COSMOSIS: The Space Governance Framework That Wants to Add Some Structure to Washington's Chaos

Policy documents from the White House and the Office of Space Commerce this summer finally acknowledged what anyone who has tried to launch a rocket knows: space is complicated. As in, a complex system, the kind that requires adaptive governance rather than the usual bureaucratic slog. A move in the right direction, sure, but one that's still a bit short of the finish line.

Enter the COSMOSIS complex systems approach, a framework developed by M.C. Sungaila, a partner in the Complex Appellate Litigation Group, adjunct professor of Space Law and Policy at LMU Loyola Law School, and an AAA-ICDR panel arbitrator. It's a governance model that would set constraints and boundaries on the space system while letting actors and governance iterate and adapt based on real-world feedback. Because, as we all know, the only constant in space is change - and perhaps the occasional exploding rocket.

The White House Office of Science and Technology Policy (OSTP) chimed in with its July 2026 report, "Science: A New Golden Age," which notes that modern science evolves through feedback loops and iteration. The report recommends federal agencies build a self-improving science enterprise, create intra-agency metascience capabilities, and use regulatory sandboxes to test new tech under controlled conditions. It also suggests weighing benefits alongside risks, which is a novel concept for some regulators.

Before that report, OSTP was already treating emerging tech like AI (including the Genesis Mission), quantum, nuclear, and space as interlocking parts of a single system. Because navigation and power on the Moon will rely on quantum, AI, and nuclear power, and science research will be accelerated by AI and space discoveries. It's all connected, like a cosmic web of paperwork.

The Office of Space Commerce (OSC) Mission Authorization framework also recognizes the complexity of novel space activities. The program aims to streamline licensing decisions across the FCC, FAA, and CRSRA, with OSC as a central node. The certificate program is designed to evolve, with OSC expected to "rapidly iterate its process and refine requirements" based on industry feedback, and ongoing supervision that's "risk informed and proportionate" rather than one-size-fits-all. Because in space, one size fits no one.

To fully implement this complex systems vision, the executive branch needs to expand its governance methods. The COSMOSIS framework offers a way forward, grounded in the Outer Space Treaty and Frank White's Overview Effect. It emphasizes interconnection and stewardship, while encouraging innovation through governance experiments and feedback loops.

The framework has seven components: 1) A focus on interconnection and stewardship, 2) The Cynefin framework for decisionmaking, which categorizes problems as Clear, Complicated, Complex, or Chaotic, 3) Identifying governance levels and polycentric nodes, 4) Treating governance as a living, adaptive system with diversity and redundancy, 5) Building feedback loops and horizon scanning, 6) Conducting retrospectives with multi-dimensional metrics, and 7) Applying complex systems governance principles.

But wait, there's more. The article suggests three ways OSTP and OSC could embrace this framework more fully. First, OSTP should establish a White House-level cross-agency metascience hub, because individual agencies can't see the big picture. Second, OSC should adapt risk factors in response to real-world inputs during the life of a commercial space activity, and include criteria like lunar cultural heritage protection. Third, OSC should create an ombudsperson or mediator role to expedite certification decisions, as other agencies like FERC, USPTO, IRS, and SBA have done. No new Congressional authorization needed, because who has time for that?

In the end, to manage the complex system of space and space law, we need a framework that defines constraints while leaving room for improvisation. COSMOSIS is one such framework, and it should be applied holistically across the Golden Age report and OSC's Mission Authorization program. Because if we're going to govern the cosmos, we might as well do it with some cosmic-level thinking.