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Towards an Informed and Risk-Based Framework of Space Regulation and Debris

29 July 2015 || 5 minute read

Space debris has made the headlines again recently with the crew of the International Space Station sheltering in the docked Soyuz vehicle as a fragment from a now-defunct Russian weather satellite (International Designator 1979–095AD) passed at around three kilometres distance on 16 July. This followed the stations 22nd and 23rd pre-determined debris avoidance manoeuvres in April and June this year — the April manoeuvre being to avoid another piece of debris from the same Russian weather satellite.

The European Commission estimates that economic losses for European satellite operators alone due to in-orbit collisions and debris avoidance manoeuvres amount to around €140 million per year, and that this could rise to as much as €210 million per year within a decade. The consequential economic loses on the ground due to service disruption is unquantified, but a significantly higher figure is implied.

The space station incident is curious, not only as it was only the fourth time the “shelter-in-place” protocol has been enacted in the stations 16+ years, but it serves to highlight the challenge posed by ‘unguided space objects’ — these tension and challenges are perhaps best encapsulated by CubeSats. A CubeSat is a class of spacecraft that is deployed in-orbit from a container by an ejector system. The size of the spacecraft is not constrained. However, the container’s total volume is typically an integer number of litres, termed units (U), allowing multiple spacecraft whose total volume equals that of the container to be launched concurrently. The most common CubeSat form-factors are the 1U and 3U CubeSat; however, variants from 0.5U up to 12U exist.

The (relatively) low-cost of CubeSats, coupled with their ready availability has sparked a wave of interest, from scientists to government innovation bodies and Silicon Valley entrepreneurs looking to exploit the opportunities offered, in single platforms and by the deployment of constellations for multi-point measurements and observations.

Due to the size of these spacecraft they are, in-effect, unguided space objects — leading some in the space community to raise concerns over the impact of CubeSats on the space debris population around our Earth. Indeed some fear that constellations of CubeSats could lead to the ruin of the space sector due to an uncontrolled growth in space debris. However, a recent study by NASA’s Orbital Debris Program Office found that although three of the UK’s five CubeSats do not comply with existing space debris requirements, approximately 80% of all CubeSats do. Despite this, and the lack of comparison metrics on non-CubeSat spacecraft the media, using this same report, continue to present CubeSats as a potential problem. Meanwhile, the national and international frameworks governing space exploration and exploitation date from a different era, when space was the preserve of large government led programmes, serving national prestige, geo-politics, and national security.

It is argued that these rules are hindering a new wave of innovation, commercialisation and economic growth in the space sector. In response to this, the UK Space Agency has published a consultation paper with eight recommendations on how the agency could modify the regulatory process to improve transparency and predictability for new UK entrants seeking to launch and fly CubeSats. As the paper points out, this is a challenging task for the UK Space Agency as they are tasked with delivering economic growth, whilst also being the regulating authority.

Admirably, the paper seeks to establishment a new technical framework by developing a traffic light system for a range of pre-determined technical assessments and associated likely regulatory outcomes. In turn, the paper notes that at the discretion of the UK Space Agency this system could be used to make informed, risk-based judgements on the true need for insurance and other requirements normally included in a licence issuance by the UK Space Agency. It is this regulatory need for third party insurance that has been singled out as the biggest obstacle to the UK’s CubeSat industry.

Of the eight recommendations, another that stands out is the suggestion that the UK Space Agency should conduct an assessment of CubeSat launch systems to identify those which would attract a green (low risk) rating; the paper notes that this would be “analogous but not equivalent to certification”. It is likely that a green rating would however become a quality symbol, which in-turn may lead to an unforeseen and undesirable increase in launch costs on such platforms.

All considered the paper appears to be a welcome step in the correct direction as it notes that this new technical framework is intended for CubeSats “in the first instance, but … could be broadened to encompass similar small satellite systems” that take advantage of common aspects across missions.

However, it does seem peculiar to single out CubeSats for special treatment. Whilst the report is wise to rule out regulatory mechanisms such as blanket waivers, the regulatory burden of unnecessary third party insurance is not restricted to CubeSats — why should a similarly well-informed and risk-based judgement approach not be applied to all UK licensed spacecraft? Additionally, why not reduce the burden on the regulator as well as the licensee by introducing an approved operator’s scheme — similar to the Trusted Traveller Program in the US — whereby experienced operators, with a track record of compliance with best-practise and regulatory requirements could be subjected to a slimmed down process?

Finally, to fully resolve the issue of space debris rather than tinkering with the current regulations we need big ideas and bold steps; this could be, for example, a Space Traffic Control System (1, 2, 3). Or alternatively, it could a new international treaty introducing the concept of salvage, as exists at sea, to space. By monetizing space debris, it creates the opportunity for entrepreneurship and innovation to act where governments have failed to-date.

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