Future deep space missions will benefit from submilliarcsecond angular navigation accuracy (< 25 km projected distance at Neptune). Conventional Very Long Baseline Interferometry (VLBI) measurement strategies entail observations of a radio source (RS) and spacecraft pair. To increase the 3–5 milliarcsecond accuracies currently attainable, instrumental improvements could be coupled with either of two methods: 1) Use improved calibration measurements with the single RS as the spacecraft reference, or 2) use a reference frame established by a local network of RS's near the spacecraft to reduce the contribution of sky-dependent error sources. The demanding baseline vector (earth orientation) and tropospheric calibrations needed to realize submilliarcsecond accuracy with the single-source strategy would not be necessary with the multi-source strategy. The two strategies are compared via a sample covariance analysis. In this analysis, the single-source method yields 1.5 milliarcseconds for the navigation accuracy, while the multi-source method yields 0.5 milliarcseconds.