to return energy to the grid (e.g., by plugging in a parked electric vehicle so that the vehicle’s battery can be used as a power source) to during periods of peak demand.

Unfortunately, innovative energy-management technologies are markedly underutilized in the U.S. power sector. Distorted market-incentive structures, inadequate control protocols governing relationships between operators and consumers, and reliability concerns have all made utilities reluctant to embrace a more dynamic grid. Moreover, grid users (i.e., residential and commercial customers) cannot currently participate in an open energy market on an equal footing with utilities. This means that our nation is not realizing the full value of services that customers can provide to a power grid.

A smarter grid-operating system would (1) make it easier for operators to integrate distributed energy resources (DER) with more conventional types of power supplies, (2) economically incentivize changes in user behavior to smooth out energy-demand curves, and (3) enable everyday Americans to invest in distributed clean-energy technologies and earn returns for providing various services to the power grid. These steps in turn would greatly facilitate large-scale integration of renewables into the U.S. power mix.

The second pathway for addressing the intermittency problem is to finally create a connected and integrated American power grid. This would enable areas with steady supplies of renewable energy—such as solar in the Southwest, wind in Texas and the Midwest, and off-shore wind in New England—to deliver power to different parts of the country as needed. Preliminary studies done by the National Renewable Energy Laboratory (NREL) have demonstrated the economic and environmental benefits of unifying currently disconnected sections of the American power grid. Examples from California and Texas illustrate the need to and benefits of expanding national transmission capacity.

California’s power grid highlights the problems of building aggressive renewable energy portfolios without sufficient transmission. As renewable-energy capacity in California has increased, so too has curtailment—i.e., deliberate reduction in output—of that capacity (Figure 1). Roughly half of this curtailment has been due to transmission constraints. Transmission constraints have also prevented creation of approximately 72,000 potential American jobs from renewable-energy projects in the Midwest.

Figure 1

Insufficient transmission capacity coupled with increasing renewable-energy production in California is resulting in significant curtailment, or waste, of renewable energy in the state. (Source: California ISO. (2021).

In Texas, the 2021 winter storm Uri recently demonstrated an even more dire consequence of limited interconnection across our nation’s power infrastructure: the disastrous failure modes that can manifest in isolated power grids. When Uri hit, grid operators simultaneously encountered high load demand as residents turned up their heaters and inadequate energy supply as naturalgas power plants began failing in the cold weather. The rolling power failures experienced in Texas during the storm could have been mitigated if Texas had been able to import energy from other grids. Connecting the regional power grids that exist in the United States will improve grid resiliency across the nation by allowing regions to draw from each other as circumstances and local conditions demand.

Strengthening the U.S. power grid through improved use of energy-management technologies and better regional interconnections will have benefits that extend beyond grid flexibility and resilience. Grid modernization will create jobs across America in the construction, manufacturing, and energy sectors. By empowering rate-payers to produce their own energy, sell back surplus energy to the grid, and be rewarded for shifting energy-consumption patterns in response to grid conditions, grid modernization will generate economic value for consumers. By encouraging development of distributed energy resources, grid modernization will allow rural communities to replace expensive and burdensome propane shipments with continuously flowing electricity from local solar and storage installations. By transforming the U.S. power grid from a collection of regional entities into an interconnected, national resource, grid modernization will allow energy developers to tap into a national energy market instead of being limited by regional boundaries. And by creating a more unified energy sector, one in which states and communities rely on each other for power, grid modernization might even result in a more united country.

Plan of Action

The federal government plays a critical role in regulating and maintaining the nation’s grid infrastructure. As such, there is much that the Biden-Harris Administration can do—by using existing executive authority and by working with Congress on legislative actions—to strengthen the resilience of the U.S. power grid and foster integration of distributed energy resources and renewables into the U.S. power sector. Progress on these fronts will help transition the United States towards a 100% clean-energy future while creating industries and jobs centered around clean-energy resources, building up America’s advanced manufacturing base, and generating new economic opportunities for all Americans.

Actions using existing executive authority

Improve coordination between federal and state entities to reduce regulatory barriers to energy development. The federal government can support interstate grid projects (such as regional interconnections) by helping coordinate state legislatures and by reducing regulatory burdens related to such projects. In particular, FERC plays an important role in coordinating regional grid investments and planning across states (such as the Eastern seaboard’s off-shore wind grid). The Biden-Harris Administration should prioritize this function of FERC in order to reduce the bureaucratic hurdles faced by energy developers. The new White House Office of Domestic Climate Policy (Climate Policy Office) can play an additional coordinating role, helping to align technical research conducted at the Department of Energy (DOE)‘s national labs with policy and regulatory work conducted through the White House Office of Science and Technology Policy (OSTP), the Department of Interior, the Department of Defense, and other relevant federal entities. Finally, the Climate Policy Office can work with state legislatures to provide state-specific recommendations (i.e., recommendations tailored to the unique natural resources and electricity market structures of each state) on how to best incentivize investment and job growth in the energy industry.

Actions involving collaboration with Congress

Scale R&D innovations in clean-energy technologies by increasing relevant DOE funding. The federal government can use its federal budget to help scale R&D innovations in clean energy and help advance those innovations towards manufacturing and production. By accelerating commercialization and mass production of clean-energy innovations, federal investment will help make clean energy more affordable for American consumers, while simultaneously fostering job growth in the American energy sector. To that end, the next White House budget proposal should include significant funding increases for DOE, in particular for DOE’s Office of Energy Efficiency & Renewable Energy (EERE)1, Loan Program Office (LPO), and Advanced Research Project Agency for Energy (ARPA-E). Increasing funding for these offices, which use different financing schemes to invest in technologies at different stages of commercialization, is a direct way for the federal government to scale up American-made energy technologies. These three offices heave a proven ability to identify promising candidates for energy innovation.2 Increasing appropriations for these high-impact offices by $500M will represent a more than 10% increase in each offices’ budget: enough to make a difference, but not a dramatic departure from the budget increases already appropriated by Congress from FY 2019– FY 2020.

Broaden the definition of “qualifying facilities” to allow everyday Americans to participate in energy markets. Broadening the definition of “qualifying facility (QF)” in the Power Utility Regulatory Policy Act (PURPA) of 1978 to include energy storage, power quality factors, and demand response would require utilities to compensate energy providers for a wider range of services: i.e., services that go beyond simple energy production. The power grids of today and of the future are more than a collection of relatively fixed energy demands and supplies. Broadening the definition of QF would acknowledge the increasingly dynamic nature of the power grid, where excess supply often needs to be stored for later and where some portion of demand load can be shifted to different times of day. In particular, broadening the definition of QF would require utilities to (1) treat their own customers as first-class suppliers for a diverse set of potential use-cases in the energy marketplace and (2) properly compensate rate-payers for any services they provide to the power grid. Ensuring the market properly rewards customers for adopting novel clean-energy technologies will spur clean-energy market growth, drive innovation, and generate economic value for individual Americans newly able to participate in electricity markets.

Encourage construction of additional transmission capacity via tax incentives and loan programs. Tax credits have historically been a popular way for Congress to incentivize development of renewable energy such as wind and solar.3 By making the construction of additional transmission capacity similarly eligible for tax credits, Congress can support a critical piece of our nation’s grid infrastructure while creating construction jobs across the country.4

Frequently Asked Questions
What role can electric vehicles play in a smarter grid?

From the standpoint of the power grid, electric vehicles (EV) are essentially mobile batteries. EVs plugged in and their batteries used to store surplus renewable energy when production is high or return energy to the grid when renewable-energy production drops. However, this vehicle-to-grid exchange requires careful coordination between EV owners and utility operators. The current power grid is not designed to handle individual consumers returning power to the grid, and there is no way for utilities to compensate EV owners for the value they provide to utilities by doing so. A “smart grid” would create an electricity marketplace that EV owners could participate in. Such a marketplace would significantly improve the value proposition of EVs, encouraging EV uptake as well as domestic investment in advanced automobile manufacturing. Given that Tesla became America’s most valuable automobile company in 2020, the market has already seen the value that EVs have to offer. A smarter power grid will allow full capitalization of that value by consumers, industry, and our power grid.

In an increasingly divisive political environment, how can bipartisan support be generated for investment in energy infrastructure?

Investing in the U.S. power grid will benefit many constituent groups, allowing for a multifaceted approach to messaging. For instance:



  • Solar energy coupled with storage can lower electricity costs and reduce reliance on imported natural gas or propane for rural and isolated communities.

  • Certain U.S. geographic regions, such as the Southwest, contain some of the greatest natural renewable energy sources in the world. Directing federal incentives towards such areas will create jobs at the state and local level while reducing foreign energy dependence.

  • President Eisenhower passed the Interstate Highway Act by appealing to bipartisan support in a Cold War environment and helped create our modern road infrastructure. The transmission power grid, as the “interstate highway” for the electricity that powers America, is a similarly important piece of infrastructure that will help America maintain its national security and international competitiveness.

How do established or maturing clean-energy technologies relate to America’s economic and strategic interests?

Distributed clean-energy technologies, like energy storage, residential solar, on-shore and offshore wind, and electric vehicles are quickly reaching economies of scale. Artificial intelligence is increasingly being used to ensure grid stability, optimize grid operations, and inform resource planning. High-voltage transmission lines and power inverters are critical parts of the infrastructure that makes up the backbone of the power grid. Each of these technologies presents an economic opportunity for the federal government to invest in building new infrastructure and spur private development, creating new jobs and industries in the process. In addition, many of these technologies are currently manufactured abroad or rely on minerals imported from foreign countries. The federal government should direct research funding towards technologies that do not rely on foreign imports and that leverage America’s existing manufacturing infrastructure and natural resources. Finally, maintaining a robust workforce of professionals who know how to manage and debug production processes will be important for ensuring that our nation is capable of translating American R&D into products that can be manufactured domestically. Following through on the Plan of Action outlined in this proposal will help open the power grid to broader participation and ensure cleaner, more equitable power distribution while simultaneously advancing American technical competitiveness and manufacturing capabilities.

Why is changing the definition of qualifying facilities under PURPA important to helping Americans achieve access to the power grid market?

The federal government’s recent involvement in the power market has focused on tax credits and R&D funding. Indeed, the Energy Act of 2020 injects significant federal funding to R&D funding programs and extends certain tax credits. While continued support for R&D funding is important and tax credits are an important market mechanism, amending PURPA is a different type of action altogether. By changing the definition of qualifying facilities, the federal government categorically changes the basis by which utilities buy power. Firmly establishing an expanded definition of QF via legislation will prevent non-elected bodies from arbitrating the definition of QFs either now or in the future. FERC performed such arbitration in 2020, to the detriment of energy storage projects and the chagrin of clean-energy trade associations.


Amending the definition will force the market to properly compensate consumer-provided services that provide value to the grid. For instance, smart thermostats can reduce electricity used for heating and cooling when energy supply drops or electric vehicles can be optimized to only charge when supply is ample. Incentivizing behavioral changes like these is critical for achieving a 100% clean power grid. Amending PURPA to allow Americans to invest in and earn returns on a broad range of energy technologies today will prepare the United States for the power grid of tomorrow.

Section 230 Is Essential to the Internet’s Future

Summary

Section 230 is not a gift to Big Tech, and eliminating it will not solve the problems that Big Tech is causing. Those problems stem from a severe lack of competition. Repealing Section 230 will exacerbate those problems.

Section 230 is critical to the proper functioning of the Internet. To rein in Big Tech, the law should be supported, not weakened or repealed. The Trump Administration’s executive order on Section 230 should be repealed. Further, action to limit the power of large tech companies should be taken on three fronts: antitrust, privacy, and interoperability.

Creating an Advanced Research Projects Agency (ARPA-L) for the Department of Labor

Summary

To create fresh and powerful new approaches to the complex challenges that America’s workers face, Congress and the Biden-Harris Administration should invest $100 million per year for 5 years to launch an Advanced Research Projects Agency for Labor (ARPA-L). ARPA-L’s mission will be to conduct high-impact R&D programs that create breakthroughs to meet America’s workforce challenges.

The COVID-19 pandemic has deeply exacerbated longstanding problems for America’s workers. Mismatches between workers’ skills and employers’ needs alongside persistent racial and gender inequities have long undercut opportunity. Moreover, work has continued to change due to technology and automation, globalization, and shifting relationships between workers and employers. Even before the COVID-19 crisis, many millions of Americans were not earning enough to support themselves and their families. These Americans are missing out on gainful work, while our economy and our society are missing out on their full contribution.

With current advances in information technology, data science, applied social sciences, and learning science, this moment calls for an ambitious initiative to tackle the longstanding challenges for America’s workers. The Federal Government should launch an ARPA-L to research, develop, and test breakthrough approaches that boost workers’ skills and harness data to open new opportunities. By drawing from the operating model of prior ARPA organizations and adapting it to these challenges, ARPA-L’s programs can make it possible to ameliorate underemployment and unemployment and transform the future of work.

To initiate ARPA-L, Congress should provide a budget of $100 million per year over a five-year period. The Biden-Harris Administration and the Secretary of Labor should appoint a highly qualified director and provide that individual with the support needed to succeed. By creating this independent agency at the Department of Labor (DOL), Congress, the White House, and DOL can create opportunity for the U.S. workforce for decades to come.

Averting Environmental Risks in the New Space Age

We face an existential crisis: Space is at risk of developing the equivalent of the ocean’s “drifting island of plastic.” Air, space, and light pollution now present looming environmental threats created by the launch of new “mega-constellations” of thousands of satellites in the part of space near Earth called “Low Earth Orbit” (LEO). A “take risks and fail often” approach to new technology has been extended to space without consideration of the fact that mistakes in space cannot be cleaned up like they can on Earth.

In 2019, a European Earth observation satellite came dangerously close to colliding with a newly launched mega-constellation satellite, having to perform a last-minute maneuver to avoid the satellite, whose operator did not respond to attempts to contact it. As the number of satellites in congested orbits increases exponentially, close calls like this are becoming more commonplace. And we are seeing an unexpected number of these satellites fail such that they do not even have the ability to try to avoid dangerous collisions. As the movie Gravity illustrated, a collision in space can set off a chain reaction of further collisions, potentially destroying or disabling satellites and spreading large amounts of dangerous space junk. The recent introduction of thousands of satellites in LEO is also creating light and radio-frequency pollution that impairs the once-clear access to the cosmos for critical scientific-based research. Indifferent to these serious environmental issues, and largely unregulated, mega-constellation operators are rushing to launch as many satellites as possible before new rules are put in place.

The Biden-Harris Administration should direct the Federal Communications Commission (FCC) and the Federal Aviation Administration (FAA) to fully examine and address these critical environmental issues before the United States authorizes thousands more LEO satellites in mega-constellations. Three concrete steps are warranted: (i) determine the aggregate impact of all mega-constellations, (ii) conduct a thorough review of these “unprecedented” new uses of space under the National Environmental Policy Act (NEPA), and (iii) adopt new rules that consider the full environmental impacts of mega-constellations before they are launched. In this regard, the Biden-Harris Administration should consider either (i) issuing an Executive Order instructing the FCC and the FAA to evaluate the environmental consequences associated with mega-constellations before permitting their launch or deployment, or (ii) proposing legislation that requires the FCC and the FAA to do the same.

Action — or inaction — by the Biden-Harris Administration will set the standard on which the global space industry will base its next design choices. Unless we act now, we may find that, as with climate change, we wish we had acted much sooner.

Challenge and Opportunity

Space near Earth is both a limited and a shared resource — a ”commons” that must be protected. Currently, as leading experts recognize, certain satellite operators do not have an economic incentive to protect shared resources. The same is true for our atmosphere and our night sky. 

These threats have developed because of recent changes in the marketplace and commercial cost/safety tradeoffs that have negative environmental impacts. 

Many recent technological advances have eliminated the high cost of access to space that once fostered a responsible space ecosystem, and limited the number of objects in space. Previously, the rules to manage the risks were adequate. That is no longer the case. Today, self-interest and the public good are quickly diverging, as the cost of failure to an individual actor is far, far less than the collective risk of multiple individual failures — a long-anticipated “tragedy of the commons” in space. 

One example is the needless choice of using large numbers of economically expendable satellites that have high negative environmental impacts, when fewer and more reliable satellites can achieve the same goals without those impacts. This threat to the commons both in space and here on Earth is manifested in the many thousands of LEO satellites being launched into space, with one company alone planning to launch over 40,000 satellites in the near future. By comparison, mankind has launched only about 9,000 satellites total since space exploration began seven decades ago. The International Telecommunication Union (ITU) and national regulatory filings indicate that around 100,000 LEO satellites could be launched in the coming decade. Indeed, the FCC has authorized or received applications for constellations that will consist of about 100,000 LEO satellites operating at any given time, and when expected replacements are factored in, many multiples of that number will launch and ultimately vaporize in the atmosphere over a 15-year license term.

A leading provider of collision-threat analysis tools has notionally depicted the scale of the satellite constellations expected to deploy in LEO over this decade, in the following figure:

Figure 1: Illustrative LEO Constellation Deployment (2017-2029)
Figure 1: Illustrative LEO Constellation Deployment (2017-2029)

From S. Alfano, D. Oltrogge, R. Shepperd, “Leo Constellation Encounter and Collision Rate Estimation: An Update.” 2nd IAA Conference on Space Situational Awareness (ICSSA), Washington, D.C., January 14-16, 2020, https://www.documentcloud.org/documents/6747529-LEO-CONSTELLATION-ENCOUNTER-and-COLLISION-RATE.html. 

Mega-constellations in LEO raise a number of significant environmental threats:

Polluting Our Air and Affecting Climate Change

Mega-constellations are designed so their defunct satellites reenter the atmosphere and vaporize, releasing chemical compounds, including aluminum oxides. The Aerospace Corporation (an advisor to the U.S. Space Force) reports that this massive increase in the number of satellites reentering the atmosphere and releasing chemical compounds and particles could contribute to climate change through radiative forcing and ozone depletion.1 Most of the reentering mass vaporizes into small particles consisting of a “zoo of complex chemical types.” The stratosphere where this pollution gathers is home to the fragile ozone layer that protects the Earth from UV radiation.

None of these risks is currently being examined, or even considered, by the FCC as the United States authorizes mega-constellations to serve the United States. Authorization includes permission for initial deployment and the subsequent deployment of an unlimited number of replacement satellites over a license term in the case of U.S.-licensed systems, and, in the case of constellations licensed by other Administrations, permission to serve the United States with those constellations.

Polluting Space

The operation of large numbers of LEO satellites in mega-constellations significantly raises the risk of collisions in space. This is particularly true when those satellites do not retain a high level of reliable maneuverability for as long as they remain in orbit. Satellites that cannot maneuver cannot avoid collisions with other satellites or the large amounts of lethal space junk already in LEO orbits. The resulting collisions can be catastrophic—fragmenting the satellite into thousands of pieces on new space junk that spread into and impact orbits hundreds of kilometers above and below the collision. This new space junk essentially becomes high-speed, unguided missiles that pose a collision risk to other satellites.2

The following figure from the European Space Agency depicts the growing number of space objects in the LEO region (2000 km and below).3 A significant portion of recent increases is attributable to LEO satellites themselves, as well as the fragmentation of those satellites after collisions.3

Collisions can have a devastating impact, sending large clouds of high-speed shrapnel-like space junk into surrounding orbits. This space junk can disable or destroy other satellites that are critical for connectivity, mapping, weather, and defense purposes — and it can persist for decades and even a century or more, making access to space riskier and more expensive. Thus, satellites in mega-constellations that fail or degrade such that they can no longer be reliably maneuvered while they remain in orbit present undue risks to space and everyone who seeks to utilize space. Of great concern are the cost/safety tradeoffs being made in mega-constellation designs that value low-cost, economically expendable satellites over constellations with fewer and more reliable satellites. Making that tradeoff reduces the likelihood of successfully maneuvering to avoid collisions.

Under current policies, mega-constellations continue to be authorized by the FCC under risk standards that were developed for single satellites and that are wholly inadequate for megaconstellations. Today, the FCC seeks to ensure that the risk of a single satellite colliding with another space object is less than one in 1,000 for the expected lifetime of that satellite. That approach does not consider the additive risk from each satellite in a mega-constellation and the unlimited number of replacements that could be launched over a 15-year license term. This would allow for catastrophic collisions very frequently, as depicted below:

Table A: Application of Current Approach to Collision Risk
# of Satellites in OrbitAllowed Mean Time Between Collisions in Years
1,0005
5,0001
10,0000.5 (180 days)
50,0000.1 (36 days)
100,0000.05 (18 days)

When even a single collision can have devastating effects, effectively sanctioning many collisions is simply an untenable policy. Collision risk scales with LEO constellation size and the number of LEO constellations, and this aggregate risk is not being considered in the current authorization process. Moreover, the tools the FCC uses today to evaluate collision risk do not factor in a number of relevant risks, including:

If mega-constellations are allowed to continue to deploy without a full and complete analysis of these issues and the adoption of suitable mitigation measures, competition and innovation in space may come to a standstill. The Organization for Economic Cooperation and Development (OECD) calls the deployment of mega-constellations a “game changer” and warns of the prospect for a never-ending spiral of collisions that would eventually render LEO unusable and possibly impenetrable — foreclosing access to and innovation in space for generations.

Polluting Dark and Quiet Skies 

Mega-constellations present threats to ongoing critical scientific research in the fields of optical astronomy and radio astronomy. The question of how these threats should be mitigated has not yet been resolved. They include three types of interference: (i) satellites in the night sky reflecting sunlight that interferes with optical research telescopes; (ii) artificial radio wavelength emissions that interfere with radio telescopes; and (iii) light pollution that impacts naked eye viewing of the night sky. Indeed, the disruptive nature of the growing number of mega-constellation trails in the night sky is evident from a variety of reports. Nevertheless, the effect of fully-deployed mega-constellations on the visibility of the night sky and on professional astronomical observations has not been adequately considered as a policy matter. 

The threats of mega-constellations to critical astronomy-based scientific endeavors were recently addressed by a leading group of experts under the auspices of the United Nations Committee on the Peaceful Uses of Outer Space (COPUOS), which included the UN Office of Outer Space Affairs (UNOOSA) and the International Astronomical Union, among others. Their recent report and recommendations emphasize that “[c]utting edge astronomical discoveries can only continue on the basis of an unobscured and undisturbed access to the cosmic electromagnetic signals,” and detail why mega-constellations are a threat to astronomy. As the report explains in detail, further work to mitigate the adverse impacts of LEO mega-constellations is urgently needed, and appropriate limits must be adopted and enforced by individual national governmental authorities. 

Tragically, there is no apparent systematic means for addressing these matters in the United States. Historically, these threats have not been addressed by the FCC in authorizing the deployment and operation of LEO mega-constellations. In fact, some mega-constellation proponents have asserted that the FCC does not even have jurisdiction over the “visibility of satellites,” and have resisted calls for the FCC to fulfill its statutory obligation under NEPA, and consistent with standing Executive Orders, to examine the environmental impact of deploying thousands of satellites.

Plan of Action

As the Biden-Harris Administration sets its agenda, protecting the environment in space and on Earth and keeping space accessible for all should be of utmost importance and an immediate priority. 

The last Administration recognized that these operators have little incentive to protect the “commons” that is our environment, but still failed to act. Indeed, the prior Administration allowed more mega-constellation satellites to be launched while it said it would consider new rules that remain unadopted. The Biden-Harris Administration should chart a new course.

First, the Biden-Harris Administration should immediately cease the existing practice of authorizing constituent parts of an individual mega-constellation without considering the aggregate impact of (i) all of the parts of that constellation, (ii) all of the other megaconstellations that are authorized or in the process of being authorized, and (iii) other megaconstellations that are likely to be developed and deployed as a natural response to the lack of regulatory oversight. 

Second, the Biden-Harris Administration should order a thorough review of the environmental threats caused by each of these unprecedented new uses of space, including consideration of suitable mitigation techniques such as meeting the same objectives with fewer and more capable satellites. In this regard, the Biden-Harris Administration should consider either (i) issuing an Executive Order instructing the FCC and the FAA to evaluate the environmental consequences associated with megaconstellations before permitting their launch or deployment, or (ii) proposing legislation that requires the FCC and the FAA to do so. Such an Executive Order would be consistent with the Carter Administration’s prior directive that federal agencies evaluate major actions significantly affecting the environment of the global commons.  

Third, the Biden-Harris Administration should adopt rules that require that the total impact of a mega-constellation be considered before providing authorization to launch from or serve the United States. Indeed, acting FCC Chairwoman Jessica Rosenworcel has recognized that “this rush to develop new space opportunities requires new rules. Despite the revolutionary activity in our atmosphere, the regulatory frameworks we rely on to shape these efforts are dated.” Acting Chairwoman Rosenworcel has also warned that the FCC’s history of approving LEO constellations without addressing these risks means the U.S. will be “junking up our skies” if we do not move faster in adopting new rules.22 Operators should be required to provide sufficient assurances at the application stage about how they will mitigate those impacts. Periodic “health checks” should be conducted to ensure operators are living up to their commitments, and when they do not, the Biden-Harris Administration should take appropriate action, including freezing authority for further launches.

Early Prevention is Critical

While there are a number of important steps needed to manage these issues, the most critical step is to prevent more harm before it occurs, by addressing these issues at the application stage, where US agencies authorize the deployment of satellites. 

For decades, the FCC has been the agency authorizing the deployment and operation of commercial satellites, and their ability to serve the United States. In that role, the FCC has also for decades addressed the safe flight of commercial satellites and the potential for them to contribute to the space junk problem. The FCC is also mandated by statute to factor in public interest considerations that are not within the charter of other agencies. The FCC has had a rulemaking proceeding on safe flight and space junk issues pending for over two years.4 More generally, the FCC is also obligated to consider the requirements of NEPA and implement directives and orders as to the environmental impact of FCC actions. 

Other agencies study or oversee different aspects of these issues. For example, the FAA authorizes the launch of satellites from U.S. soil and is obligated to consider NEPA in that context. The National Aeronautics and Space Administration (NASA) has studied the effects of space junk on the long-term sustainability of physical access to space but has not addressed: (i) the risks associated with space junk disrupting vital communications networks in the near term, (ii) the impact on Earth of a steady stream of thousands of satellites vaporizing and polluting our atmosphere, or (iii) the disruptions to ongoing scientific research that mega-constellations create. 

Congress, industry leaders and other experts have recognized the need for increased awareness of the growing number of trackable objects in space. It is apparent that this challenging task only becomes more difficult as space fills up with more uncontrollable space junk. To date, the Department of Defense has had a lead role in this task. More recently, there have been calls by Congress and others in the industry to bring this mandate under the Office of Space Commerce (OSC), a division of the National Oceanic and Atmospheric Administration (NOAA) in the Department of Commerce. OSC would be charged with collecting space situational awareness data from government, foreign and commercial sources as well as with developing a space traffic management function to prevent operational satellites from colliding with space junk. This function is incredibly important, and it must be facilitated by ensuring that operators are building, deploying and operating satellite systems in a manner that minimizes the chance of collisions and creating increased space junk in the first place.

We should also work closely with our international allies to put rules in place that ensure safe and shared access to space, a clean atmosphere, and a dark and quiet night sky. The United Nations’ COPUOS and UNOOSA have started to address some of these issues, but the existing UN COPUOS guidelines on space junk were adopted over 13 years ago, before the New Space Age. They do not address the risks presented by mega-constellations that the FCC has recently acknowledged or the environmental harms discussed above. Moreover, these guidelines are not legally binding. Under the leadership of UN Ambassador Linda Thomas-Greenfield and Special Presidential Envoy for Climate John Kerry, we should ensure there is international action in this area and shared responsibility regarding space and Earth. 

Of course, any guidance at the multinational level must be applied and enforced at the national level to be effective. Recent reports from OECD and the COPUOS working group emphasize the need for a national-level focus on the environmental threats created by mega-constellations. The United States (through the FCC) must implement rules for the licensing of commercial satellites and otherwise address the environmental threats posed by mega-constellations to ensure that US companies, government agencies, and scientists have continued safe and reliable shared access to these finite resources. 

The Biden-Harris Administration has already demonstrated its commitment to science-based policymaking and to the environment. That initiative should include a rigorous examination of the environmental threats posed by mega-constellations to our shared resources in space and here on Earth. The U.S. should lead in establishing sustainable environmental policies in the New Space Age — not continue existing practices that perpetuate the current reckless rush to fill space with mega-constellations before suitable rules and policies can be put in place. If the Biden-Harris Administration acts expeditiously, America can get in front of these threats and lead the world.

Conclusion 

The standard the Biden-Harris Administration sets today with respect to mega-constellations — whether by action or inaction — is what the global satellite industry will soon follow. It is unquestionable that mega-constellations pose a variety of significant environmental threats, and that NEPA requires these issues to be fully examined. By instituting and applying high standards for environmental protections, the Biden-Harris administration can ensure our shared space resources are used safely and in a manner that limits environmental harm both in space and on Earth.

Frequently Asked Questions
Satellites are not new – why should this be an early priority for the administration?

A new and very different use of space is occurring in the form of constellations of thousands, or even tens of thousands, of satellites in the part of space nearest Earth, and known as “Low Earth Orbit” (LEO), which is already congested with space objects. These “mega-constellations” are considered “game changers” and even their proponents describe these proposals as “unprecedented” in nature.5 These mega-constellations are being advanced without a full evaluation on the environmental costs they impose, and without regard for whether the same objectives could be achieved in a more environmentally friendly manner — or if the missions to be served by these mega-constellations are in fact worth the environmental consequences. Leading third parties have detailed the expected environmental harms from these megaconstellations: air pollution, space pollution, and light and radio-frequency pollution.6 Mistakes in space cannot be cleaned up like they can on Earth. It would be common sense to prevent junking up space in the first place. Moreover, decisions made — or not made — during the course of this year as more mega-constellations satellites are approved for deployment will set the standard for the global space industry and the design of additional satellite constellations in LEO.

Are there sufficient environmental impacts on Earth to warrant environmental review?

Yes. The vaporization of mega-constellation satellites when they deorbit and reenter the atmosphere releases chemical compounds that could contribute to climate change through, among other things, radiative forcing and ozone depletion.7 That process poses a new source of air pollution in the form of small particles comprising “a zoo of complex chemical types” that will “form around an 85-kilometer altitude, then drift downward, accumulating in the stratosphere…”8 The stratosphere where this pollution gathers is home to the fragile ozone layer that protects the Earth from UV radiation.9 Scientists anticipate that the fact that these pollutants are directly injected into the uppermost layers of the atmosphere (top down) means that they can cause significantly greater harm than pollutants that emanate from Earth (bottom up).


Particularly under these circumstances where many experts have issued calls to arms about the significant environmental effects of mega-constellations, there is no excuse for turning a blind eye by failing to conduct an environmental review. A key purpose of NEPA is to ensure that agencies look before they leap, particularly when presented with previously unanticipated circumstances that may have a significant environmental effect.10

Could the space industry be naturally incentivized to operate responsibly in space?

The FCC has long recognized the lack of economic incentives for individual actors to act responsibly with respect to the shared resource that is space.11 Changes in the space industry have eliminated the incentives to achieve safe-space operations that previously existed.12 The cost of launch has dropped precipitously, reducing the cost of access to space. Economies of scale that enable small, inexpensive payloads are driving investment in inexpensive and economically expendable satellites. When the cost of space access is high, self-interest motivates high standards of care because the cost of failure is high. The term “space-qualified” once meant the industry’s highest standards for quality and reliability, even in the harsh conditions of space. Those high costs once fostered a safe space ecosystem: the number of objects in space was limited, and the rules to manage the risks were adequate. With economic barriers gone, self-interest and the public good are quickly diverging. The cost of failure to an individual actor is far, far less than the collective risk of multiple individual failures — a long-anticipated “tragedy of the commons” in space.

Is this a choice between better broadband and a clean environment?

Not at all. Many different advances in satellite technology over the past several years are providing significant increases in both broadband speeds and capacity for consumers. Satellite operators have proposed systems with fewer, more reliable satellites that can achieve the same objectives as mega-constellations, and without high levels of negative environmental impacts.


Professor Andy Lawrence, author of Losing the Sky, recently said it best: “Giving people better Internet, and keeping Capitalism healthy and competitive, is quite possible without thousands of low orbit satellites. Why should we accept arbitrary degradation and pollution when it’s not even necessary?”13 Particularly when experts, including the FCC, recognize that many satellite operators do not have a natural incentive to protect common natural resources (space, the atmosphere, Earth) for the benefit of others, it is essential to adopt regulations and licensing approaches that ensure we can both have access to the most advanced technology and also maintain a safe and clean environment. Many options exist, and the number and reliability of satellites in a LEO constellation is a design choice that companies can make to ensure that consumers have both better broadband and assurances of a safe and clean environment.

Aren’t LEO orbits the safest place to operate?

There is no direct correlation between the altitude at which a LEO satellite system operates and the risk of collision involving that system. A number of factors come into play in assessing safety, including the density of objects in a given orbit. Some orbits are denser than others, meaning that satellites and space junk are less dispersed. In fact, “the most crowded section is between 500 and 1000 km up. It’s the densest region, it’s the Highway 401 of space.”12 Then you have to consider the defunct satellites and space junk in higher orbits that will naturally deorbit through lower orbits and create collision risks. The scale of a given constellation (number of satellites) and its design are also major factors in assessing collision risk.

Aren’t LEO orbits naturally “clean”?

Satellites that cannot maneuver cannot avoid collisions. And when they do collide, even collisions at 550 km would pollute orbits many hundreds of kilometers above and below, with large fields of fast-moving shrapnel-like space junk that would traverse other orbits for decades or a century, as well as impair use of those orbits and harm many other users of space. Furthermore, having satellites in lower orbits does not solve the atmospheric pollution issue. And as leading experts explain, mega-constellation satellites in low orbits are most visible when most ordinary people are looking at the sky, as well as when key optical astronomical observations need to take place.12 These satellites also can be visible all night in summer because of the relationship of the Sun to the Earth at that time of year.12 Moreover, interference with radio astronomy does not depend on the time of day because the glare of the interfering signals beams down all of the time.12

Why is this not a matter for an international body like the United Nations Office of Outer Space Affairs through the Outer Space Treaty?

To be sure, there is a role for international cooperation to ensure a clean atmosphere, safe and shared access to space, and a dark and quiet night sky. But only national regulators can ensure that actually occurs in how they fulfill their obligations regarding shared use of space in national licensing and policy-making decisions. Recent reports from OECD and the UN’s COPUOS working group emphasize the need for a national-level focus on the environmental threats created by mega-constellations.

Expanding the NSF Graduate Research Fellowship Program to Preserve American Innovation

Summary

The U.S. government has identified artificial intelligence (AI), quantum information science (QIS), 5G networks, advanced manufacturing, and biotechnology as the five “Industries of the Future (ITF)”: key technological domains projected to have the greatest impact on advancing national competitiveness in the coming years. Sustained investment in the ITF is crucial to preserving national security, improving American healthcare, advancing towards a green economy, and achieving other societal priorities. Continued progress in the ITF is also necessary for the United States to stay ahead of global economic competitors such as China and the European Union.

However, the United States currently lacks the robust science, technology, engineering, and math (STEM) workforce needed for maintaining ITF leadership. Systemic inequities in the U.S. STEM talent pipeline hinder development of the deep scientific and technological expertise needed for U.S. workers to realize the full potential of the ITF. To address these inequities, the federal government must leverage and invest in its strongest vehicle of American scientific talent: the National Science Foundation (NSF).

By expanding its Graduate Research Fellowship Program (GRFP), the NSF can help build a scientific and technical workforce that fully reflects American diversity and captures the full value that such diversity offers. The result will be a nation in which more students—including the socioeconomically disadvantaged, minorities, women, and those far-removed from academia—have the skills and opportunities to contribute to the Industries of the Future.

Forging 1,000 Venture Scientists to Transform the Innovation Economy

Summary

The US innovation ecosystem is falling behind global players like China and India because our current Research and Development (R&D) landscape does not incentivize commercialization in university laboratories. The federal government should establish the Venture Science Doctorate (VSD) initiative to close this gap by training graduates to combine research and entrepreneurship in legacy sectors. The Biden-Harris Administration should support VSD to turn more metropolitan areas into innovation centers. Swifter shifts from theory to products are “crucial to our future prosperity” as a global leader and as the United States of America, creating opportunities to mitigate rising economic inequality. Executing the VSD will require multiple agencies. The Office of Science and Technology Policy (OSTP) will coordinate the creation of demand-side policies that remove barriers to innovation in legacy sectors. The National Science Foundation (NSF) will coordinate a strategy of regional development through VSD programs, tracking their impact with state-level economic indicators. A multinational collaboration will widen access to talent and distribute US lessons in innovation policy among international regulators in the pursuit of truly global public goods. A stronger science innovation system will recover ground the US has lost to competitors and create compelling partnership opportunities for allies.

This proposal describes a scalable PhD program that brings sector-shaping technologies to market. By bridging NSF programs for scientist training (e.g. I-Corps) and company funding (e.g. Small Business Innovation Research, Small Business Technology Transfer) VSD will support the entire innovation ecosystem. By producing scientists and influencing undergraduate degree choices, VSD will effect targeted and broad-based workforce expansion. By training graduates to create high-value manufacturing companies, job creation in this workforce and supporting sectors will soar. To do this, VSD will use mission-oriented research, complementing basic scientific research with DARPA-like, combinations of training, R&D and commerce. These are the economic experiments our innovation system needs for growth and sustainability in legacy sectors like clean energy. But to share this prosperity we need to start with the states “left behind.”

COVID-19 Presents an Opportunity to Invest in Federal IT Modernization

Summary

COVID-19 has reshaped every facet of our social and professional experiences. What began for almost all of us as a short-term work-from-home event has turned into a prolonged crisis that will have lasting effects on how we interact with each other and do business. Even as vaccine rollouts continue and offices slowly start to reopen, much work will continue to be remote. Employees are likely to work staggered schedules or in predefined groups in order to maintain social distancing for an unknown period of time. Many meetings and tasks that went virtual during the pandemic will likely stay that way. And employers of all types, including governments, will continue to rely heavily on technology to keep employees and customers connected and engaged.

The pandemic accelerated an already rapid ongoing shift to a tech-driven world. As a nation, we must similarly accelerate investments in information technology (IT) to support this new normal. COVID-19 has already exposed critical weakness in existing U.S. IT systems at the federal, state and local levels. Technical problems delayed millions of Americans from receiving unemployment benefits, and are now delaying millions more from receiving timely vaccines. Remote work is raising equity issues and cybersecurity concerns, and periodic internet outages have caused major disruptions to school and work.

The upshot is clear: our investments in IT modernization and cloud computing over the last 10 years have not been sufficient. It’s time to start talking about the next steps the United States can and must take to lead at the federal level, ensuring that our nation’s IT infrastructure and tools can securely and adequately support all remote workers while providing secure, reliable, and state-of-the-art online services.

A Strategy to Blend Domestic and Foreign Policy on Responsible Digital Surveillance Reform

Summary

Modern data surveillance has been used to systematically silence free expression, destroy political dissidents, and track ethnic minorities before placement in concentration camps. China’s surveillance-export system is providing a model of authoritarian stability and security to the 80+ countries using its technology, a number that will grow in the aftermath of COVID-19 as the technology spreads to the half of the world still to come online. This technology is shifting the balance of power between democratic and autocratic governance. Meanwhile, the purported US model is un-democratic at best: a Wild West absent of accountability and full of black box, NDA-protected public-private partnerships between law enforcement and surveillance companies. Our system continues to oppress marginalized communities in the US, muddying our moral claims abroad with hypocrisy. Surveillance undermines the privacy of everyone, but not equally. Most citizens remain unaware of, unaffected by, or disinterested in the daily violence propagated by the unregulated acquisition and use of surveillance. The lack of coordination between state and local agencies and the federal government around surveillance has created a deeply unregulated surveillance-tech environment and a discordant international agenda. Digital surveillance policy reform must coordinate both domestic and foreign imperatives. At home, it must be oriented toward solving a racial equity issue which produces daily harm. Abroad, it must be motivated by preserving 21st century democracy and human rights.