Written Evidence Submitted by Black Arrow Technologies Ltd

(SPA0105)

A Defence of the UK Space Regulator in the Light of the In-Flight Failure of the SMU Mission

 

The criticism levelled at the Regulator during the recent Science & Technology Committee hearing on the recent in-flight failure of the launch from Spaceport Cornwall, as reported through a number of media outlets, suggested that the Committee did not realise or acknowledge that failure is a stark reality in the space launch sector and development flights such as Start Me Up should be considered as high-risk. The cause of failure in this case was clearly flight hardware related, likely an internal quality management issue, rather than CAA certification, so the criticism of the Regulator in the same session was unwarranted. If it had happened in US, it’s unlikely that the approach of the FAA would have been questioned in the same way.

The media reports suggested a lack of perspective, set against a Regulator in the difficult position of meeting increased expectation to get it right first time. Although not a good look for the nascent UK sector, responsibility should be apportioned where it resides, to primarily improve the process and oversight for future missions. In reality, the CAA could not have prevented the reported hardware failure anyway.

According to the Guardian report, the CEO of Virgin Orbit, told MPs he had expected the CAA to work more closely to the Federal Aviation Authority in the US but he had found the UK regulator more conservative.

As Sir Stephen Hillier said: “Our primary duty is to ensure that the space activity in the UK is conducted safely.” The CAA has been tasked to roll-out the UK’s certification and licensing process; the FAA process does not apply, and a rushed approach would also lead to the same level of criticism. The CAA protects the UK’s mandatory independence and has always stated to industry that the full licensing process would take 9-18 months; for Spaceport Cornwall & Virgin Orbit, this took approximately 15 months – and as a Pathfinder, where the CAA team were learning to put the Regulations into practice, They met their target timelines admirably.

Virgin Orbit knew the details of the CAA approach well in advance. To assume the UK, a new launch nation, would immediately be able to have the same level of expertise and confidence in its licensing as one that has 70 years’ experience, is of course, nonsense.

The CAA should be defended, in this case, against any (and all) criticism related to the roll-out of the certification. For Government to publicly criticise the agreed CAA approach is an extraordinary betrayal and implies low levels of understanding or appreciation of the sector at Government level and this needs to improve quickly.

Black Arrow Space Technologies has often questioned the manner in which the UK space launch development programme (mostly focussing on spaceports) was handled since 2015, with limited engagement and financial support for a broader range of viable UK launch developments, and highlighting a reliance on ‘proven’ overseas providers to advise licensing and provide launch services from UK spaceports.

The visibility and engagement of UK systems to UK regulators would clearly be an advantage, as would gaining experience and confidence in the UK landscape, providing skills, jobs and assistance to UK businesses competing in a high-growth, precision engineering sector, with global commercial opportunities in numerous regions.

A major threat to the UK’s rightful claim to be a space nation is that improperly handled or reported failures could prematurely and unfairly impact credibility in the UK’s design & operations capability and the CAA licensing process, seriously affecting the view of the few private space launch investors that are present in the UK. This should be avoided.

Room for improvement certainly, but, from a UK space perspective, not a bad start.

 

 

(March 2023)