Written evidence submitted by Civil Aviation Authority – (SSS002)

Written evidence to the House of Commons Scottish Affairs Committee Inquiry: Scotland’s Space Sector

March 2025

The UK Civil Aviation Authority’s role as the space regulator

We are the UK's space regulator and play a central role in the expanding the space sector by regulating under an outcomes-based framework which enables the sector to realise their ambitions in a safe, secure and sustainable way. We license launch and return activity, spaceports, range control services and in-orbit operations and are responsible for the ongoing monitoring of space activity, including hundreds of satellites in orbit.

Our highly skilled, multi-disciplined space team includes regulators with experience in hazardous sectors, space and aerospace engineers, and environment experts. We also draw on expertise from teams across the CAA to support the safe operation of space activities.

The principal legislation that applies to spaceflight is the Space Industry Act 2018[1], the Space Industry Regulations 2021[2] and the Outer Space Act 1986[3]. Regulation 4 of the Space Industry Regulations appoints the CAA to exercise every function conferred on the regulator by or under the Space Industry Act. In relation to spaceflight activities under the Outer Space Act, the CAA is authorised to exercise regulatory functions under the Contracting Out (Functions in Relation to Space) Order 2021.

In carrying out our regulatory functions we are committed to follow the principles of the wider UK Civil Aviation Authority and the Regulators’ Code[4] and the growth duty. 

In assessing applications and conducting our monitoring functions we commit to:

• A consistent and proportionate approach which takes account of the relative risk associated with the proposed activities.
• Reducing administrative burdens where possible by working with other regulators and facilitating the use of existing supporting evidence where appropriate.
• Engaging with industry to support applicants on their journey, identify how to streamline processes and provide guidance on the legislative framework we operate within.

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Since becoming the UK’s space regulator in July 2021, we have licensed over 385 different space activities including spaceport operations, launch and range control services. We continue to monitor 23 licensees and over 750 objects in orbit. In January this year we granted a launch operator licence for Rocket Factory Augsburg (RFA) to launch from SaxaVord Spaceport in Shetland.

We have issued multiple licences to Scottish companies including orbital licences to AAC Clyde Space based in Glasgow. The UK has a long, proud history of satellite production and a large amount of our work goes into licensing and monitoring these activities. We have issued the UK’s first vertical launch licence to Saxa Vord Spaceport in Shetland, which allows up to 30 launches a year.

The Scottish space sector continues to grow and our work around launch has been particularly focused there in recent times. We continue to develop strong working relationships with Scottish companies which helps us to enable success in the sector, understand the industry ambitions, and receive feedback to improve our work as the space regulator.

The UK Civil Aviation Authority recognises the pivotal role that it holds in enabling the UK’s space economy. This is an important area for growth, national security and vital to our modern economy. 16% of the UK’s GDP currently relies on satellites[5]. UK Space Agency data space shows the space sector adds an estimated £18.9bn to the UK economy and £298m in Scotland[6].

How we approach regulating space

We have positive relationships with stakeholders across the UK’s space sector. Our openness and engagement with licensees and potential future applicants, helps understand the future direction and ambitions of the sector, and helps us develop and improve our regulatory work in a way that best supports the sector while maintaining safety.

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Since becoming the UK’s space regulator in July 2021, we have constantly been improving on how we work with industry to help the industry meet the regulations and make sure we are an enabler to growth and ambitions. This includes:

• Improving the support given to companies’ pre-application.
• Putting on workshops to build understanding of key requirements and principles (such as preparing an effective safety case and how to demonstrate risks are as low as reasonably practical).
• Making our tools and advice clearer and more effective based on industry feedback.

We are a learning organisation and constantly review and take action to improve our work all with safety and enabling the industry in mind. We have brought in changes that have improved the efficiency of licensing for industry and for our work as the regulator, including:

• Reducing our internal assessment criteria for the Assessment of Environmental Effects (AEE) by two thirds, to make the review process more streamlined and proportionate whilst maintaining the robustness of our review.
• Streamlining the Technical Question Set for orbital missions maintaining safety and sustainability requirements while reducing the burden on applicants.
• Revising and simplifying the Regulator Licensing Rules to streamline the volume of information required by applicants when submitting a licence application. The revised rules enable a risk-based framework for orbital licence applications that is proportionate.
• Using shared ‘workbooks’ to improve transparency, communications and understanding through the licence process.
• Improving flexibility and pace around issuing licences by using ‘conditions precedents’ where appropriate, for information like insurance documentation. Our monitoring work then ensures compliance with these conditions.

We welcome the creation of the Regulatory Innovation Office (RIO), and that space is one of the RIO’s initial focus areas. We are working with the RIO on a project to develop metrics to measure the success of our measures to improve the licencing processes for space activity – as this is key to assuring that the changes that we implement are achieving our objectives and making a positive impact.

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The UK’s space regulations are goal setting and therefore friendly to innovation. This allows for innovators to come forward with proposals and us to be able to work with them constructively to enable new ideas and not be a blocker. It does not preclude us working with industry to develop tailored guidance to set out minimum expectations.

We are currently involved in the world’s first Regulatory Rendezvous Proximity Operations (RPO) Sandbox. This project stemmed from the Department of Science, Innovation and Technology (DSITs) Regulatory Review where one of the recommendations was for further clarity, consistency and confidence when licensing new, novel and complex missions such as RPO. We have been working collaboratively alongside HMG and three companies who specialise in RPO, where a satellite provides serving functions to other space objects. This Sandbox is testing the regulatory framework to identify any gaps in policy, guidance and regulations to smooth any potential issues and bottlenecks early to provide that clarity to support and enable RPO activities.

Whilst our flexible outcomes-based approach can already support the licensing of these complex servicing and manufacturing activities the outcomes of the Sandbox will further put the UK forward as a global leader. An example of where our regulatory framework has already supported these types of missions is through the recent licensing of Space Forge’s Forgestar 1 satellite. This is an important licence that helps the company test elements of its technology and paves the way for novel missions and innovations by home grown UK companies. We are already working with them on licensing their next mission.

We are also supporting research of future technology including human spaceflight through research with King’s College London[7] and Sheffield University – this is key for the parts of the sector with an interest in human transport and tourism.  This enables us to influence the development of international standards in readiness to support UK activity as it develops in that area. 

We have a very active role in preparing the next generation to fill the roles of a future space economy. Our STEM outreach program has seen experts from the space team going into schools up and down the UK. In the last year the wider CAA set a target of reaching 100,000 school children through our STEM work. We have recently hit that target in large part to our work going out to schools, and educational events to educate and inspire around space. Recently one event alone saw a member of our engineering team talking and taking questions from 7,000 school children in one session. To boost the Scottish space sector specifically we have also been involved with the annual MACH competition at Machrihanish Airbase. We are sponsoring the upcoming MACH-25 and through this competition are helping inspire university students from across Scotland.

Given the nature of the sector, we are always prepared for things to go wrong. The launchpad fire at SaxaVord last year was a prime example of what can happen when things do not go as planned. However, this incident was an opportunity to test the safety measures agreed with SaxaVord within their spaceport licence. The fire did not result in harm to any people present and provided us with real world experience of SaxaVord, and RFA’s handling of a potentially dangerous incident.

Working with other regulators

We support the aims of recommendation three of the DSIT Space Regulatory Review to work with independent regulators to drive out duplication and demands for excess information, and reduce the time, cost and complexity of the licence application process.

Examples of how we are putting this into practice include:

• Apply “Collect once, use many times” principle, which is also echoed in the Regulator’s Code, where we encourage launch or spaceport licence applicants to use previous equivalent environmental assessments to form part or all their Assessment of Environmental Effects (AEE) to reduce burden to the applicant. For example, where an equivalent assessment was developed as part of a spaceport’s planning permission or aspects of a previous AEE which has been reviewed by us, where appropriate. We have also worked alongside other regulators, such as the Marine Management Organisation and Marine Directorate, where applicants have used parts of the AEE to support their marine licence application.
• We work with other regulators, such as the marine licensing regulators, to reduce the impacts of overlaps between launch and marine licensing. Overlaps include similar marine environment impacts assessments and addressing the risk to mariners. We work closely with the applicants and marine licensing regulators to avoid replicating assessments or duplicating efforts (where materials and expertise could be used for both regimes).
• Working with the Health and Safety Executive to ensure effective coordination, cooperation, and collaborative working in relation to the regulation of health and safety at spaceports, during spacecraft launch, return and other associated activities.

Whilst CAA are committed to continuous improvement of licensing, in some areas the legislation may pose barriers for industry and regulators as it may not facilitate or optimise the ability to rely on assessments made under other or related regimes. We believe there is a need for an HMG led mapping exercise of the regulatory requirements for spaceflight activities across the whole UK regulatory system. This is needed to identify areas where there are overlaps in requirements, and how they are evidenced, leading to the development of a delivery plan for streamlining requirements (including segmenting where this can be done at an operational level and where this requires legislative/policy amendments). We welcome the Government’s announcement of the Digital Regulatory Pathway project for space.

In addition to domestic regulators, we constantly engage with regulators around the world to strengthen relationships, put the UK outcomes-based framework on the map, promote high standards and share knowledge to enable cross jurisdictional missions. Current examples include working with Australia who have hosted a test launch by a company who is seeking to also launch from Scotland; and working with the Japanese authorities responsible for space, to share understanding on novel rendezvous and proximity missions. We are working with key international regulators to set up a Global Regulator’s Forum to enable future collaboration.

Our work enabling launch from the UK.

Launch, spaceport and range operations account for a small number of all licences dealt with by the UK Civil Aviation Authority. However, these applications tend to be complex and pose the greatest level of risk to life and so take a significant amount of time and resource despite the relatively small number compared to orbital licences.

In January this year, we reached a significant milestone by licencing Rocket Factory Ausburg to launch from Saxa Vord Spaceport. Following grant of Saxa Vord’s spaceport licence in December 2023 and range control licence in April 2024, CAA has now granted all the necessary licences for launch from Saxa Vord spaceport. This is well ahead of industry technical readiness to launch. We have put in place a team of dedicated space inspectors who are working closely with and monitoring these companies as they gear up to launch.

We are currently assessing licence applications for two UK based companies who are seeking to launch from Scotland. In the past year we have also had pre-application discussions with four overseas companies who have expressed an interest in launch from the UK.

We believe this is evidence that the regulatory environment in the UK, and our approach to regulation, is well regarded internationally and is an attractive selling point to inward investment. We have engaged with the Scottish Government, Department for Business and Trade, and Scottish Development International to drive interest, and investment into Scotland and the UK.

March 2025