Once targets are acquired, satellites may be tracked given the predictability of their orbits and ΔV penalties associated with maneuvering, particularly in low Earth orbit (LEO). Wheelon also notes that destroying LEO satellites is not difficult given that it is only necessary to stand in their path to destroy them given high relative velocities. Of course, kinetic attacks are not the only disturbances against which a potential space-based BMD would need to contend.