Licensing space activities in the era of New Space

ESA-ECSL Workshop March 20th 2019 Toby Harris Head of Orbital Systems Contents

• International Standards and Treaties • UK Acts and Licensing • Licensing process • License authorisation and supervision • Licensing considerations • New Space • Large constellations • New licensing challenges • Improving authorisation: New models and capabilities • Future licensing • Summary

2 International treaties and standards

United Nations Committee on the Peaceful Uses of Outer Space (UNCOPUOS)

• 1967 UN (OST): basic legal framework of international (e.g. prohibits weapons of mass destruction in space, claiming celestial bodies etc..)

• 1972 UN Space Liability Convention (SLC): expands on the liability rules created in the Outer Space Treaty • If an object was launched from a State’s territory, facility, or if the State caused the launch to happen, then that State is fully liable for damages that result from that space object.

• 2007 UN Space Debris Mitigation Guidelines: 7 Key recommendations to international community to limit pollution of the orbital environment

3 UK Acts and licensing

In the UK, these conventions are conveyed through:

• 1986 UK Outer Space Act (OSA): Provides current UK framework to license launches for UK licensed payloads outside the UK, and UK operations in .

• 2018 UK Act (SIA): Will provide the future framework to license launches from the UK (with or without UK payloads), and UK operations in orbit.

• Licensing: If an operator wants to operate from the UK, then UKSA can license subject to insurance, financial and technical criteria being met.

4 • The UK executive licensing authority is the UK Space Agency

• UKSA will not grant a licence to an operator unless the activities authorised by the licence will: • not jeopardise public health or the safety of persons or property • be consistent with the international obligations of the • not impair the national security of the United Kingdom

• Further the licensee must conduct their operations in such a way as to prevent • the contamination of outer space (e.g. Debris) • adverse changes in the environment of the Earth (e.g. Debris) • interference with activities of others in the peaceful exploration and use of outer space (e.g. Debris)

• Its about getting the right balance between mitigating risk and enabling novel technologies.

5 Licensing process

PHASE 0 PHASE B PHASE C PHASE D PHASE E PHASE A PHASE F Mission Preliminary Detailed Qualification Launch & Feasibility Disposal Analysis Definition Definition & Production Operations

Flight Preliminary Critical Design Readiness Design Review Review Review (PDR) (CDR) (FRR)

Pre- Analysis of Application Licencing Compliance Application Data OUTER SPACE Submission Decision Monitoring ACT LICENSING Consultation Provided PROCESS AUTHORISATION SUPERVISION 6 NO

Determination of Is OSA YES Traffic Light NO Licence Review applicant status Required? Requested?

YES Review of answers to Ten Questions given preliminary question to applicant set Pre-application

POSSIBLY

Indicative b Mission YES outcome b okay to Standard determined bb license? Mission? YES NO Applicant provides Standard question NO answers to question sets provided to sets applicant Extra questions for bespoke mission Application NO NO issued

Data Review of answers to sufficient YES Compliant POSSIBLY question sets to mission? decide?

YES

License authorisation Licence issue 7 Authorisation: Pre-application

• UKSA have recently introduced a ‘traffic light’ scheme as part of pre-application

Unacceptable risk – • Greater transparency of technical assessment process cannot licence

Uncertain risk – more • Reduced process burden on operator/applicant information needed

• Improved predictability of timescales/outcomes Acceptable risk – granting of a licence is likely • Promotion of safe, secure, sustainable access to space

8 Authorisation: Licensing considerations

WHO? WHY? WHEN?

HOW? WHAT? WHERE? Authorisation: Licensing considerations

OPERATOR MISSION OBJECTIVES MISSION PHASES PHASE: LEOP Mission responsibility Technology demonstrator Single PHASE: OPERATIONAL ORBIT ESTABLISHMENT Operator capability PHASE: DISPOSAL Path-finder mission Multiple Operator experience PHASE: CONSTELLATION ESTABLISHMENT Commercial service Small /Medium / Large constellation Training PHASE: ORBIT MANOEUVRING Follow-on mission Rendezvous mission Information sharing PHASE: TARGET ACQUISITION AND ENGAGEMENT Proximity mission Emergency procedures PHASE: IN-SERVICE OPERATIONS PHASE: TARGET UNDOCKING AND RETREAT

LAUNCHER & OPERATIONS PLATFORM/PAYLOAD Standard mission example: debris collision risk

2.0E-05 25 year de-orbit time is an IADC guideline which UKSA ) 1

- 1.5E-05 uses as part of its licensing 2yr - requirements increasing orbital inclination

1.0E-05 100

25 years threshold

10

Collision (m Probability 5.0E-06

1 0.0E+00 250 300 350 400 450 500 550 600 650 700 750 perigee altitude (km)

200 400 600 800 1000 1200 1400 1600 1800 2000 Orbital Lifetime (yrs) Perigee Altitude (km) 0.1

LEO collision probability with 0.01 debris Re-entry time: Object lifetime with no station-keeping (post-mission) Standard mission example: Mitigating debris risk LEO satellite injected into orbit >> 25 yrs, no deorbit system

PLATFORM/ LEO satellite injected LAUNCHER orbit >25 yrs with PAYLOAD deorbit system

LEO satellite injected into orbit less than 25 years Standard mission example e.g. cube-sat

Cube-sat Platform Cube-sat ejection from conforms to injected into dispenser on Cube-sat orbit < 25 years ISS standard

• Passivation of all launcher objects and vehicles once no longer required • Construct cube-sat as to limit risk during re-entry (e.g. high probability of atmospheric demise) License supervision • Supervision focusses on

• Compliance of in-orbit activities • Regular update on UK licensed objects • Regular verification of UK licensed objects (Space Surveillance and Tracking or SST) • Annual health-check

• End-of-life activities: re-entry and grave-yarding operations UKSA has been licensing missions for many years – what’s changed?

14 New Space

Novel and potentially disruptive technologies have begun to Left: OneWeb LEO mega- evolve as accessibility to space becomes cheaper and more Constellation widespread: Below: launch requirements for • Large constellations (aka ‘Mega-constellations’) OneWeb

• In-orbit servicing (e.g. debris removal, satellite servicing, Credit : OneWeb refurbishment, re-fuelling, disposal and even platform construction). Credit : OneWeb Left: Future in-orbit active population could grow enormously in the next 5 years (courtesy CSIS) Credit : Orbital Left: Orbital ATK ATK MEV satellite servicing mission

Below: RemoveDEBRIS space debris removal demonstrator

These new systems offer new challenges to long term space sustainability Credit : SSTL 15 Large constellations

• Large constellations of satellites are a • However, to ensure coverage, you need a lot of type of Non-Geostationary Satellite Orbit satellites. (NGSO) system. • This means that • there is potential for lots of failed satellites and • As they are based in LEO they have hence increased collision risk lower latency, making them ideal for • the burden of managing the satellites is could be broadband communications significant, and so conjunction risk could be higher • Satellites will need to be replenished regularly

LEO MEO GEO <50ms >135ms >560ms

Credit : SSTL 16 O3b 27satellites 8000km 8000 Samsung 7000 4600 satellites 6000 SpaceX Starlink 1500km 5000 4400 satellites 4000 ~1200km Oneweb 3000 800 satellites 2000 1200km 1000 Hongyan 0 Iridium 0 500 1000 1500 2000 300 satellites 66 satellites 1100km 800km S&SG Telesat LEO 200 satellites One 117 satellites 800km 1000km

Commsat Astrome 800 satellites 600 satellites 600km 1400km

There are many proposals for large SpaceX Starlink LEO constellations 7500 satellites 340km

Boeing This may increase the active satellite 3000 satellites 1000km population by as many as 20 times 17 Understanding the risks • Large Constellations present many questions on best practice: • Is ‘25 year rule’ good enough? • What is a necessary and sufficient PMD or reliability?

• When is orbital ‘carrying capacity’ reached? Below: Illustration of the growing • How should the CONOPS of these missions be issue of space assessed/regulated? debris in orbit

• Rendezvous and Proximity Operation (RPO) and formation missions present similar questions

• These issues are explored through international forums such as the IADC

• UKSA needs to be able to understand and assess the Credit : NASA risks of long-term impact of licensing new missions. 18 Improving authorisation: new capabilities

• To authorise future licenses, UKSA is significantly uplifting our capability to perform technical assessments.

• We are recruiting and training a new technical team, consisting of engineers, physicists and operations experts

• We are developing in-house expertise to create new predictive Orbital Environment models to • Determine likelihood of close encounters between spacecraft • Determine collision likelihood of failed spacecraft • Understand the impact of a collision fragmentation on the environment • Understand the potential financial impact of an event in orbit Improving authorisation: new capabilities Orbital Risk Assessment Capability (ORAC) library

Below: Large constellation simulation of an inter-plane polar collision and subsequent fragmentation

Above: Close encounter and conjunction frequency assessment

Below: High frequency conjunction partners used to inform financial risk models Above: Orbital traffic simulator

Right: Continuum based object Above: Fragmentation distribution density model following an in-orbit collision • UKSA are working closely with external collaborators • For example, the University of Southampton have provided support using their evolution model, DAMAGE. • Models such as this allow us to study the sensitivity of different constraints (e.g. PMD rate or satellite lifetime) on what the orbital environment could look like. • This helps provide evidence for best practice

TWO LARGE CONSTELLATIONS Mega constellation deployment

ONE LARGE CONSTELLATION

Above: Future orbital debris prediction with and without the Above: Illustration of collision rate sensitivity to deployment of a large constellation (graph courtesy Prof. Hugh constellation separation distance (graph courtesy Prof. Hugh 21 Lewis) Lewis) Quantitatively assessing liability

• As well as understanding environmental risk, we are Credit : rd 3 party ESA developing models to assess financial risk 1) Licensed satellite hits 3rd party • These models will use output from our evolutionary collision Licensed risk models along with financial data about the orbital craft environment to provide quantitative risk estimates • This will inform metrics such as maximum probably loss 2) Debris fragments (MPL) and third party liability insurance requirements (TPL) created from collision

Minimum Possible Expected Maximum Possible Loss (lowest value) Loss (mean) Loss (highest value) Minimum Probable Maximum Probable Loss (e.g. 0.5%) 3) Fragments collide Loss (e.g. 99.5%) with subsequent 3rd parties Right: Example Maximum 99% confidence interval Probable Loss (MPL) model Probability CDF Probability

Loss (financial, life, property) 22 Above: An illustration of a potential liability claim through multiple collision events 22 Future licensing

• UKSA are currently reforming our regulatory environment and licensing approach • How we license future missions requires evolution in how we authorise and supervise • Authorisation demands a better understanding of the risks of these new missions • Supervision of activities requires • Better objective capabilities to assess operational compliance (for example, enhanced Space Surveillance and Tracking) • Movement towards a partnership between UKSA and licensed operators

23 Summary

• UKSA currently licenses space-systems guided by principles of UN treaties and international best practice.

• Novel and disruptive technologies are now offering new technical challenges which could adversely impact the orbital environment.

• Understanding the risks of these new systems is essential in helping define international best practice, and limit adverse affects on the orbital environment.

• UKSA are developing in-house technical capability, supported by strong collaboration with academia and International Space Agencies.

• Our goal is to make evidence based decisions to ensure a sustainable future space environment for everyone.

24 Questions?

(Movie courtesy Dr H. Lewis, University of Southampton)