ANALYSIS of ALTERNATIVES and SOCIO-ECONOMIC ANALYSIS Legal Name of Applicant(S): Euro Cryospace France Submitted By: Euro Cryosp

ANALYSIS OF ALTERNATIVES

and

SOCIO-ECONOMIC ANALYSIS

Legal name of applicant(s): Euro Cryospace France

Submitted by: Euro Cryospace France

Prepared by: REACHLaw Ltd

Substance: Chromium trioxide [EC 215-607-8, CAS 1333-82-0]

Use title: The use of chromium trioxide for the surface preparation of aluminium alloy cryogenic tanks used in the Ariane 5 launcher

Use number: 1 ANALYSIS OF ALTERNATIVES and SOCIO-ECONOMIC ANALYSIS

CONTENTS

LIST OF ABBREVIATIONS ...... 7

DECLARATION ...... 9

1. SUMMARY ...... 10

2. AIMS AND SCOPE OF THE ANALYSIS ...... 12

2.1. Aims of the Analysis ...... 12

2.2. The applicant ...... 12

2.3. Space sector products and the Supply chain ...... 13

2.3.1. Launcher systems ...... 13

2.3.2. Supply chain characteristics ...... 15

2.3.2.1. The supply chain ...... 15

2.3.2.1.2. Heritage ...... 17

2.3.2.2. Standards ...... 18

2.3.2.2.1. Space programme ...... 18

2.3.2.2.2. Technology Readiness ...... 19

2.3.2.2.3. Overview of the Key Steps to Industrialisation ...... 19

2.4. Scope ...... 20

2.4.1. Geographical scope ...... 20

2.4.2. Temporal scope ...... 21

3. APPLIED FOR “USE” SCENARIO ...... 21

3.1. Analysis of substance function ...... 21

3.2. Reasoning for the choice of material...... 22

3.3. Market and business trends including the use of the substance ...... 23

3.3.1. The General Space Market ...... 23

3.3.2. The Applicant’s Space Market and Trends ...... 24

3.4. Annual tonnage ...... 24

3.5. Remaining risk of the “applied for use” scenario ...... 24

3.6. Human health and environmental impacts of the applied for use scenario ...... 25

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3.6.1. Number of people exposed ...... 25

3.7. Monetised damage of human health and environmental impacts ...... 26

4. SELECTION OF THE “NON-USE” SCENARIO ...... 27

4.1. Efforts made to Identify Alternatives ...... 27

4.1.1. Research and development ...... 27

4.1.2. Data searches ...... 28

4.1.3. Assessment of shortlisted alternatives ...... 28

4.1.3.1. Alternatives scope ...... 28

4.1.4. Identification of known alternatives ...... 28

4.1.5. Nitro-Sulfo-Ferric Acid ...... 29

4.1.5.1. Substance ID, properties, and availability ...... 30

4.1.5.2. Technical feasibility of NSF ...... 30

4.1.5.3. Economic feasibility and economic impacts of NSF ...... 31

4.1.5.4. Availability of NSF ...... 31

4.1.5.5. Hazard and risk of NSF ...... 32

4.1.6. Conclusions on NSF ...... 32

4.2. The most likely non-use scenario ...... 33

4.2.1. The applicant’s non-use scenario ...... 33

4.2.2. Launcher manufacturer’s non-use scenario ...... 34

4.2.3. Launch service provider’s non-use scenario ...... 35

5. IMPACTS OF GRANTING AUTHORISATION ...... 35

5.1. Economic impacts ...... 36

5.1.1. Economic impact on the space sector companies ...... 36

5.1.2. Conclusion of the economic impacts ...... 39

5.2. Human Health or Environmental Impact ...... 39

5.3. Social impacts ...... 39

5.4. Wider economic impacts ...... 40

5.5. Distributional impacts ...... 43

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5.6. Uncertainty analysis ...... 44

6. CONCLUSIONS ...... 45

6.1. Comparison of the benefits and risk ...... 46

6.2. Information for the length of the review period ...... 46

6.3. Substitution effort taken by the applicant if an authorisation is granted ...... 47

APPENDICES ...... 50

Appendix 1 – Definitions ...... 50

Appendix 2 – Statistics ...... 51

Appendix 3 – The ESA Convention ...... 51

Appendix 4 – Space Programme Implementation and Development ...... 52

Appendix 5 – Technology Readiness Level definitions ...... 54

Appendix 6 – Technology Readiness Levels ...... 55

Appendix 7 - General time-frames for technology development and exploitation time of space vehicles ...... 56

Appendix 8 – Overview of impacts (year by year) ...... 57

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TABLES Table 1. Sales breakdown by segments (public/institutional and private/commercial market) ...... 24 Table 2. Estimated Concentration of Ground-Level Cr (VI) expressed as a percentage to the level at 100 meters from the factory ...... 25 Table 3. Monetised excess cancer impact ...... 26 Table 4. Health impacts based on estimated excess fatal cancer incidences ...... 27 Table 5. List of data sources used in the preparation of the report ...... 28 Table 6. NSF formulation ...... 30 Table 7. Conclusions on NSF ...... 32 Table 8. Overview of impacts ...... 36 Table 9. Economic impact on the applicant ...... 37 Table 10. Economic impact on the launcher manufacturer ...... 38 Table 11. Summary of the economic impacts ...... 39 Table 12. Distributional Impacts ...... 43 Table 13. Values use in the main analysis and sensitivity analysis ...... 44 Table 14. Changes in shutdown period ...... 44 Table 15. Changes in missed launches ...... 44 Table 16. Changes in impacts with 10 % discount rate ...... 45 Table 17. Comparison of the Benefits and Risks ...... 46

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FIGURES

Figure 1. Ariane 5 launcher structure with the EPC, which contains the cryogenic tanks produced by Euro Cryospace France, towards the bottom ...... 13 Figure 2. Chromium Trioxide supply chain ...... 15 Figure 3. A simplified overview of the flow of Chromium Trioxide in space industry ...... 16 Figure 4. Key steps in the implementation of new technologies in the space sector ...... 20 Figure 5. Les Mureaux in France ...... 21 Figure 6. Treatment process for the Aluminium used in production of the cryogenic tanks. Chromium trioxide is introduced during spraying at the pickling step ...... 22 Figure 7. Overview of the non-use scenarios...... 33

Use number: 1 Legal name of the applicant(s) Euro Cryospace France

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LIST OF ABBREVIATIONS

°C Degrees Celsius % Percent Cr6+, Cr (VI) Chromium in its hexavalent state A5 Ariane 5 Launcher A6 Ariane 6 Launcher Annex XIV Chemicals requiring authorisation under REACH AoA Analysis of Alternatives B Billion CAS Chemical Abstracts Service

CrO3 Chromium trioxide CSR Chemicals Safety Report EC European Commission ECHA European Chemicals Agency EEA European Economic Area e.g. For example EPC Etage Principal Cryotechnique/ Main Cryogenic Stage ES Exposure Scenario ESA European Space Agency ESC Etage Supérieur Cryotechnique / Upper Cryogenic Stage etc. et cetera (and the rest) EU European Union EUMETSAT European Organization for the Exploitation of Meteorological Satellites FCSP Euro Cryospace France (GIE) GEO Geostationary Orbit (36 000 km above the Earth's equator) GmbH Gesellschaft mit beschränkter Haftung GPM Gaussian Plume Model GTO Geostationary Transfer Orbit i.e. id est (that is) ISO International Standards Organisation K Kelvin LEO Low Earth Orbit (altitude between 160 km and 2000 km)

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NASA National Aeronautics and Space Agency M Million m Metre m2 Metre Squared m3 Metre Cubed m3/h Metre Cubed per hour MEO Medium Earth Orbit (altitude between 2000 km and 36 000 km) REACH Registration, Evaluation, Authorisation and Restriction of Chemicals SAS Société par Actions Simplifiée SEA Socio-Economic Analysis SME Small and Medium Sized Enterprise SVHC Substances of Very High Concern t Tonne TRL Technology Readiness Levels UK The United Kingdom US United States of America WCS Worker Contributing Scenario

Use number: 1 Legal name of the applicant(s) Euro Cryospace France

ANALYSIS OF ALTERNATIVES and SOCIO-ECONOMIC ANALYSIS

1. SUMMARY

This report examines the potential alternatives for chromium trioxide (CrO3) in surface preparation of aluminium alloys and the socio-economic aspects of its replacement. Information for the report was collected from the applicant and its customer through survey and interview.

The applicant, Euro Cryospace France, is applying for Authorisation for the use of chromium trioxide in the surface preparation of aluminium alloys used on cryogenic tanks for the Ariane 5 launcher. The chromium trioxide allows the formation of high adhesive metallic oxide layers on the aluminium alloys used to construct the cryogenic tanks. The cryogenic tanks manufactured by the applicant are used to store liquid oxygen and liquid hydrogen which are used for cryogenic propulsion.

The tanks are treated in large enclosed spraying tunnel which is controlled from outside at a central console. After surface preparation, tanks are rinsed with cold and hot water. The purpose of this post treatment process is to remove all chromium from the tank's surface. At the end of the process, there are no traces of chromium trioxide but only trace amounts of Al Cr complex. Smaller flying parts are also treated in a pilot-scale system, which is an enclosed spraying cabinet under identical process and operating conditions to the large-scale treatment. The highest potential for exposure is during the weighing and loading of the substance to the chemical tanks of the installation and during waste water management and maintenance tasks.

The environmental releases are low as all waters are treated on-site and the effluent is recycled back into the process. Air emissions are treated with demisters. The worker exposure is monitored by personal and static sampling. Both the spraying tunnel and cabinet are closed which keeps the exposure levels very low. During tasks with higher exposure potential workers wear extensive PPE including chemically resistant suits and motorised respirator hoods in order to minimise exposure. Surface preparation is performed infrequently; maximum 24 days per year for the cryogenic tanks and maximum 16 days per year for the pilot-scale treatment.

Alternatives for the use of chromium trioxide on cryogenic tanks must meet several critical properties:  Satisfactory adhesion of the gluing primer on the metallic surface after preparation under cryogenic conditions;

 No corrosion generated by the substance used for surface preparation. For each critical parameter above, standard testing procedures are in place to ensure consistency and repeatability. Any alternative must provide:

 A process that does not induce any surface defect that may affect flight worthiness and/or launch performance;

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 The tanks must meet the technical requirements of the Ariane 5 launcher and the qualification status which has been approved by the whole customer chain.

In the AoA we demonstrate that the alternative surface preparations are not suitable for this use as they do not meet the technical criteria required, despite the efforts of the applicant, the space agencies and the launcher manufacturer.

If the applicant could no longer use chromium trioxide, they would have to stop its production activities entirely for 24 months. This would result in substantial loss of value added for the applicant and its supply chain. The total monetised impacts of the non-use scenario are a cost of approx. EUR 290 million during the applied for review period. However, this cost only represents those socio-economic impacts that are easily quantifiable. On a larger scale the non-use scenario may lead to layoffs and the specialized and skilled workforce leaving Europe. The EU would lose its competitiveness in the global space market and the EU’s independent access to the Space may be jeopardized.

The main benefit of the non-use scenario is the reduced exposure to a carcinogenic substance. The health impacts on workers and the general population related to the carcinogenicity due to the use of chromium trioxide by the applicant ranged from EUR 15 to 25 during the applied for review period.

By comparing the human health impact with the socio-economic impacts, the report finds that the socio economic benefit of the applicants’ continued use of chromium trioxide outweighs the risks to human health and the environment. This conclusion is further supported by an uncertainty analysis.

In conclusion, Euro Cryospace France produces tanks that are critical to the operation of the Ariane 5 launcher. Should chromium trioxide be unavailable for this use in the surface preparation on the cryogenic tanks a production stoppage will occur that will have a knock-on effect along the supply chain; from other components sub-contractors, the launcher manufacturer, the launch service provider, the EU’s access to space, and on the satellite manufacturers. Based on the needs of the Ariane 5 launcher programme, a timeframe of 7 years after the sunset is requested.

Use number: 1 Legal name of the applicant(s) Euro Cryospace France

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2. AIMS AND SCOPE OF THE ANALYSIS

2.1. Aims of the Analysis

Chromium trioxide (CrO3) (EC 215-607-8; CAS 1333-82-0) is subject to Authorisation because it contains chromium in its hexavalent (Cr6+, Cr (VI)) oxidation state. It is classified as carcinogenic (category 1A) and mutagenic (category 1B). It is not considered a threshold substance and, therefore, the adequate control of risks arising from the applied for use of the substance cannot be demonstrated in accordance with Annex I, section 6.4 of Regulation (EC) No 1907/2006.

The application for use of chromium trioxide is for the surface preparation of aluminium alloys used on cryogenic tanks for the Ariane 5 launcher. The chromium trioxide allows the formation of high adhesive metallic oxide layers on the aluminium alloys used to construct the cryogenic tanks. The cryogenic tanks manufactured by the applicant are used to store liquid oxygen and liquid hydrogen which are used for cryogenic propulsion. Cryogenic propulsion allows for better launcher performance, compared to storable propellants.

The aim of this report is to demonstrate that there are no suitable alternative substances or technologies for the use applied for and that the socio-economic benefits of continued use of chromium trioxide outweigh the risks to human health and the environment.

2.2. The applicant The applicant, Euro Cryospace France, is a ”Groupement d’Intérêt Economique” (French company legal structure similar to a Joint Venture legal structure) owned by two members companies Air Liquide Advanced Technologies & Airbus Safran Launchers.

Euro Cryospace France is located in the Yvelines department in the Île-de-France region in north-central France and is a subcontractor of Airbus Safran Launchers SAS & Airbus Safran Launchers GmbH.

The applicant is applying for the continued use of the substance for the surface preparation of cryogenic tanks used in the Ariane 5 launcher’s EPC (Etage Principal Cryotechnique/ Main Cryogenic Stage) & ESC H2 tank (Etage Supérieur Cryotechnique / Upper Cryogenic Stage).

The EPC Tank is about 23 m high with a diameter of 5.4 m. When empty it weighs only 6 tonnes and approximately 180 tonnes when full of propellant. The upper compartment contains 149 tons of liquid oxygen and has a total capacity of 135 m3, while the lower compartment contains 26 tons of liquid hydrogen and has a capacity of 375 m3.

The ESC H2 tank is about 4 m high with a diameter 5.4 m. When empty it weighs 2 tonnes and approximately 4.5 tonnes when full of propellant.

The tanks are only a few millimetres thick. Given the structural characteristics of the main stage of the launcher, when the tanks are empty they have to be pressurised to prevent them buckling under their own weight.

Use number: 1 Legal name of the applicant(s) Euro Cryospace France

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Figure 1. Ariane 5 launcher structure with the EPC, which contains the cryogenic tanks produced by Euro Cryospace France, towards the bottom

2.3. Space sector products and the Supply chain Eurospace recognizes 4 main product segments: launcher systems, satellite systems, scientific systems/probes and ground systems/services. The European space sector provides launch services through Arianespace.

Satellite systems, scientific systems/probes and Ground systems/services are not in the scope of this application. Launcher systems are explained in the next section.

2.3.1. Launcher systems Space programme development is a highly political decision. Large investments (e.g. developing Ariane 5 cost 5B €) over long periods of time from EU governments are supporting the EU’s independent access to space.

The launcher industry can be divided into two categories:  Launcher development activities; mainly funded through ESA and other governmental agencies, with the aim of consolidating and improving existing technologies as well as

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promoting the development of new technologies. There are currently two launcher systems developed and manufactured by the European space industry: Ariane and Vega. Soyuz launchers, manufactured in the Russian Federation, are also launched from the European spaceport.

This application is solely concerned with the use of chromium trioxide on the cryogenic tanks of the Ariane 5 launch systems.

The next generation of European launchers (A6) is currently in the design phase of development. These are being designed to cover numerous missions: Low Earth Orbit (LEO), Geostationary Orbit (GEO), Polar/Sun-synchronous orbit (SSO) and Medium Earth Orbit (MEO) and Mars Transfer Orbit (MTO). The final decision on the development of these A6 systems was taken at the Council at Ministerial level on 2nd of December 2014.

Furthermore, test flights of the Ariane 6 will take place in the next 4-5 years with a requirement for 2 successful test flights before the launcher will be used for any missions, commercial or otherwise.

Development cycles for a new launcher system are between 5 and 10 years, depending on the programme. These long development programmes lead to a standardised launcher configuration that will be used for as long up to 30 years, while some of the individual systems within launchers, e.g. engines, can remain broadly unchanged for longer.

Once a launcher design is finalised actual production begins. Building a launcher takes approximately 2 to 3 years.

Launcher systems are standardised once validated by all the necessary reviews, associated testing & approvals, and finally proven during the adequate number of test flights (2). Once validated, the standard is produced with the aim of not implementing changes to protect the validity of the qualification status. Any changes to the existing technology will require system/subsystem redesigns and/or manufacturing engineering, evaluation of impact by the whole customer chain. It will consequently need to return to design and/or manufacturing engineering phases and satisfy again to the qualification loop, i.e. reviews, test, and customer chain approvals.

The costs associated with above mentioned actions are high and typically in the order of several millions of Euro (dependant of the actual modifications and associated impacts).

 Operational launcher systems and parts are sold to launcher integrators and then on to launch services operators e.g. Arianespace. Arianespace operates from the European spaceport in Kourou, French Guyana.

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Arianespace’s services are sold to customers worldwide. In 2014, launcher systems represented 19.5 % of the total sales of the European space industry. The Ariane and Vega family of launchers support the core business of Arianespace, together making up more than 93 % of the total mass launched since 2011 (which was the first year of operations of Soyuz in the European spaceport). The remainder was launched with the Soyuz launcher.

Arianespace is not the only launch services provider. Competition for the space launch market from the non-EU manufacturers like e.g. US based Space-X, Russian, Chinese and Indian manufacturers has intensified in the last decade; moreover other territories do not prohibit the use of Cr (VI) treatments on launchers. Should Ariane 5 fail to be available, the European space industry will face becoming uncompetitive, driving both commercial and institutional satellite owners to the non-European competition. This will hamper the European ability to access space until a qualified alternative can be put into production or Ariane 5 is retired from service and replaced. It also has the potential to damage the reputation of the European space industry to deliver launchers and launch services.

2.3.2. Supply chain characteristics The space manufacturing industry is an infrastructure supplier. The sector operates at the higher end of the space value chain and supplies service providers and public institutions with launchers and space vehicles to meet their specific requirements.

2.3.2.1. The supply chain The supply chain consists of several layers. This is outlined in Figure 2 below.

Figure 2. Chromium Trioxide supply chain

Subcontractors on Level 2 often offer several specialist services and products for the prime level companies. These can include launcher structures, satellite structures, separation systems, mechanisms and mechanical equipment, digital electronics for satellites and

Use number: 1 Legal name of the applicant(s) Euro Cryospace France

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launchers, satellite communication equipment, satellite instruments, space mission analysis, systems engineering and project management through engineering services, assembly and integration, and support testing at the launch site. They can also design, develop, manufacture and market solid rocket motors, energetic materials and raw materials, thermostructural and organic composite materials for the aerospace, aeronautics and automotive industries.

For the production of Ariane 5 launchers, Euro Cryospace France works as a sub-contractor of Airbus Safran Launchers. The prime contractor offers complete launcher services to the space client, who in this case is Arianespace. Euro Cryospace France is specialized in providing the cryogenic tanks for the Ariane 5 launcher, which is its only activity. For chromium trioxide, the applicant uses a formulation manufactured and supplied by one formulator which possibly could import CrO3 from non-EU countries. A simplified overview of the flow of Chromium Trioxide in space industry is given in Figure 3.

Airbus Safran Launchers is the European prime contractor for civil and military space transportation and orbital systems specialist. It designs, develops and produces launchers like Ariane, the ATV cargo vessel for the International Space Station, atmospheric re-entry vehicles, ballistic systems, propulsion systems and space equipment.

Arianespace is the international leader in commercial launch services provider, and today holds an important share of the world market for satellites launched to the geostationary transfer orbit (GTO). Arianespace, as a unique commercial operator, oversees the marketing and sales, production and operation from CSG (Kourou) of Ariane, Soyuz and Vega launch vehicles. Ariane 5 is the world’s most reliable launcher with highest number of successful consecutive launches.

Figure 3. A simplified overview of the flow of Chromium Trioxide in space industry

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2.3.2.1.1. The ESA Convention All of the assembly and integration activities for the space industry takes place within Europe due to the political nature of the sector. There are specific laws, regulations and multilateral agreements on what can/should be produced and where. The space sector has, consequently, a very limited ability to rely on non-European facilities for supply. ESA projects (like Ariane launchers) are governed by the ESA convention which, in particular, imposes geographical return rules which play an important role in the setup of the supply chain for those projects. For more information please see Appendix 3.

2.3.2.1.2. Heritage Heritage involves using the experience of parts and technologies from previous missions to give credibility and confidence in the performance of this technology for future missions. Worker knowledge and know-how can also be considered heritage as experience gained over many years can be applied in different programmes. Heritage, consequently, may involve, for example, the use of the same material under a comparable space environment or exposure, treated by the same people under similar conditions.

In the launcher industry the concerns about the heritage of systems, sub-systems and components in launchers are extremely important. After the development stage the system configuration is fixed with every system in one launcher being identical to the next, meaning that the configuration for the operational systems is rather rigid with little flexibility provided in change situations.

An example for the importance of heritage is given by the introduction of the Ariane 5 launcher. When Ariane 5 was developed, in 1996, the initial test flights failed. This resulted in the continuation of the Ariane 4 programme, which had its first launch in 1990 and continued in service until 2003. There was an overlap of 7 years where there was the potential for use of either of the launchers to be used as the reputation (Heritage) of the Ariane 5 was established. Once the Heritage is established, any move away from it can damage the reliability and reputation of the launcher.

In relation to Euro Cryospace France, there is a rigid expectation in relation to the final technical parameters and performance that the cryogenic tanks, supplied to their customer Airbus Safran Launchers, must meet when being used in Ariane 5. This ensures the Heritage of the tanks and the confidence that it will perform as expected. There is a level of freedom, however, in the processes it implements to achieve these parameters and performance. This freedom assumes the authorisation of the customer, and must be supported by qualification logic and an implementation schedule agreed along the whole supply chain.

The advantage, therefore, of using technologies with established Heritage, like the cryogenic tanks treated with chromium trioxide, is that they all have reached the required and accepted Technology Readiness (TRL; see Section 2.3.3.2.2 below for an explanation of TRL) for that component and so can be integrated without the need for lengthy and expensive redesign, development and qualification.

Use number: 1 Legal name of the applicant(s) Euro Cryospace France

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considered the manufacturing and launch preparation phase, where designs are fixed and no change is allowed.

Any change in an existing system must go through the development phase again. There is a more detailed description of these phases is given in the Appendix 4.

2.3.2.2.2. Technology Readiness The concept of technology maturity is a scale of 9 levels used to measure the maturity of technologies, is also employed. Each technology has to reach certain maturity to be acceptable in specific phases of a space programme. TRL 8 is required to assess flightworthiness and TRL 9 is the level reached after a successful operational flight mission.

Development of the product begins with design phase when the mission and functions needed are defined (TRL 3-4). The period before TRL 3 is an undefined number of years of research and development work. After outlining the requirements (TRL 5-6) comes justification and definition phase (TRL 7-8). The final verification phase including qualification follows next (TRL 9). Developing the technology from TRL 3-9 takes minimum 7-10 years, after which can be 3-5 years from qualification, via design and document changes to the final first prototype product (TRL 8-9). Afterwards the product is ready for production/industrialisation. Details of the 9 technology readiness level (TRL) are given in the Appendices 5 and 6.

Cryogenic tanks must reach a TRL level of 9 before they can be considered qualified for use in the Ariane 5 launcher.

2.3.2.2.3. Overview of the Key Steps to Industrialisation There are 4 steps required of any new material introduced into the space industry supply chain to ensure that they are suitable for space applications. These are:  Research & Development: The timeframe for Basic Technology Research is undefined. Alternative technologies must be commercially available so that they can be investigated. There is a strong reliance by FCSP on commercial chemical suppliers at this point. A commitment to fund a development programme is also needed. To date no alternatives can

match the performance of CrO3;  Testing alternatives by space companies against the functional requirements: These requirements are defined by Airbus Safran Launchers and must meet the requirements of the Ariane 5 launcher. The performance of the alternatives is tested until the functions and critical requirements are met for both the ground and space environments.  Wettability proving satisfactory free surface energy of aluminium substrate for nominal primer adhesion: ;  Adhesion of the gluing primer on the substrate under cryogenic conditions: adhesion of primer onto the aluminium substrate is verified

Use number: 1 Legal name of the applicant(s) Euro Cryospace France

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Figure 5. Les Mureaux in France

In addition to the direct impacts, indirect impacts have to be taken into account as well. The indirect impacts are felt in the whole European space sector. The space industry companies are spread all around Europe, most of the employees (90 %) in the space sector are located in France, Germany, Italy, UK, Spain and Belgium (2013). As a conclusion the geographical scope of this study for direct impacts is Les Mureaux and for the indirect impacts is Europe.

2.4.2. Temporal scope The applicant will produce 6 to 7 tanks per year until the end of Ariane 5 programme, which is estimated to be completed in the mid-2020s. The temporal scope of this application is, consequently, until the end of Ariane 5 programme.

3. APPLIED FOR “USE” SCENARIO

3.1. Analysis of substance function Oxides associated with aluminium have high surface energies and are relatively unstable, varying in thickness and containing a level of surface roughness. This reduces the ability of substrates, which might be used to adhere to the aluminium alloy surface, to bind. In order to ensure reproducible adhesion which provides the alloy with maximum strength and durability in an industrial setting, surface preparations are required to modify the surface chemistry of the alloy in such a way to ensure effective structural adhesive bonding by introducing a uniform reactive surface.

This means that a controlled film of active aluminium oxide is grown on the surface of the alloy. The thickness of the active layer is dependent on the type of surface preparation

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employed and the alloy substrate. The key requirements of the treatment are that it must demonstrate:

 Wettability providing satisfactory free surface energy of aluminium substrate for nominal primer adhesion.  Satisfactory adhesion of the gluing primer on the substrate under cryogenic conditions;  No corrosion generated by the pickling substance.

The effectiveness of surface preparations can only be demonstrated by trial and error; taking into consideration the type of alloy to be treated and the adhesive required in the process. For each key requirement above, standard testing procedures are in place to ensure consistency and repeatability.

Effect of surface preparation using chromium trioxide leads to formation of an aluminium oxide/hydroxide film as well as adequate surface physical conditions, which provides the most suitable surface for structural bonding of adhesives used in the cryogenic tanks, i.e. the applied adhesive completely wets and penetrates the surface.

In summary, pickling using chromium trioxide is used to prepare the surface of the alloy for adhesive bonding in the processing steps that follow it. Chromium trioxide is used as it offers the best result for treatment of the surfaces due to its strong reduction abilities, while also having a minimal effect on the fatigue properties of the treated aluminium alloy.

Treatment process for the cryogenic tanks

Degreasing Rinsing Pickling

Drying Hot Rinsing Cold Rinsing

Figure 6. Treatment process for the Aluminium used in production of the cryogenic tanks. Chromium trioxide is introduced during spraying at the pickling step

3.2. Reasoning for the choice of material Aluminium alloys offer several advantages over other metals. Some of these advantages are that it is not very expensive, is easily available in different semi-finished product forms, easily machinable, easily shaped and weldable and is not susceptible to stress–corrosion cracking. In comparison, magnesium displays lightweight properties but has bad corrosion resistance properties and is difficult to machine (inflammable).

Titanium has good corrosion resistance properties but is expensive, heavy and not as available as aluminium.

Use number: 1 Legal name of the applicant(s) Euro Cryospace France

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Additionally, galvanic corrosion issues, mechanical properties, thickness, temperature resistance, etc. in the end product need to be taken into account. Aluminium fulfils all the requirements of the space sector and is the only material currently possible to be used for the applications for which it is employed. As the aluminium alloys are critical to the needs of the space sector the only viable alternative options is reagent change rather than a substitution of the materials to avoid the need for treatment. Al-alloys are the best compromise between cost, weight, and performance.

The use of Aluminium alloys cannot, therefore, be replaced in this use and, consequently, surface preparation is required in the process whenever it is used.

3.3. Market and business trends including the use of the substance

3.3.1. The General Space Market The space market can be divided into:  Institutional market: The institutional market is made up of national (e.g. military, ministries of research or agriculture, etc.) or international bodies structured at European level (e.g. ESA, EUMETSAT, the EU). European public institutions play a key role in the space sector and their involvement is essential to sustain the space economy. They are the largest part of the sector’s customer base. Their procurement includes operational systems and contracted RDT activities.

Investments in space programmes have strategic implications as they bring scientific, industrial, technological and security capabilities. For the institutional market, missions are related to the public service domain, such as meteorology, science, security, communications, exploration, human space flights, launchers etc.1

 Commercial and exports market: The commercial and exports market segment includes private customers, mostly satellite operators, in Europe and worldwide, as well as public entities located outside Europe. There are also many foreign suppliers involved in the commercial side of the European space sector e.g. European commercial customers also order a significant share of satellites from the US. The commercial market has traditionally been dominated by the geostationary satellites and associated telecommunications services; but recently the Low Earth Orbit (LEO) constellations have become the main growth segment for this market. The public/institutional vs. private/commercial market is described in Table 1 in terms of sales breakdown.

1 ASD-EUROSPACE (2013). ”Space Trends 2013, Global Space Activity Overview”. 2nd Edition, June 2013.

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Table 1. Sales breakdown by segments (public/institutional and private/commercial market)2

European customers Export customers TOTAL Sales by segment M€ Public Private Public Private Launcher development programmes 569 569 Operational launcher systems and parts 809 4 33 846 Total Launcher systems 569 809 4 33 1 415 Telecommunication systems 301 458 480 733 1 972 Earth Observation systems 822 14 171 46 1 053 Navigation systems 397 47 0 7 452 Total satellite systems 1 520 519 651 787 3 477 Science systems 724 27 89 26 865 Human related Space infrastructure (ISS, ATV,…) 328 1 0 28 358 Microgravity products (racks, experiments) 55 1 0 3 59 Total scientific systems 1 107 29 89 57 1 281 EGSE, MGSE (test & support equipmt) 34 13 6 18 70 Ground stations (TT&C, UL/DL…) 233 90 20 19 363 Professional services (engineering, test, etc.) 362 75 3 13 453 Total ground systems and services 629 177 30 51 886 Other & unknown 114 10 26 48 199 Total 3 939 1 544 800 976 7 258 Both of these markets would be impacted by should Ariane 5 not be available for launch until a suitable solution has been identified and qualified.

3.3.2. The Applicant’s Space Market and Trends The applicant’s business trend and the use of the substance are foreseen to develop in line with Ariane 5 production. The applicant produces 7 tanks per year until the end of Ariane 5 programme, which is estimated to be completed in the mid-2020s. The trend and the use are, therefore, expected to stay stable during the review period applied for.

3.4. Annual tonnage The tonnage used is 0.83 tonnes/year of chromium trioxide.

the usage trend will be stable until the Ariane 5 launcher is replaced, which is expected to be by the mid-2020s. After this time the use of chromium trioxide for the surface preparation of the cryogenic tanks will cease completely.

3.5. Remaining risk of the “applied for use” scenario Chromium trioxide is included in Annex XIV based on two intrinsic properties: carcinogenicity (category 1A) and mutagenicity (category 1B). Cr (VI) compounds have the potential to induce both somatic and germ cell mutations. The consequences of mutagenicity can be severe, however, based on the results of the epidemiological studies of workers exposed by inhalation to Cr (VI) compounds and on results of long-term oral carcinogenicity studies in animals, it is known that mutagenicity of Cr (VI) compounds is mostly linked with oncogenic transformation of epithelial cells in lungs and in intestine leading to lung cancer or intestine cancer. Taking that into account, the focus of the current health impacts assessment

2 ASD-EUROSPACE (2014).

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3.7. Monetised damage of human health and environmental impacts The excess cancer risks can be monetised as:

Table 3. Monetised excess cancer impact

Monetised excess cancer impact = Excess risk level × Population × Vmortal

(Vmortal: Monetary value of one fatal cancer case)

Based on the latest recommendation, the monetary values of one cancer case are chosen as EUR 2.2 million to 3.6 million, according to the following example presented in ECHA’s publication of Valuing Selected Health Impact of Chemicals: Summary of the Results and a Critical Review of the ECHA Study (December 2015, ECHA).

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than with sulfochromic surface treatment and these were not within the required specifications.

As a result, the process was not deemed technically feasible.

 Laser Surface Treatment: This alternative was tested from 2000-2015. Initial tests using a low power device gave poor results in terms of bonding performance. Further testing in 2009 showed an improvement compared to the initial results but with slow processing speed (< 1 m2/h). Given the large size of the tanks and the requirement that subsequent treatment steps require this was not seen as being feasible on an industrial scale because of time and practicality issues.

Tests in 2012 with a device from a different supplier showed good results for bonding performance. However, in 2014 a decision was taken by the Ministerial Council to stop any further developments of this surface preparation under the Ariane 5 programme and funding was withdrawn.

This surface preparation was, consequently, not implemented in the Ariane 5 due to its insufficient technology maturity (TRL 5/6).

 Nitro-Sulfo-Ferric Acid surface treatment: This alternative was tested from 2012-2014 and was selected as a potential replacement to chromium trioxide on pilot (reduced scale) plant trials following positive initial results. The pilot plant trials were also used to define the useable concentrations range. This provided results that were sufficient to consider implementation at a production level.

This alternative will be further discussed in Section 4.1.5, below.

4.1.5. Nitro‐Sulfo‐Ferric Acid As has been stated previously, after the development of a launcher the configuration is fixed and rigid, with little flexibility provided in change situations. Furthermore, there is a reluctance to take any risks with the Ariane 5 launcher for several reasons:

 The Ariane 5 launcher is, currently, the most reliable launcher in the world and as a result it commands a large share of the global launcher market;

 Any increase in risks could result in the catastrophic failure of the launcher which would irreparably damage the reputation of the reliability of the launcher;

 Changes to processes, or the introduction of new processes, means that Heritage needs to be built-up again.

 There are plans to replace the Ariane 5 launcher by the mid-2020s.

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For this to occur, the following steps will need to be undertaken:  Qualification work at sample level (process parameters);  Tool changes to ensure full compatibility with NSF;

 Qualification/Validation of the updated jigs and tools;  Full Qualification of the process on a prototype tank on a full scale;  Tests on the flight standard qualification model to ensure conformity;  Documentation update;  Implementation of the new process on a flight article;  Tests on the flight article to ensure compliance with standards and requirements for flight;  Restart of production

At this moment it is estimated that this change will take 24 months until it is commercially viable. This would consequently mean losing the entire business for that time span and lead to the possibility of lost jobs in the EU.

4.2.2. Launcher manufacturer’s non‐use scenario Since neither using an alternative substance nor outsourcing of the cryogenic tanks treated with chromium trioxide or re-designing the system are possible options for 24 months, in the

absence of a qualified replacement for CrO3, the manufacturing capability could be at stake and have annual economic losses until a solution or replacement is found. In sunset date year 2017 the production of launchers would fall drastically. The launcher manufacturer would lose their business related to Ariane 5. There could be additional impacts due to penalties because of non-respecting the contract or due to losing of future contracts. The launcher producer would be forced to cease production of all the current operational systems relying on cryogenic tanks treated with chromium trioxide until feasible alternative is ready. Consequently this means missing production of an average of launchers in the non-use scenario.

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4.2.3. Launch service provider’s non‐use scenario

5. IMPACTS OF GRANTING AUTHORISATION The impacts of the non-use scenario are analysed on three levels based on how direct the impacts of the production interruption are:

 impacts on the surface preparation processor  impacts on the space industry manufacturer  impacts on the launch service provider

The non-use scenario is summarised in the Table 8 below indicating how Euro Cryospace France, the launcher manufacturer, and the launch service provider would react. Impacts on the supply chain members are shown in the table. Negative impacts of the non-use scenario are shown as (-) and positive impacts as (+).

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whole highly skilled workforce in the company during the shutdown, as there is a lot of competition for these skilled workers within the space industry. Should Euro Cryospace France have to lay workers off, it is considered as a direct unemployment effect and the maximum is consequently lost jobs.

Total social impacts

In addition to the social impact on Euro Cryospace France, there are larger social impacts felt across the whole Europe. Since the non-use scenario for the launcher manufacturer and the launch service provider diminish their Ariane 5 related production for 24 months, their subcontractors and basically the whole European space industry will face indirect unemployment effect. Due to large scope of the sector these impacts are described qualitatively and it is speculative information.

The space sector in Europe employs 38 000 people directly.3 As the space industry companies are spread all around Europe, also the jobs affected by the non-use scenario are situated in several countries. Most of the employees (90 %) in the space sector are located in France, Germany, Italy, UK, Spain and Belgium (2013). Since the space sector activities usually require complex skills, large share of the employees have higher education than average. Most of the employees in space industry have scientific or engineering degree, and 40 % hold PhD or master level degree. In addition, 62 % of workers have at least a bachelor level degree (2013). Space industry companies where these employees work are relatively large, as only 3-8 % of the manufacturing and development in Europe are done by SME’s.4 It is also possible that the highly skillful, well-educated workers would aim to find jobs outside the EU which leads to human capital flight (brain drain). The skilled labour force in the EU is vital to the development and the region as a whole.

5.4. Wider economic impacts When considering space sector one cannot deny the large impact on the whole Europe in the geo-political and wider economic point of view. Wider economic impacts constitute of a variety of societal issues the non-use scenario would cause. In this context the EU’s space policy5,6 aims to promote technological and scientific progress, support industrial innovation and competitiveness, enable European citizens to benefit from the space applications and increase EU’s position in the international politics in the area of space. The space policy is

3 EUROSPACE (2015). 4 ASD-EUROSPACE (2014). “The European space industry in 2013”. Facts & Figures 18th edition, June 2014. 5 European Commission (2013). “EU Space Industrial Policy. Releasing the potential for economic growth in the space sector”. Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions. Brussels, 28.2.2013. COM(2013) 108 final. Available online: http://eur-lex.europa.eu/legal- content/EN/TXT/PDF/?uri=CELEX:52013DC0108&from=EN 6 Council of the European Union (2007). “Resolution on the European Space Policy”. 4th SPACE COUNCIL. COMPETITIVENESS (Internal Market, Industry and Research) Council meeting. Brussels, 22 May 2007. Available online: http://www.consilium.europa.eu/ueDocs/cms Data/docs/pressData/en/intm/94166.pdf

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important part of the European Commission’s programme Europe 2020 goals, including space projects in Horizon 2020. To achieve these goals it is necessary to secure the EU’s independent access to space. In the long run, there would additionally be several types of wider economic impacts.7,8 First of all, the EU space industry’s competitiveness in the global space market would suffer. The non-use scenario would have direct impact on development and deployment schedules of the EU space programmes9, e.g. for Galileo, EGNOS and Copernicus. The most important direct benefit from space activities is the information that cannot be obtained otherwise. This can be commercially relevant, relevant for public administration and security and science. The space industry, with its activities and applications, is vital for the EU’s growth and development; therefore the wider economic impacts of the non-use scenario would be especially harmful.

Europe's space policy is aimed at achieving the following objectives: promoting technological and scientific progress, stimulating industrial innovation and competitiveness, enabling European citizens to reap the benefits of space applications and raising Europe's profile on the international stage in the area of space. In order to achieve those goals, Europe needs to maintain independent access to space. The EU's independent access to space also means increased European capability to pursue independent missions from Europe's spaceport in Kourou.

Also ESA Ministerial 2014 and the Resolution for independent access to space highlight the importance of the EU’s independent space policy. It recognises the strategic and socio- economic value for Europe to maintain an independent, reliable and affordable access to space for institutional and commercial European customers and recalls the importance for all European institutional actors to consider as a high priority the use of launchers developed in Europe. Additionally, the current three destinations that ESA includes in its exploration strategy, LEO, the Moon and Mars, shall be recalled.

The European space industry is, in its domain, one of the best in the world but is facing increasing world competition especially over the last few years. Any inability to produce launcher parts inside Europe would endanger the European space industry and related jobs, and compromise autonomous European access to space. Manufacturing launcher parts outside Europe is a major issue while being a non-acceptable option. As a minimum it would create an unbearable distortion in the market. The market is highly competitive and there are

7 European Commission (2011). “Towards a Space Strategy for the European Union that Benefits Its Citizens”. Communication from the Commission to the Council, the European Parliament, the European Economic and Social Committee and the Committee of the Regions. Brussels4.4.2011. COM(2011) 152 final. Available online: http://eur-lex.europa.eu/legal- content/EN/TXT/PDF/?uri=CELEX:52011DC0152&from=EN 8 Council of the European Commission (2011). “Resolution on " Benefits of space for the security of European citizens” ". 3133rd COMPETITIVENESS (Internal Market, Industry, Research and Space) Council meeting Brussels, 6 December 2011. 9 European Commission (2014). “EGNOS and Galileo – The EU satellite navigation programmes explained”. Luxembourg: Publications Office of the European Union. 2014. ISBN: 978-92-79-36329-0. http://bookshop.europa.eu/en/egnos-and-galileo-pbNB0114211/

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high barriers to entry in the business due to the heritage requirements from the end users. A company who ends up falling out from the market for a period of time would face the high barriers again. It would be critical for especially the whole telecommunications market if the EU could not deliver its satellites into orbit. The cause consequence/relationship in this case can be shown, for example, as satellites are designed for specific launcher types. Therefore if Ariane 5 launchers are not available for two years, the feasibility of launching the already built satellites with alternative launchers will be limited. If the launch of the satellites is delayed, the orbital position originally planned for these satellites will be lost to competitors. Such losses are irreversible and there are only a limited number of orbital positions available.

There are three types of needs the EU’s space policy is targeting to: social, economic and strategic. The EU citizens wellbeing in Europe depends on several space related services and applications as public and civil security, humanitarian and development aid, transport, the information society and environment. In economic sense, space sector creates new products, know-how, and different forms on industrial cooperation. These lead to new innovations and contribute to competitiveness, growth and job creation. In strategic way space is a major player when creating EU’s economic and political independence.

The space programmes do not only benefit the space sector companies, but also the current EU citizens and future generations. Space technology is used in several industries. Telecommunication satellites support the communication needs and assist people living in remote areas. This also is related to the crisis management, when satellite services help shorten response times in emergencies. Satellites are also used for Earth monitoring and to observe e.g. vegetation, ocean currents, water quality, natural resources, atmospheric pollutants, greenhouse gases, and the ozone layer. These are keys for understanding and tackling climate change. In agriculture and fisheries the satellite-enabled applications help the land use and fishery controlling which guarantees safe food quality and secure the environment. Security is also one major issue as satellite positioning and observation is used for detecting illegal immigration, preventing cross-border organised crime, and combating piracy at sea. In addition, space-based applications are used in healthcare industry as well as in transportation planning for cars, planes, and ships.

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preparation of aluminium alloys used in the manufacture of the cryogenic tanks used in the Ariane 5 launcher before the sunset date.

As discussed in Section 3 of this document, the time required to identify and implement alternatives is long and the requirements necessarily high in order to reduce risk of failure of the launchers to a minimum. This has successfully been achieved, with Ariane 5 currently considered the most reliable space launcher in the world. Additionally, production in the launcher sector is capital intensive and the investment cycles are very long.

Potential for increased development costs due to a short review period may lead to a situation where high cost for developing an alternative is not justified by the commercial value of the

space product. In addition, the socio-economic benefits of CrO3 are high. The EU and its space projects are thus dependent the current use of CrO3.

A normal review period is, consequently, needed for Euro Cryospace France to avoid incurring undue financial strain in an attempt to implement an alternative that increases the risks of launcher failure exponentially, which should it happen would impact the European launcher industry in general, resulting in huge financial and reputational damage.

Euro Cryospace France, therefore, requests a review period of 7 years.

6.3. Substitution effort taken by the applicant if an authorisation is granted In anticipation to the sunset date for chromium trioxide, in 2012 Euro Cryospace France prepared a plan to change from using chromium trioxide to the Nitro-Sulfuric-Acid (NSF) process.

Development testing is an iterative and continuous process. Products and process improvements are tested until the requirements (technical but also industrial requirements) are met.

No alternative is, consequently, at a sufficient technology readiness to be implemented. As such the timeline will delay the production of Ariane 5 and the process will likely not be able to be fully implemented before early-mid 2020s, i.e. the timeframe for the replacement of the Ariane 5 launcher, for which this process is used exclusively.

Euro Cryospace France, its parent members, and the European space industry in general is committed to complying with all applicable national and European regulations in relation to substances of very high concern (SVHC). As such, substituting CrO3 is a definite goal of all the actors within the industry. With this in mind, alternative processes are in the development

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Annex – Justifications for Confidentiality Claims

Page Justification for confidentiality number

14, 18, 19, 20, Demonstration of Commercial Interest 24, 28, 29, 30, The information regarding the technical specification and properties of the 31, 34, 47 applicant’s products and production methodologies, and the tested alternative technologies are trade secrets of the applicant. These specifications and properties enable the applicant’s products to earn specific classification and fulfil the requirements in specific standards, which ultimately give the applicant a competitive advantage over their competitors. Demonstration of Potential Harm The release of information related to the technical specification and properties of the applicant’s products and production methodologies and tested alternatives would be beneficial to the applicant’s competitors. If this information would be known by competitors, it would allow the possibility to replicate technological solutions for their own products and production, and benefit from the knowledge on which alternatives failed in testing. This could ultimately cause harm to the applicant’s competitive position. Limitation of Validity of Claim The claim for confidentiality on information regarding the technical specification and properties of the applicant’s products and production methodologies and the tested alternatives will remain valid indefinitely. 13, 33, 34, 35, Demonstration of Commercial Interest 36, 37, 38, 39, The information regarding the economic figures and predictions and 40, 43, 44, 45, employees are trade secrets of the applicant and should therefore be kept 46, 57 confidential due to competition issues. Demonstration of Potential Harm The release of the applicants individual cost items would give competitors (each other) an unfair advantage in the market. The release of such information could thereby cause harm to the applicant’s competitive position. Limitation of Validity of Claim The claim for confidentiality on the applicants’ socio-economic figures will remain valid indefinitely.

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APPENDICES

Appendix 1 – Definitions Launchers are used to carry a cargo from the Earth’s surface into outer space. Launchers consist of the launch vehicle, launch pad and other infrastructure. The payload in a launcher is usually a satellite to be placed into orbit. In this report, the launcher systems are split between operational launcher systems and parts (sold to launcher integrators and to launch services operators) and launcher development activities (funded by space agencies).

Space vehicles/satellites are artificial objects placed into the space orbit by a launcher. They consist of two main parts: the platform and the payload. The common types of space vehicles can be divided into military and civilian Earth observation, communications, navigation, weather, and research space vehicles in addition to space stations and human space vehicles. Platform does the recurrent “housekeeping” operations, such as electricity production, thermal control, telemetry, and controlling the location, attitude and altitude. Payload is customer- and mission-specific and therefore space vehicles can have a number of purposes.

Probes are robotic space vehicles designed to travel through the space leaving the Earth orbit to explore and collect information on science purposes. Probes may fly by, orbit or land on other planets or moons, or enter interplanetary or interstellar space.

Orbit is the regular, repeated elliptical course of a celestial object or space vehicle about a star or planet. Typical orbits used in space missions are Geostationary Orbit (GEO) which is at 36 000 km above the Earth's equator, while Low Earth Orbit (LEO) has altitude between 160 km and 2000 km.

Prime contractor is the chief contractor which has the obligation to complete a project and may hire one or more subcontractors.

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Appendix 2 – Statistics

Ariane Statistics

The Ariane launcher series was initially developed because it was felt politically, scientifically and industrially that Europe needed to secure its own, unrestricted access to space that was cost effective and reliable for European states and industry. The current Ariane 5 sets the standard for the global launch service industry combining the proven track record, accuracy and reliability and commands about 50 % of the global commercial launcher market. Ariane 5 is launched six to seven times a year, of which only one or two are for institutional customers. This launcher is provided by Airbus Safran Launchers as the prime contractor.

Ariane 5’s parts are produced all around Europe, e.g. the cryogenic main core stages (EPC) are composed of elements produced in factories in France, Germany and the Netherlands; Solid Rocket Boosters (EAP) in France, Italy and Belgium; the upper composite parts are made in Germany, France and Spain; while the lower and upper adapters are produced in Sweden and Spain.

The current version of Ariane 5 has a typical length of 50.5 m and mass of 780 tons. Ariane 5’s boosters can provide up to 14,000 kN of thrust, with a burn time of 140 seconds, reaching an exit speed of 3,475 m/s carrying a satellite weighing 4,100 kg. The current Ariane 5 rocket is capable of carrying a maximum lift capacity of nearly 10 tonnes into GEO and over 20 tonnes into LEO and its target market is mainly focused on large weight space vehicle for low earth and geostationary orbit.

Appendix 3 – The ESA Convention

The ESA Convention for the establishment of a European Space Agency10 clarifies how the geographical distribution of all the ESA space contracts shall be governed by certain rules. According to its Article VII Industrial Policy, the aim is to improve the world-wide competitiveness of European industry by maintaining and developing space technology by encouraging the rationalisation and development of an industrial structure appropriate to market requirements, making use in the first place of the existing industrial potential of all Member States.

In the ESA Convention Annex V Industrial Policy, it is stated that in the placing of all contracts, the Agency shall give preference to industry and organisations of the Member States. The geographical distribution of all the Agency’s contracts shall be governed by the following general rules. A Member State’s overall return coefficient shall be the ratio

10 European Space Agency (ESA). Convention for the establishment of a European Space Agency. Available online: http://download.esa.int/docs/LEX-L/ESA-Convention/20101200-SP-1317-EN Extract ESA- Convention.pdf (accessed 19.10.2015).

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between its percentage share of the total value of all contracts awarded among all Member States and its total percentage contributions. For the purpose of calculating return coefficients, weighting factors shall be applied to the value of contracts on the basis of their technological interest. These weighting factors shall be defined by the Council. Within a single contract having a significant value, more than one weighting factor may be applied. Ideally the distribution of contracts placed by the Agency should result in all countries having an overall return coefficient of 1.

Appendix 4 – Space Programme Implementation and Development

Each space programme is unique; scientific programme; Earth observation programme; launcher; telecommunication all have different decision making processes, however, they all follow the same general phased implementation. These phases are explained below: • Phase 0 any mission specific needs are identified and analysed. In this phase possible system concepts are proposed that will ensure execution of all systems engineering;

• Phase A is the feasibility and conception/modelling phase. Here there is a finalization of the requirements of the mission, as identified in phase 0. Identification of, and solutions to, critical parameters and risks to ensure the mission meets the needs, ensure execution of all systems engineering activities and provision of documents in support to the preliminary requirement review (PRR). Additionally activities required to ensure implementation of PRR actions are also undertaken. This phase also has more to do with payload selection and subsystems etc. Material selection is not a major consideration at this point, unless there are very specific mission requirements necessitating specialized equipment. If, however, the platform is based on a standard platform there can be some material selection already known here; • Phase B is the preliminary design and more detailed view of material selection. There is a need to demonstrate that the solutions selected at the end of Phase A meet the technical requirements according to the schedule, budget and the organization requirements. Additionally it is necessary to ensure implementation of all systems engineering activities and provision of documents in support to system requirement review (SRR) and preliminary design review (PDR).

This phase ends with a preliminary design review;

• Phase C is the design phase. This is the first time that the customer will see detailed list of materials. This is the point at which materials and processes are discussed. Here the system detailed definition is established. The ability to meet the technical requirements of the system technical specifications is also verified. Additionally, there is a need to ensure execution of all systems engineering activities and provision of documents in support to critical design review (CDR), ensure implementation of the CDR actions.

This phase ends with a critical design review;

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• Phase D is production, ground qualification and acceptance review. Finalisation of the development of the system by qualification and acceptance occurs, as does the finalisation of the preparation for operations and utilization. Additionally it is necessary to ensure implementation of all systems engineering activities and provide documents in support of the execution of the qualification review (QR) and acceptance review (AR) actions.

This can be followed by a flight acceptance review.

• Phase E requires that there is utilization support for the launch campaign. This involves providing support to the entity in charge of the operations and utilization of the space vehicle in accordance with the terms of the business agreement. Additionally there is a need to ensure implementation of all systems engineering activities and the provision of documents in support to the flight readiness review (FRR), operational readiness review (ORR), launch readiness review (LRR), flight qualification review (FQR), end of life (EOLR), and recurring products acceptance review (AR).

• Phase F deals with disposal. The systems engineering organization shall support the entity in charge of the disposal following the terms of a business agreement.

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Appendix 5 – Technology Readiness Level definitions11

TRL Definition

TRL 1 Transition from scientific research to applied research. Essential characteristics and behaviors of systems and architectures. Descriptive tools are mathematical formulations or algorithms.

TRL 2 Applied research. Theory and scientific principles are focused on specific application area to define the concept. Characteristics of the application are described. Analytical tools are developed for simulation or analysis of the application.

TRL 3 Proof of concept validation. Active Research and Development (R&D) is initiated with analytical and laboratory studies. Demonstration of technical feasibility using breadboard or brassboard implementations that are exercised with representative data.

TRL 4 Standalone prototyping implementation and test. Integration of technology elements. Experiments with full-scale problems or data sets.

TRL 5 Thorough testing of prototyping in representative environment. Basic technology elements integrated with reasonably realistic supporting elements. Prototyping implementations conform to target environment and interfaces.

TRL 6 Prototyping implementations on full-scale realistic problems. Partially integrated with existing systems. Limited documentation available. Engineering feasibility fully demonstrated in actual system application.

TRL 7 System prototyping demonstration in operational environment. System is at or near scale of the operational system, with most functions available for demonstration and test.

Well integrated with collateral and ancillary systems. Limited documentation available.

TRL 8 End of system development. Fully integrated with operational hardware and software systems. Most user documentation, training documentation, and maintenance documentation completed. All functionality tested in simulated and operational scenarios. Verification and Validation (V&V) completed.

TRL 9 Fully integrated with operational hardware/software systems. Actual system has been thoroughly demonstrated and tested in its operational environment. All

11 The National Aeronautics and Space Administration (NASA) (2015).“Definition Of Technology Readiness Levels”. Available online: http://esto nasa.gov/files/trl definitions.pdf (accessed 18.8.2015).

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documentation completed. Successful operational experience. Sustaining engineering support in place.

Appendix 6 – Technology Readiness Levels

Instruments and space vehicle sub-systems are classified according to a "Technology Readiness level" (TRL) on a scale of 1 to 9. Levels 1 to 4 relate to creative and innovative technologies before or during the mission assessment phase. Levels 5 to 9 relate to existing technologies and to missions in definition phase. If the TRL is too low, then a mission risks being jeopardized by delays or cost over-runs.

Below the diagram and table explain the 9 TRL levels and define what is achieved at each step.

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Appendix 7 - General time-frames for technology development and exploitation time of space vehicles Below is a simplified diagram to describe the potential timeframe of technology maturity development and space vehicle exploitation over its lifecycle. TRL levels and Project Completeness/Phase are, however, independent of each other and technologies are fed into project phases as appropriate.

Technology Readiness

TRL 1 Basic principles observed and reported

TRL 2 Technology concept and/or application ~10 years formulated

Investigation TRL 3 Short-listing and Analytical and experimental critical function

and/or characteristic proof‐of‐concept Alternatives Identification,

TRL 4 Component and/or breadboard validation in laboratory environment

TRL 5 Component and/or breadboard validation in relevant environment

TRL 6 System / subsystem model or prototype demonstration in a relevant environment ~7 years TRL 7 System prototype demonstration in an operational environment TRL 8 Actual system completed and qualified through test and demonstration

TRL 9 Alternatives Development and Implementation Actual system through successful mission operations

Use number: 1 Legal name of the applicant(s) Euro Cryospace France

ANALYSIS OF ALTERNATIVES and SOCIO-ECONOMIC ANALYSIS

Use number: 1 Legal name of the applicant(s) Euro Cryospace France

58 ANALYSIS OF ALTERNATIVES and SOCIO-ECONOMIC ANALYSIS

References

ASD-EUROSPACE (2013). ”Space Trends 2013, Global Space Activity Overview”. 2nd Edition, June 2013.

ASD-EUROSPACE (2014)

EUROSPACE (2015)

ASD-EUROSPACE (2014). “The European space industry in 2013”. Facts & Figures 18th edition, June 2014.

European Commission (2013). “EU Space Industrial Policy. Releasing the potential for economic growth in the space sector”. Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions. Brussels, 28.2.2013. COM(2013) 108 final. Available online: http://eur-lex.europa.eu/legal- content/EN/TXT/PDF/?uri=CELEX:52013DC0108&from=EN

Council of the European Union (2007). “Resolution on the European Space Policy”. 4th SPACE COUNCIL. COMPETITIVENESS (Internal Market, Industry and Research) Council meeting. Brussels, 22 May 2007. Available online: http://www.consilium.europa.eu/ueDocs/cms_Data/docs/pressData/en/intm/94166.pdf

European Commission (2011). “Towards a Space Strategy for the European Union that Benefits Its Citizens”. Communication from the Commission to the Council, the European Parliament, the European Economic and Social Committee and the Committee of the Regions. Brussels4.4.2011. COM(2011) 152 final. Available online: http://eur- lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52011DC0152&from=EN

Council of the European Commission (2011). “Resolution on " Benefits of space for the security of European citizens” ". 3133rd COMPETITIVENESS (Internal Market, Industry, Research and Space) Council meeting Brussels, 6 December 2011.

European Commission (2014). “EGNOS and Galileo – The EU satellite navigation programmes explained”. Luxembourg: Publications Office of the European Union. 2014. ISBN: 978-92-79-36329-0. http://bookshop.europa.eu/en/egnos-and-galileo- pbNB0114211/

European Space Agency (ESA). Convention for the establishment of a European Space Agency. Available online: http://download.esa.int/docs/LEX-L/ESA- Convention/20101200-SP-1317-EN_Extract_ESA-Convention.pdf (accessed 19.10.2015).

Use number: 1 Legal name of the applicant(s) Euro Cryospace France

59 ANALYSIS OF ALTERNATIVES and SOCIO-ECONOMIC ANALYSIS

The National Aeronautics and Space Administration (NASA) (2015). “Definition Of Technology Readiness Levels”. Available online: http://esto.nasa.gov/files/trl_definitions.pdf (accessed 18.8.2015).

Use number: 1 Legal name of the applicant(s) Euro Cryospace France