If you listened closely, you could hear the collective groans of the commercial space community echo through space and time on April 30, 2024. This is the infamous day that the new federal government policy on critical infrastructure (National Security Memorandum 22) was released with nary a mention of space or satellites. For many, this was an affront on the future of the space economy and a plague upon the house of space policy in the United States.
As the stardust settles after the release of NSM-22, the space community should take a moment to see the opportunity it has been presented. While it is true that space has been left out of NSM-22, and it is also likely true that this was a significant oversight, it should not come as a surprise and should give space operators everywhere the motivation they need to seize this moment and shape their own future in critical infrastructure.
A shock to none
There have been great expectations among space economy stakeholders that, one fine day, space would be designated as the 17th critical infrastructure sector as proof positive of its value to our great nation. The issue remains in doubt, but the release of NSM-22 without a single mention of space or satellite infrastructure as an element of terrestrial critical infrastructure, or as a systemically important entity quickly dashed those hopes. This development, however, should have come as a shock to no one, given the perception of space in the critical infrastructure community. A review of the publicly available critical infrastructure documents tells a different story.
Each of the 16 sectors has a sector specific plan that drives how the sector is managed, the newest of which was written in 2016. Of the 16 sectors, only seven mention space at all in their sector specific plan.
Several of those repurpose the language from the communications sector rather than adding something specifically tailored to space. Meanwhile, none of the sectors mention space in their government coordinating council charters or their sector coordinating council charters, with the lone exception of communications.
This quick analysis reveals that, outside of the communications sector, the awareness of the impact of space systems on critical infrastructure is minimal at best and non-existent at worst. Agree or disagree, space is just not in the orbit of those involved in critical infrastructure management and strategy, so it should come as no surprise that NSM-22, written by these very individuals, leaves space out entirely.
Opportunity to shoot for the stars
Had space been named in NSM-22 in any significant way, it would have bound the space community to the parameters of the new policy. While the policy is a welcomed update to a decade-old predecessor, the policy hardly wows with its creative updates and brave initiatives. The sector risk management agency model remains in place and the sectors remain as they were. There are an assortment of studies and directives assigned to various agencies and the role of DHS is solidified. The addition of systemically important entities is new and is noteworthy, but the policy is far from an overhaul of the critical infrastructure policy environment. As such, the inclusion of space would constrain it to a policy framework not designed for the technological advancements, growth potential and geopolitical competition at play in space. Instead, the space community should use this moment to chart a new course. A course unconstrained by terrestrial models and properly catered to the realities and goals of the space economy.
Space Security Memo-1
NSM-22 is signed. The deed is done, and there’s no going back to the president for reconsideration. Wasting time on lamenting exclusion from this policy document will waste time that the security of our space systems cannot afford to lose. Instead, the space community should do what it is well used to doing: going first. Boldly.
No one would deny that space is a harsh and difficult environment in which to operate — so why would we want space to be governed by the same critical infrastructure rules as those on terra firma? The space community now has the unprecedented opportunity to use NSM-22 as an example and mold it to create the kind of governing structure that is right for its operations. From there, space can create its own model of critical infrastructure, like I suggested in previous articles. Ultimately, the space economy will be better off by distancing itself from the largely business as usual NSM-22 and boldly going where no sector has gone before — into the deep space of the creation of a new and up-to-date guiding policy that aligns with the realities of operations in space. NSM-22 provides a template that the space economy can use as it pulls from previously published works on space and critical infrastructure to create new policy, which we could call Space Security Memo-1 (SSM-1).
Involvement and buy-in from the National Space Council would certainly be helpful. But it’s not necessarily required, since Executive Branch policy such as NSM-22 does not apply directly to private entities, but rather to the government agencies that manage the infrastructure. Working together with government partners is the best practice — but having the opportunity to now lead that work is an opportunity that should not be missed.
The exclusion of space from NSM-22 should not surprise anyone nor should the exclusion cause the community to waste time on what might have been. Instead, the space community is freed of a constricting policy document that was not designed for the realities of what is critical in space. Space should endeavor to chart its own path and create a critical infrastructure model for space systems that is independent of terrestrial critical infrastructure models. The two have dependencies, so this does not mean they will be firewalled, but we should all seek to protect our space critical systems in ways that make sense for space — not ways that make sense for power plants in Missouri.
Nick Reese is the cofounder and managing partner of Frontier Foundry, a data and artificial intelligence company based in Washington. He was the director of emerging technology policy at the U.S. Department of Homeland Security from 2019 to 2023.
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