IAC-2020-Commercial

IAC-20,E6,1,x57479

Commercial Incentives for Debris Removal Services

H. Brettle 1, A. Ziadlourad 1, M. Lindsay 2, J. Forshaw 1, J. Auburn 1

1 Astroscale UK, 2 Astroscale Holdings

Abstract As the threat of space debris grows, so does the potential market for debris removal services. This paper assesses commercial incentives for satellite operators to pay for debris removal services and quantifies their willingness to pay. The amount of orbital debris generated in low Earth orbit has been steadily increasing over the years and whilst on- orbit collisions are rare, historical trends cannot reliably be used to infer future risk. The nature of low Earth orbit (LEO) is set to change considerably, with satellite constellations projected to launch tens of thousands of new satellites over the next decade. As the number of satellites in key orbits increases, so does the likelihood of collision, posing a risk to the sustainability of the entire orbital environment. The challenge of space debris can be considered as a tragedy of the commons, whereby individual actors damage the shared orbital environment through their contribution to space debris, even though it is not in their long-term interest to do so. Whilst governments and international frameworks may be able to shape the discussion, the missing enabler has been identifying commercial incentives that could address the problem. As technological solutions to address the threat of space debris become feasible, so must the commercial incentives for satellite operators to use such solutions. In addition to being an environmental concern, space debris also poses a direct threat to the service provision and safety of satellites for a given satellite constellation operator. In addition, ensuring that debris is removed from operational orbit can enable satellite operators to utilise more efficient orbits and optimise their satellite design for operational service. This paper presents quantitative analysis justifying action by commercial satellite operators to remove failed satellites from orbit, strengthening the business case for this new market. Firstly, we assess how debris removal services can mitigate the risk of extended satellite lifetimes. Secondly, we analyse the trade-off between satellite reliability and cost, demonstrating how the consideration of third- party debris removal services can outsource end-of-life capabilities to third-party debris removal services. Finally, we evaluate the value to satellite operators of having access to higher orbits that give them a better satellite efficiency, with debris mitigation risks offset by third-party debris removal services. Keywords: (commercial, sustainability, debris removal services, business case)

Acronyms/Abbreviations As the technology for debris removal matures, so • ADR – Active Debris Removal must the business case for these services. Customers are • CAM – Collision avoidance maneuver currently reluctant to pay for debris removal services • LEO – Low Earth Orbit until either there is stricter regulation in place mandating • PMD - post-mission disposal debris removal or a clearer economic case for such • QoS – Quality of service services. The objective of this activity is to identify viable commercial business models for debris removal services. Introduction The successful development of the debris removal market requires 3 core components: viable technology Though it is still nascent, the market for debris solutions, effective regulation and policy, and a strong monitoring and removal is predicted to grow business case for satellite operators to act. There can be significantly in the next decade. The increasing number no successful market without these components. In of launch vehicle providers and decreasing costs for performing this business analysis, we present results to satellite development leads to a rise in the number of support a number of commercial incentives for debris operators in orbit. The deployment of unprecedented removal services. number of satellites in the next few decades will The following arguments demonstrate the business contribute to more crowded and dangerous orbits. case for an affordable debris removal service for large Anomalies in orbit, as a result of strong particle radiation LEO constellations. Different arguments will resonate from the Van Allen Belts or generic malfunctions, will more strongly with different satellite operators, contribute to, and result in the failure of a certain depending on their business strategy. Some arguments percentage of satellites. Debris removal services can are more quantifiable, whilst others are more subjective provide the backstop for the tail-end of the failed satellite incentives. distribution to ensure a sustainable orbital environment.

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This paper begins in Section 1 by demonstrating the reported that ‘the majority of installations on the UK value of debris removal services in mitigating the risk of Continental Shelf have exceeded their design life’ [3]. extended satellite lifetimes. Section 2 presents the trade- The difference in other sectors is that regulatory off that satellite operators face between cost and permission is required to extend asset lifetimes, in reliability, demonstrating the value of debris removal recognition of the risk it poses to the environment [4]. services in outsourcing residual risks. Section 3 The trade-off between extended revenues and space illustrates how debris removal services provide satellite sustainability poses a challenge for satellite operators: operators with a responsible way to deploy into higher de-orbiting functional satellites at the end of their design orbits and access the associated benefits, presenting life will protect the space environment but it comes at a debris removal services as an enabling service for cost of potential additional revenue from continued satellite operators. Section 4 presents a number of other operations. elements of the debris removal service value proposition Debris removal services present a solution to this including: protecting operational service (Section 4.1), trade-off, enabling satellite operators to de-orbit satellites managing regulatory risk (Section 4.2), recognition as a beyond the anticipated end of their life, even if they have responsible space actor (Section 4.3) and reducing failed or run out of fuel. In this section, we analyse the insurance premiums (Section 4.4). The main findings of value that debris removal services can provide to satellite this paper are summarised in the Conclusion (Section 5). operators, recognising the economic incentives that they face in extending satellite lifetimes, whilst ensuring that 1. Mitigate Risk of Extended Satellite Lifetimes the orbital environment is protected. We model the additional value in retaining satellites in LEO while It is common practice for operators to keep their employing active debris removal services to ensure that satellites in orbit for as long as they are operational, often post mission disposal can still be maintained. extending beyond their original design life. There are clear economic incentives to do so, given that the capital 1.1 Metrics Considered: Additional Revenue and PMD expenditure has already been sunk in the build and launch Rates phases. In geostationary orbit, nearly a third [1] of commercial communications satellites are operating Measuring the PMD rate is an established way to beyond their design lives, more than double the amount assess the proportion of satellites that have been de- in 2009. Such life extension activities are likely to orbited responsibly. For a given constellation, the PMD increase in the coming years, with TelAstra reporting that rate is defined as the percentage of satellites that are “keeping aging satellites in service is likely to become a removed from Earth’s orbit within a reasonable time trend”. In LEO, there are similar incentives to extend period (currently less than 25 years). Multiple NASA and satellite lifetimes. For example, the Iridium first ESA studies in recent years have shown that the achieved generated satellites were designed for an initial seven- reliability of post-mission disposal operations is one of year mission but many remained in orbit for over 20 the most critical factors in the growth of the LEO debris years. environment. A target PMD rate of 95% assumes that 5% However, such life extension can pose a risk to the of satellites fail and remain on orbit but that 95% are de- orbital environment, as the longer satellites continue to orbited at end-of-life. However, if satellites remain in operate, the more likely it is that they fail and remain in orbit beyond their design life, the number that fail is orbit. If left in orbit, such satellites can degrade, risking expected to rise, and therefore the PMD rate of a fragmentation events that cause further damage to the constellation may drop below the pre-defined target, as orbital environment. ESA’s Envisat had a design life of illustrated in the following figure. five years but remained operational for 10 years before unexpectedly failing. At over 8000 kg and orbiting in a 790 km sun-synchronous polar orbit, it now represents one of the most critical space debris objects in LEO. In the case of Iridium, 13 additional satellites failed during extended operations and will remain on orbit as debris for decades or even centuries to come [2]. If left in orbit, such failed satellites pose a direct threat to other satellites in operation and can fragment causing further damage to the orbital environment. In other sectors, such as oil and gas, we see similar incentives for life extension. The lifetime of offshore oil rigs is often extended beyond their operational lifetime to maximise Fig. 1a - Illustration of Post Mission Disposal Rate revenue and efficiency. Oil and Gas UK previously decay, within design life and beyond.

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As a specific example, we assume that a constellation As previously discussed, satellite operators are of 100 satellites is designed for five years of operation, incentivised to keep satellites in orbit beyond their design but that their lifetime is extended by an additional year. life, in order to benefit from additional revenues, as As a result of this extension, we assume that an additional illustrated in the figure below. 5% of satellites will fail during the extended period. If we assume that each satellite is generating $1M revenue per year, the year extension of operations will result in an additional $100M in revenue but an additional five failed satellites in orbit. In this simple example, we find that if debris removal costs less than $20M per failed satellite removed, it is still favourable for the constellation to extend the satellite operational lifetime by one year whilst also offsetting the additional debris created with removal services. This demonstrates that satellite

Fig. 1b – Illustration of satellite revenues, within operators can afford to pay for debris removal services, design life and beyond. provided that the costs are below this threshold. This incentive to continue life extensions is not Through employing debris removal services, satellite without limit. As satellites remain on orbit for longer and operators can retain satellites in orbit beyond their longer, the number of failures will continue to increase, operational lifetime while still meeting regulatory PMD and therefore eventually the cost of debris removal will rates. We evaluate the cost of debris removal services exceed the value of the additional revenues received from required for life extension to generate additional revenue, the remaining operational satellites. This is illustrated by whilst ensuring that any additional debris due to the life the example below. extension is removed from orbit.

1.2 Modelling life extension and debris removal

In this section we evaluate the cost of additional debris removal required to protect the orbital environment versus the additional revenues received Fig. 2b - The optimum extension time for a satellite from extended satellite operations. Through modelling operator, assuming a 100-satellite constellation and 7% PMD compliance and satellite revenue, we show that satellite failures per year of extension, revenues of $1.5M satellite operators can still benefit from additional per satellite per year and a conservatively high debris cost revenues whilst offsetting any negative impact on the of $20M. orbital environment with debris removal services. The model allows us to explore the impact of different failure As such we show that debris removal services will not rates, the number of satellites in a constellation and incur further penalties and will in fact offset the negative different satellite revenue assumptions. impacts of life extension on the orbital environment, We first assume that the satellite design is optimised whilst still remaining commercially beneficial to such that the reliability of the satellite matches the operators. desired compliance with a PMD rate. We assume a 95% PMD target and that 5% of satellites will fail during the 1.3 Break Even Comparison design life timeframe. If the satellite lifetime is extended by one year however, we will expect more satellites to By generalising this example, we assess the values of fail (since they are operating beyond their design life) as satellite revenue, debris removal cost, and failure rate illustrated in the figure below. expectation, for which debris removal can provide value to satellite operators. The following figure 3a shows the breakeven cost of debris removal services for different assumed satellite revenues, whilst assuming that 5% of the constellation satellites will further fail in the extension year.

Fig. 2a - The failure rate of a satellite constellation

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Fig. 3a - The break-even point for a satellite operator assuming a 1000 satellite constellation with 5% satellite failures during the operational phase and 5% failure rate Fig. 3b - The break-even point for a satellite operator in the subsequent extended year. assuming 5% satellite failures during the operational phase and a varying failure rate for the extended year. We From this figure we can see that different satellite assume the satellite generated revenue per year per operator revenues assumptions change the debris satellite is $1.5 million. removal break-even point for the satellite operators. If satellite revenues per year were higher, then there would We demonstrate that even high numbers of failures be more economic incentive for operators to extend their assumed during the extension period can still be offset satellite lifetimes, and the breakeven cost of debris with debris removal services and result in overall removal could be even higher. If few satellite failures increased revenues for the operator due to the extended were expected during the extension period, similarly the revenues of the remaining operational satellites. The value of life extension, combined with debris removal numbers presented here are representative and illustrative services to offset a reduced number of failures, would be only, but they do clearly demonstrate that debris removal greater. services provide value to operators, even assuming high These findings are independent of the size (number of failure rates and removal costs. As discussed in other satellites) of the constellation since we are considering sections of this paper, this is because the benefit of life the failure rate as a proportion of the constellation size. extension is felt across the majority of satellites that The revenue per satellite is likely to be different for remain operational, whereas debris removal services are different constellation sizes, which will in turn effect the only required for the small proportion of satellites that value of debris removal services. For operators with fail unexpectantly. higher revenue per satellite there is more value to life extension combined with debris removal services, as is 1.4 Constellation Replenishment shown in the above figure. These results show that for a constellation with In this section we instead consider a 30-year revenues of $1M per satellite per year, the operator can operations cycle to determine the value of life extension still generate additional revenue through extending accounting for satellite build and launch costs as well as satellite lifetimes whilst also accounting for debris constellation replenishment. We consider two scenarios, removal costs as high as $19 million to ensure that there both assuming a 100-satellite constellation: is no negative impact on the orbital environment. Even if • No Extend: Satellites have a five-year design and extending the satellite lifetime by one year doubles the operational life. To operate over a 30-year time number of satellite failures, the operator will still frame, satellite operators will need to carry out six generate additional revenue and find value in employing replenishment cycles, thus launching 600 satellites debris removal services. overall to account for the extra replenishment cycle. The following figure assumes a fixed $1.5M revenue We assume a 95% PMD rate is met, given a 5% per satellite per year and shows the break-even cost of failure rate for the constellation satellites. debris removal services required for different failure rate • Extend + Debris Removal: The satellites still have assumptions. In this scenario, even if 20% of constellation satellites fail in the extension period, then a five-year design life, but instead remain in orbit debris removal costs of less than $6M per removal can for an additional extension year (six years in total). ensure PMD compliance, offset the increase in debris, We assume that a further 5% of satellites will fail in and still provide additional revenue to the satellite the extension year. To operate over a 30-year time operator from extension. frame, operators will instead need five replenishment cycles, thus launching only 500 satellites in total with debris removal required to

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maintain the same PMD level as before. This will There are decreasing marginal returns in reliability as the incur a further 25 debris removal missions required desired reliability of the satellite increases. For example, to offset the increase in satellite failures that result it is more costly to increase satellite reliability from 90% from the extension. to 95% than it would be to increase reliability lower down the curve. As such, a combination of robust satellite By looking at the break-even ratio between debris design and back-up disposal capability is needed for removal costs and the cost to build and launch a satellite, operators to achieve high post mission disposal rates. we are able to assess the value in ‘Extend + Debris Removal’ over the ‘No Extend’ scenario. Given the assumptions presented above, we see that the ‘Extend + Debris Removal’ scenario is more cost effective for the satellite operator, provided that the cost of debris removal is less than four times the cost of building and launching one constellation satellite. The following figure generalises this finding, assuming different numbers of failures assumed in the extension period.

Fig. 5a – Cost optimisation for satellite operators

Future satellite failure rates will depend on a number of factors including dual-string redundancy, the manufacturing process, testing procedures and the orbital environment. Due to the high-volume manufacturing Fig. 4a - The break-even ratio for a satellite operator process of satellite constellations, it is unlikely that every assuming a constellation with a 5-year design life satellite will be fully tested before launch to the same considering a 1-year extension time per satellite over a level as historic quality assurance standards. To 30-year time horizon. summarise, the following considerations must be

accounted for when looking to increase the reliability of Debris removal services are more favourable for a given satellite: lower assumed failure rates, as few debris removal • Selection of components and units with flight missions are required for the same assumed revenue benefits from extension. Again, these findings are heritage independent of constellation size, and also the launch and • Dual-string redundancy build cost of the satellites being considered. These • Full qualification and test campaign findings present a compelling new way to consider the • Long-duration unit testing value of debris removal services, in the context of • Reliability analysis satellite operations, revenues and deployment costs. The • Consideration of additional functionality required results presented demonstrate that satellite operators can for end-of-life afford to pay for debris removal services, provided that the costs are below the identified thresholds, whilst Third-party debris removal services are better placed benefiting from life extension at no additional risk to the and more economical to capture the tail end of the failure orbital environment. distribution. Alternative options that could be considered include: 2. Trade-Off Between Cost and Reliability • Reducing satellite failure rates – as discussed above, satellite constellation operators face a trade- Satellite operators will always be constrained by the off between cost and reliability. Satellite operators trade-off between cost and reliability, and such a trade- that are targeting low-cost systems will be limited off is particularly prominent for satellite constellations in their own ability to respond to such satellite that are targeting low-cost satellites. Cost optimisation failures in their systems. balances satellite cost with the number of satellites • Integrated de-orbit capabilities, such as drag sails or required for high quality of service (QoS) to a reliability propulsion – such capabilities will still be level below 100% (as illustrated in the following figure). compromised in the case that the satellite fails. They

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also add mass, cost and most importantly launch disposal capability can help operators achieve a high cost for 100% of the satellites in the system. PMD rate.

Third party debris removal services enable satellite 3. Accessing More Efficient Orbits operators to optimise their design (and therefore streamline costs) for operational service, rather than end- Satellite operators face a number of factors to of-life deorbiting procedures which can be outsourced to Astroscale. Both of the proposed alternatives to consider in order to select the optimum orbital altitude. Astroscale’s debris removal service above result in The advantages of lower altitude satellites are better additional cost for each and every satellite in the resolution for Earth observation and lower latency constellation whereas Astroscale’s service is only communications, although all regions of LEO present required for the small proportion of satellites that fail lower latency compared to GEO alternative operations. unexpectantly. In addition, satellites at lower altitudes will passively Without external action, satellite reliability is decay in the case of failure or at end of life. At higher correlated with PMD as demonstrated in Figure 5b. Assuming that all operational satellites can be de-orbited altitudes, fewer satellites are needed for global coverage themselves and all failed satellites must be removed by and each one spends more time covering land, which external action, the PMD disposal rate is simply one together mean that satellite capacity can be used more minus the failure rate. As such, reaching a target PMD efficiently. This said, higher altitude satellites present requires more reliable satellites and therefore higher cost concerns surrounding space sustainability, since longer of production. Alternatively, Astroscale services can be natural decay times require further consideration of employed to reach a target PMD rate at a lower cost debris mitigation practices. In this vein, SpaceX (without step change increase in satellite cost from higher reliability requirements). As illustrated in the example in highlighted space debris concerns [5] as a key reason for Figure 5b, a satellite constellation with an 85% reliability lowering the operational altitude of higher layers of the (or 15% satellite failure rate) cannot meet a 95% PMD Starlink constellation, and Kuiper’s decision [6] to rate target without either: operate around 600 km was in part driven by their 1. Increasing costs to ensure the inherent satellite consideration of any potential orbital debris impact. reliability is higher (and therefore the failure rate is However, debris removal services provide satellite reduced from 15% to 5%) 2. Outsource the removal of the tail-end of the operators with a responsible way to deploy into higher failure distribution to a third party such as Astroscale orbits by ensuring any failed satellites can be safely which will remove 10% of satellites in the constellation removed from orbit, whilst benefiting from the from orbit. advantages of operating at higher altitudes. Telecommunication constellations are generally planning to operate in higher altitude regions of LEO, for example Telesat (1000 km and 1248 km) [7], Viasat (1300 km), and OneWeb (1200 km). We present two key advantages to such satellites operating at higher LEO altitudes: 1. Land Coverage – satellites at higher altitude will cover a larger instantaneous area of the Earth’s surface, therefore requiring fewer satellites for global coverage 2. Time Over Land – Similarly, satellites at higher altitudes will spend more of their time with Fig. 5b – The relationship between PMD rate and visibility to land where they can provide revenue- satellite reliability. generating coverage, therefore increasing the As presented above, increasing costs for greater efficiency of each satellite. reliability though enhanced design processes, higher In the case of land coverage, we assess the area quality components and more extensive assembly, covered on ground by a satellite for a given elevation and integration and testing will eventually have diminishing different inclinations. Table 1 shows the instantaneous returns as higher reliability is targeted. We propose that area covered on ground for a satellite at different that a combination of robust satellite design and back-up

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Table 1. Area covered at different altitudes Area Covered on Altitude (km) Ground (km2) 500 636,047 600 881,933 800 1,440,161 1000 2,080,264 1200 2,804,216

The area covered on the ground is considerably Fig. 6b – Land access percentage compared to altitude greater for satellites at higher altitudes as seen in the table for a range of inclinations from 30 to 99 degrees above. By carrying out analysis we can look further at the increased area covered on the ground by satellites at As mentioned above, these are just two of the higher altitudes. This is demonstrated in figure 6a below: considerations that satellite operators must assess when in order to select the optimum orbital altitude. Debris removal services provide satellite operators with a responsible way to deploy into higher orbits and access these benefits, and should therefore be considered as an enabling service for satellite operators.

4. Other Incentives for Debris Removal Services

4.1 Protect Operational Service

Fig. 6a – Field of view for a satellite at 500 km End of life services are fundamental to ensure altitude (in red) and 1000 km altitude (in blue), superimposed onto a map. operational service of satellite constellations, limit collision avoidance manoeuvre (CAM) operations and From these figures, along with the above table we can mitigate collision events. Satellites are exposed to see that one satellite operating at an altitude of 1000 km external collision risks due to other satellites and existing covers more than three times more area than a satellite at debris. The risk of collision for a satellite operator is 500 km which in practical terms as illustrated by the increased due to the presence of their own additional right-hand side of the figure, means that five satellites at satellites, particularly those that have failed without any 500 km altitude are required for the same coverage area. In the case of time over land, satellites at higher manoeuvring capability. This marginal increase in the altitudes will spend more of their time with visibility to collision risk with failed satellites will result in more land providing revenue-generating coverage, therefore catastrophic collisions and the requirement of more increasing the efficiency of each satellite. Again, using collision avoidance manoeuvres. This risk can then be STK, we assess for a given inclination, the time that a quantified as an additional cost to the satellite operator satellite will spend over land (excluding Greenland and through increased loss of service, increased operational Antarctica) as a function of altitude (see the figure below). If we assume that telecommunication services costs and additional fuel required for satellites. are predominantly provided over land masses, where the customers are, then we see the greater efficiency of the satellites’ capacity being used. Figure 6b shows a range of inclinations for the 45-degree elevation angle.

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• Debris Removal Services: Third party services can ensure that decommissioning is completed, regardless of asset position or condition.

It should be noted that the achieved post-mission disposal reliability to-date since the establishment of the existing orbital debris mitigation guidelines is well below 90%, so achieving this much higher rate of post-mission disposal reliability will almost certainly require a different approach than what has been used to-date. Fig. 7a – In the absence of debris removal service provision, satellite operational service is compromised. 4.2 Manage Regulatory Risk

As such, there is a financial incentive to remove failed With regulations moving towards debris mitigation satellites from orbit. Measuring the PMD rate is an plans and the future enforcement of space sustainability, effective way to assess the proportion of satellites that satellite operators should consider how debris removal have been de-orbited sustainably. For a given services can support their compliance with future policy. constellation, the PMD rate is defined as the percentage Satellite operators can manage the following regulatory of satellites that are removed from Earth’s orbit within a risks through proactive action and engaging with debris reasonable time period (currently less than 25 years). removal services: • Fines due to regulatory non-compliance – whilst no Multiple NASA and ESA studies in recent years have fines have been reported directly regarding space shown that the achieved reliability of post-mission debris, the FCC has issued fines in the past for disposal operations is one of the most critical factors in regulatory non-compliance. In 2018, Swarm the growth of the LEO debris environment. For large Technologies who were fined $900,000 by the FCC LEO constellations, it is recognised by satellite operators [11] due to non-compliance on the issuance of a [8], [9] that a high PMD rate is necessary to ensure that license ahead of launch. Whilst Swarm were fined non-functional spacecraft do not unnecessarily for not having a license, rather than being non- jeopardize the orbital environment. For constellations compliant with a license, the value of this fine with numerous satellites, a high PMD rate protects the provides a first order indication of potential immediate orbital environment which is synonymous financial ramifications. with protecting and maintaining the operational service • Regulatory Delays - There is a risk that licences are of their own constellation. not approved without a post mission disposal plan Based on a NASA Orbital Debris Program Office and ineffective debris mitigation plans result in (ODPO) study [10], for large constellations, the achieved delays. In 2017, the FCC requested additional post-mission disposal reliability needs to be in the >95- information with respect to SpaceX’s application to operate their satellite constellation. This included 99% reliability region to avoid an unsustainable increase further collision risk analysis to ensure a debris-free in the quantity of debris in LEO, and therefore maintain space environment. the operational service of a satellite constellation. High • Cost of Compliance – As debris mitigation policies PMD rates could be met through: and regulations evolve, satellite operators will need • Passive Measures: Satellites at low altitudes will to comply with a greater understanding of the naturally decay quickly due to atmospheric environment with which they will operate, and drag. However, satellites that decay without any deeper technical understanding of debris mitigation manoeuvring capability will still be at risk of measures such as design features and robust collision as they descend through lower operational plans and manoeuvres. altitudes before burning up. There is benefit to the sound regulation of space • Onboard manoeuvrability: Satellites use on- activities, especially in this new era of increased activity, board propulsion or other internal capabilities to growing debris and congestion [12]. Governments must de-orbit. This option requires satellites to be have oversight and continuing supervision of its domestic operational and have fuel available at the end of space activities, include those conducted by private their operational life. industry, according to the Outer Space Treaty, Article VI. The actions of satellite operators today will drive best

IAC-20,E6,1,x57479 Page 8 of 10 71st International Astronautical Congress (IAC) – The CyberSpace Edition, 12-14 October 2020. Copyright ©2020 by the International Astronautical Federation (IAF). All rights reserved. practice going forward. As best practices evolve into revenue streams by mitigating the potential risk it future regulations, satellite operators should be preparing poses to the orbital environment, to address the debris mitigation regulatory needs of • Enable satellite operators to optimise their design, tomorrow, today. In essence, operators should be and therefore streamline costs, for operational proactive in adopting responsible space behaviours that service, include third-party debris removal services. • Offset satellite costs by outsourcing to end-of-life

servicing, 4.3 Responsible Space Actor • Provide satellite operators with a responsible way to Through engaging with debris removal services, deploy into higher orbits. satellite operators are demonstrating that they are Such trade-offs for operators will change as the responsible space actor committed to sustainable environment becomes more congested. As such, debris practices, that are reducing the overall collision risk in removal services become an ever more important orbit, benefiting both themselves and other space users. consideration for satellite operators. As such, debris removal costs should be factored into the 9. References cost of doing business in space responsibly.

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http://satellitemarkets.com/news-analysis/next- Satellite operators face many trade-offs when it wave-low-earth-orbit-constellations, (accessed comes to optimising their service offering. As presented 30.09.20). in this paper, debris removal services are an enabling service that can benefit satellite operators facing such [8] WorldVu Satellites Ltd (OneWeb) response to FCC trade-offs. Debris removal services can: NPRM on Orbital Debris, 2019, • Mitigate the risk of extended satellite lifetimes, allowing operators to benefit from extended

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https://ecfsapi.fcc.gov/file/10507013947263/OneWe [13] Samson, V., Wolny, J., Christensen, I. (2019), “Can b%20Orbital%20Debris%20Reply%20Comments.p the Space Insurance Industry Help Incentivize the df ,(accessed 30.09.20). Responsible Use of Space?” 69th International Astronautical Congress, Bremen, Germany. [9] The Boeing Company response to FCC NPRM on Orbital Debris, 2019 [14] Swiss Re 2011 Report https://ecfsapi.fcc.gov/file/1050656163821/Boeing% https://www.swissre.com/dam/jcr:b359fb24-857a- 20Orbital%20Debris%20NPRM%20Reply%20Com 412a-ae5c-72cdff0eaa94/Publ11_Space+debris.pdf ments %205%206%202019%20final.pdf, (accessed ,(accessed 30.09.20). 30.09.20).

[10] NASA Orbital Debris Quarterly News, Aug 2018, Large Constellation Study (J.-C. Liou, M. Matney, A. Vavrin, A. Manis, and D. Gates).

[11] FCC Investigation into Swarm Technologies, December 2018, https://docs.fcc.gov/public/attachments/DOC- 355578A1.pdf ,(accessed 30.09.20).

[12] Weeden, C., Blackerby, C., Okada, N., Yamamoto, E., Forshaw, J., Auburn, J. (2019), “Authorization and Continuous Supervision of Astroscale’s De-orbit Activities: A Review of the Regulatory Environment for End of Life (EOL) and Active Debris Removal (ADR) Services”, 70th International Astronautical Congress, DC, USA

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