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)

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:

• Air pollution: When the satellites in LEO mega-constellations fail or wear out (ranging from soon after launch to five or ten years later), they are designed to vaporize as they reenter our atmosphere. That process releases chemical compounds that linger in the stratosphere and can affect climate change and the ozone layer.8 As those defunct satellites are constantly replaced, the release of pollutants continues. 
• Space pollution: When satellites in mega-constellations collide with existing space debris or with other satellites and rocket bodies, they produce wide-ranging environmental harm in the form of lethal fields of high-speed space junk that persist for decades or more and pollute orbits used by others. Such risks grow with the size of mega-constellations — which threaten far more potential collision events than other satellite systems — and not all collisions can be avoided. Cost/safety tradeoffs that prioritize using large numbers of low-cost, economically expendable satellites over fewer and more reliable satellites increase the risk further: satellites that cannot maneuver cannot avoid collisions. 
• Light and radio-frequency pollution: These unprecedented new uses of space are a source of disruption to critical scientific research that relies on optical and radio-based astronomy. This impairment is caused by light and radio-frequency pollution emitted by large numbers of satellites in LEO constellations. Massive LEO constellations also pose a threat to the continued majesty of the night sky as countless visible light trails from large numbers of these satellites fill the sky, impairing stargazing and astrophotography.

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 Orbit	Allowed Mean Time Between Collisions in Years
1,000	5
5,000	1
10,000	0.5 (180 days)
50,000	0.1 (36 days)
100,000	0.05 (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:

• Increased risk of collisions due to known changes in the orbital environment.
• The risk of collisions with all sizes of space objects (not just those ≥ 10 cm and ≤ 1 cm).
• The continued reliability of command and propulsion capabilities needed to allow satellites to maneuver to avoid collisions.
• The risk of intra-system collisions within any of these mega-constellations.
• Known risks with maneuvering techniques used to attempt to avoid collisions. 

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.

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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

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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.

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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.

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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.

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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

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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.

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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.

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.”

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.

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.

The Biden-Harris Administration should expand the focus of the Department of Energy’s (DOE) Loan Program Office (LPO) to meet the demands of a changing energy industry. The LPO was established to serve as a backstop to private-sector financing for large-scale energy projects with embedded technology risk. The program’s success in scaling large scale power plants and manufacturing plants for next generation energy technologies is well documented. However, the energy industry has changed since the program’s beginning, and the needs for support from the Federal Government have evolved. For example, technology areas that were deemed risky in 2009 are now mature, and in some circumstances, for example in electricity generation, the industry structure that was historically highly centralized has become much more distributed. Modernizing the LPO is a critical means for advancing the Biden-Harris Administration’s climate agenda because the Office supports the development of clean energy projects at commercial scale, leverages private sector capital, and creates middle-class jobs. 

This memo recommends three important changes to the DOE LPO:

1. The aperture of the LPO must be expanded to include a much larger set of technology areas. In particular, energy storage, hydrogen production and carbon capture, utilization and storage, among other nascent fields, should be supported. Authorizing legislation should be changed to give the Program Office the opportunity to support a technological area at its discretion.
2. The Loan Program must reduce the cost of application to incentivize more deployment of smaller projects. This will expand the potential set of projects to be supported and align the Office with overarching trends in the energy sector.
3. The Loan Program should expand its purview to support projects impeded by other financing risks in the energy system. These could include grid modernization, system hardening or smart grid updates (which often do not pass traditional cost-benefit analyses), and electric vehicle infrastructure deployment.

Challenge and Opportunity

The proposed solution solves two impending challenges to the President’s climate agenda. First, while innovation is necessary to meet climate goals, the private sector is reluctant to fund first generation projects for novel clean energy technology. As the US embarks on a pivotal decade with respect to managing the national carbon budget, deploying new technology at scale will become even more critical. In particular, reaching 2050 carbon goals will require successfully innovating in hydrogen production, carbon capture, energy storage, and load-following electric power — most of which cannot be currently supported under the Loan Program’s authorization. Second, the nation’s overall infrastructure deficit has been estimated to require an additional $2 trillion of spending by the American Society of Civil Engineers in their most recent 2017 assessment. In the energy sector, ASCE estimated the requirement for additional electricity infrastructure alone to be $177 billion. Simultaneously, the economic returns to investing in our nation’s infrastructure are significant. Recent studies suggest that for every $1 million invested in energy infrastructure, the Recovery Act created 15 durable jobs. The multiplier effect from infrastructure spending varies based on economic conditions, but as the country emerges from the COVID-19-induced recession, enabling the LPO to fund a broad swath of energy infrastructure would be a viable asset for job creation in the coming years.

Currently, the LPO is restricted to financing only the first three deployments of new technologies, and new technologies that are highly capital intensive, such as concentrated solar power. The LPO exists to absorb financing risk for the private sector, risks which often stem from capital intensity or technology uncertainty. As we consider the energy transition in the coming decades, a new set of technologies needs support for initial commercial deployment. Additionally, however, a broad array of infrastructure investments continue to go unfunded by the private sector for other reasons as well, particularly in geographies where commercial markets for offtakers are not fully developed. Expanding the technology and stage aperture of the LPO to include a broader array of projects would attract private capital and accelerate the transition to a decarbonized future.

Plan of Action

The Biden-Harris Administration should expand the DOE’s Loan Program Office (LPO) to enable the Federal Government to quickly make investments in a broad range of infrastructure categories through the pre-existing contracting authorizations at the LPO. Accordingly, we propose three changes to the DOE’s LPO. First, the technology aperture of the Loan Program should be expanded to include a broader set of technologies, including but not limited to energy storage, hydrogen production, carbon capture, utilization and storage, and carbon dioxide removal. Program staff should be granted the flexibility to support a wide range of technology areas at their discretion, in a manner not dissimilar to ARPA-E in the breadth of technical fields within staff purview.

Second, the Loan Program must be adjusted to account for a more distributed energy industry by reducing the cost of application and the corresponding size of project to be supported. For example, the first deployment of a novel grid-scale energy storage technology could be financed at the $10+ million level rather than the $100+ million level. A company looking to deploy that technology would be currently discouraged from applying as a result of the upfront cost of application. The Loan Program should support projects across the capital scale, with flexible application requirements depending on the order of magnitude of public support being requested. 

Finally, the Loan Program should expand to support projects impeded by other financing risks in the energy system. These risks could include high-risk project cash flows from uncertain offtake agreements, as for example with public transportation infrastructure or grid modernization, system hardening, and electric vehicle infrastructure deployment. A comprehensive list of infrastructure to support should include:

• Existing planned projects and deferred maintenance on public transit systems;
• Identified grid modernization or hardening programs in state resource plans;
• Accelerated smart grid expansion;
• Building retrofits for both energy efficiency and carbon emissions reduction;
• Electric charging stations; and
• Addressing methane leakage in pipeline systems.

Conclusion

At the Roosevelt Project, we are developing action plans for communities that experience significant industrial upheaval, particularly in the context of forthcoming energy transitions. Though these transitions will vary in their nature as a result of local socio-economic realities, access to or distance from natural resources, and exposure to various climate risks, the transitions will most acutely affect communities of working-class, low-income, under-educated Americans. Federal support for the deployment of shovel-ready energy infrastructure can support the creation of high-quality jobs. For infrastructure deployment to positively contribute to both decarbonization and job creation, projects must be targeted to regions that are likely to be affected by the transition. The adjustments to the DOE LPO proposed here offer one important tool for quickly deploying infrastructure in the next four years.

Summary

The United States leads the world in the market share – and ‘mindshare’ – of massive digital platforms in domains such as advertising, search, social media, e-commerce, and financial technologies. Each of these digital domains features one or two dominant market players who have become big through the ‘network effect,’ wherein large volumes of customer activity provide data inputs to make these platforms work even better. However, the gains that big players enjoy from the network effect often come at the expense of the platform’s customers. The network effect is further amplified by platform lock-in, whereby new platforms are unable to interoperate with existing market players. A more serious risk manifests when the dominant platform provider provides the same services as that of businesses using the platform, thus becoming a competitor with a built-in information advantage. This prevents new entrants to the market from growing big, limiting the choices available to consumers and creating the conditions for harmful monopolies to emerge.

Therefore, the Biden-Harris Administration should advocate for legislation and enact policies designed to bring openness and transparency into the digital platforms marketplace. A key aspect of such policies would be to require a set of interoperability standards for large digital platforms. Another would be to require open Application Programming Interfaces (APIs) that allow customers (end-users as well as businesses) to seamlessly take their data with them to competitors. These actions will unleash greater competition in the digital marketplaces that are becoming the mainstay of the US economy and increase transparency, choice and opportunities that the US consumer and businesses can benefit from.

Summary

The United States is an invention and innovation powerhouse that has long produced remarkable achievements. Yet American invention is at a crossroads today. After more than a half-century of unrivaled global leadership in basic science, innovation, and manufacturing, the U.S. is losing ground throughout the innovation pipeline across a wide range of sectors. The COVID-19 pandemic has exposed this vulnerability, making brutally clear the need for innovation to address major challenges that arise and highlighting weaknesses such as our dependency on global supply chains. A strong Invention Ecosystem can power our path to economic recovery, sustained growth and societal resilience.

This report explains the functions of the Invention Ecosystem, presenting a framework that highlights the ecosystem’s main components and the inventor and innovation pathways that 1) inspire and prepare students and future inventors to address crucial challenges and thrive and support the innovation economy, and 2) build and sustain today’s inventors and entrepreneurs to enable value creation from their ideas in the form of products and businesses. These pathways together will yield a pipeline of people and businesses that create jobs, foster resilient economies, and produce solutions to our most pressing challenges.

The ecosystem is outlined in four sections, represented by its distinct pillars including K-12 education, higher education, entrepreneurship and industry. Each section describes the role of the pillar, features specific challenges related to the ecosystem, and offers a set of discrete policy recommendations for a policymaker audience to extract and optimize the full value of U.S. innovation.

This report was produced by the Day One Project with support from the Lemelson Foundation.

Summary

Comprehensive and reliable mortality data is vital for public health research. Improving our infrastructure for managing these data will generate insights that promote longevity and healthy aging, as well as enable more effective response to rapidly evolving public health challenges like those posed by the COVID-19 pandemic. A modernized mortality data system will ultimately be self-sustaining through access fees, but will require federal investment to update state reporting infrastructure and data use agreements. The Biden-Harris administration should launch an effort to modernize our nation’s infrastructure for aggregating, managing, and providing research access to mortality data.

Summary

Developed during a different industrial era, today’s education system was never designed to meet modern learners’ needs. This incongruity has heaped systemic problems upon individual educators, blunted the effectiveness of reforms, and shortchanged the nation’s most vulnerable young people — outcomes exposed and exacerbated by COVID-19. Building back better in a post-pandemic United States will require federal investments not only in schools, but in “learning ecosystems” that leverage and connect the assets of entire communities. Tasked with studying, seeding, and scaling these ecosystems in communities across the country, a White House Initiative on Community Learning Ecosystems would signal a shift toward a new education model, positioning the United States as a global leader in learning.

Summary

The coronavirus pandemic has forced a sudden acceleration of a prior trend toward the virtual provision of healthcare, also known as telemedicine. This acceleration was necessary in the short term so that provision of non-urgent health services could continue despite lockdowns and self- isolation. Federal and state policymakers have supported the shift toward telemedicine through temporary adjustments to health benefits, reimbursements, and licensure restrictions.

Yet if policymakers direct their attention too narrowly on expanding telemedicine they risk missing a larger—and as yet mostly unrealized—opportunity to improve healthcare in the United States: increasing the overall share of health services provided directly to the home. At-home healthcare includes not only telemedicine, but also medical house calls (home-based primary care) as well as models in which individuals within communities offer simple support services to one another (i.e., the “village” model of senior care, which could be extended to included peer- to-peer health service delivery). The advent of “exponential” technologies such as artificial intelligence (AI), blockchain, and the Internet of Things (IoT) is unlocking new possibilities for at- home healthcare across each of these models.

The next administration should act to reduce four types of barriers currently preventing at-home healthcare from reaching its full potential:

1. Labor-market barriers (e.g., unnecessarily restrictive scope-of-practice rules and requirements for licensing and certification)
2. Technical barriers (e.g., excessively slow and burdensome processes for regulatory approval, weak or absent standards for interoperability)
3. Financial/regulatory barriers (e.g., methodologies for determining eligibility for reimbursements that favor incumbents over innovators)
4. Data sharing / interoperability barriers (e.g., overly restrictive constraints related to data privacy and portability)

The surge in education technology use in response to COVID-19 represents a massive natural experiment: an opportunity to learn what works at scale, for which students, and under which conditions. However, without the right data standards in place we risk incomplete or inaccurate inferences from this experiment.

The COVID-19 pandemic has dramatically increased use of educational technologies. There is evidence that this “emergency onlining” will lead to learning loss, especially among underserved communities. To understand and address the extent of learning loss—as well as to explore and support potential future uses of educational technologies—the U.S. Department of Education (ED) must systematically implement established open-data standards that allow us to understand how students engage with learning technologies. Widescale implementation of these standards will make it possible to combine and analyze validated data sets generated by multiple technologies. This in turn will provide unprecedented, on-demand reporting and research capabilities that can be used to precisely identify gaps and create targeted interventions. Specifically, we recommend that ED mandate the use of the open Experience API (xAPI) standard for educational technology purchased with federal funds. We further recommend that ED invest time, talent, and resources to further develop this standard and pilot efforts to leverage educational-technology data for insights through the Institute for Education Sciences (IES) and other agencies.

Challenge and Opportunity

The COVID-19 pandemic rapidly forced schools across the country to close physical campuses and convert all instruction to an “emergency online” modality for much of 2020. The situation will likely persist well into 2021. The emergency shift to online teaching meant that many teachers had insufficient preparation to successfully adapt classroom-teaching methods for digital formats. Moreover, many students—especially those from low-income families or from historically underserved racial and ethnic groups—lack access to high-speed broadband and technology assets needed to fully participate in online learning. These factors are combining to create learning losses that exacerbate our existing digital divides that may persist for years.

Robust educational research and development is needed to fully understand the extent and distribution of learning loss, as well as to develop interventions for addressing it. Educational technologies—which record all student interactions, from logins to mouse-clicks to assignment submissions—could provide a wealth of data on how online education is succeeding and/or falling short. Unfortunately, these data are frequently recorded in a way that is unique to each application. This lack of consistency makes it difficult to integrate educational data or make comparisons between institutions

The time is ripe to introduce new requirements for learning technology designed to ensure that parents, educators, administrators, and stakeholders at every level can assess where students are at, what they know, and what will best help them to advance. These insights could also significantly reduce the day-to-day demands on teachers’ time and attention, enabling them to focus on deeper student questions. The technology needed to implement such requirements are already available in the open-source xAPI standard, which is currently in the final stages of approval as an IEEE standard. Further, there are xAPI “profiles” that define specific data requirements for processes common to educational technologies, such as playing a video. While the concept of a learning-data standard was recommended by ED as early as 2015, adoption has been uneven in practice. This situation must change for us to immediately address COVID19 learning loss as quickly and accurately as possible.

Plan of Action

To address the challenges outlined above, we recommend including xAPI as a federal procurement requirement to encourage adoption among educational software and service providers. Widespread adoption will mean that most—if not ultimately all—providers consistently and automatically generate only the educational data that conforms to standards established by ED. Establishing consistent standards for educational data will make it easier for all parties to contribute meaningfully to key datasets, and for researchers to develop tools to track and exchange meaningful data. These outcomes together will deliver deeper understandings of how our nation’s students are doing, inform efforts to close achievement gaps, and facilitate tracking of changes over time. We also recommend investing ED time, talent, and resources into further developing the xAPI standard and participating in pilot projects that demonstrate its utility. Each of these recommendations is detailed further below.

Recommendation 1. Mandate use of the xAPI standard for ED-funded procurement.

We recommend that ED mandate use of xAPI for all educational technology purchased through ED directly as well as through federal grants. ED should also establish a process for ensuring compliance, including conducting conformance tests on educational software and services from different providers.

The IEEE is in the final stages of publishing the open-source xAPI standard. Mandating its adoption would demonstrate cutting-edge ED leadership. Widespread adoption of the standard will provide a common approach to collecting evidence about how students, parents, and teachers interact with education platforms, paving the way for much more rigorous, consistent, and reliable educational research.

Recommendation 2. Develop xAPI profiles to facilitate data integration and improve data quality for the educational sector.

IEEE is standardizing documents that help automate the data governance needs for a type of educational solution (“application profiles”). Standards developers are rarely familiar with learning sciences and educational research. As a result, xAPI profiles will tend to be general in nature unless domain-specific experts get involved. For instance, medical experts have worked to develop the MedBiquitious xAPI Profiles for Medical Education. Human-resources experts have developed the Human Resources Open Standards (HROS) xAPI Profile and, and work is ongoing for an Assessment xAPI Profile that supports the U.S. Chamber of Commerce T3 initiative.

ED should invest time, talent, and funding to develop xAPI profiles that are aligned with current research and national priorities. An xAPI Profile effort could help to normalize data collection from a spate of popular 5th grade mobile math applications, that properly identify the relevant ED standards, competencies or objectives are challenged by a student, which could provide such app developers with the automation that would simplify generating better, aligned data. Works like this could change online classrooms into opportunities to embed better pedagogy into practice at scale.

Recommendation 3. Invest in applied research and development.

ED should partner with schools and educational technology companies to invest in applied research that demonstrates insights from standardized educational data. ED should also work with partners to invest in public repositories of code to make it easier for all stakeholders to leverage insights. Such investments should focus both on the short term (e.g., providing immediate insights about use of educational technology and learning loss during the COVID-19 pandemic) and long term (e.g., providing examples of potential applications that could be scaled and replicated in the future). Such investments would not only advance our understanding of education, but would also help to develop a market for further development of data-based educational products. IES and ED’s Office of Educational Technology should partner to identify topics and approaches to conduct this cutting-edge research.

There are multiple examples of research using educational-process data that these investments could build on. IES recently issued a request for proposals (RFP) to use National Assessment of Educational Progress (NAEP) process data to identify students with disabilities, to understand how those student use available accommodations, and to determine which are most successful. Predictive models of student dropout risk, course design analytics to identify areas for improvement, and course-taking patterns are all being conducting using this data at relatively small scale through academic societies, such as the Society for Learning Analytics Research (SoLAR) and the International Educational Data Mining Society. All stand to benefit and leverage this data to dramatically improve research.

SoLAR recently published a position paper describing current challenges with these data.4 Larger educational-research societies such as the American Educational Research Association (AERA) and the National Council on Measurement in Education (NCME) have launched specialized groups focused on working with educational-process data.

By investing in this area, ED could help to nurture this area of research and make a difference in the lives of students, parents, teachers and schools across the country. This approach would help to motivate better data quality and enable technologists to build more robust learning applications, thereby helping us to stem the COVID-19 learning loss as quickly as possible using contemporary science and technology.