Navigation is a key component of interplanetary missions and must continue to be precise with the changing landscape of antenna design. Improvements for the Deep Space Network (DSN) may include the use of antenna arrays to simulate the power of a larger single antenna at much lower operating and construction costs. Therefore, it is necessary to test the performance of arrayed antennas from a navigational point-of-view. This initial investigation focuses on the performance of delta one-way range measurements using a shorter baseline then the current systems uses. With all other parameters equal, the longer the baseline, the better the accuracy for navigation making the number of data packets very important. This trade study compares baseline distances ranging from 1 to 1000 km with an in-use baseline, Goldstone to Canberra, of the DSN. The trade study also compares the direction of the baseline, looking at a due east baseline, a due north baseline and a baseline at 45 degrees east of north. The precision of the baseline systems can be found through a simulated created for this purpose using the Jet Propulsion Lab based MONTE navigation and mission design software tool. The simulation combines the delta one-way range measurements with two-way range and two-way Doppler measurements and puts the measurements through a Kalman filter to determine an orbit solution. Noise is added along with initial errors to give the simulation realism. This study is an important step towards the assessment of the utility of arrays for navigational purposes. The preliminary results have shown a slight decrease in reliability as the baseline is shortened.