Written Evidence Submitted by OneWeb

(SPA0008)

 

  1. OneWeb Global Ltd., a UK company that will provide global broadband from a space-based network of Low Earth Orbit (LEO) satellites, welcomes this opportunity to respond to the Science and Technology Committee call for evidence on UK Space Strategy and UK Satellite Infrastructure.

 

Background on OneWeb

  1. OneWeb is building a global communications network that will deliver low latency, high-speed broadband through a LEO constellation to provide both fixed and mobile communications via satellite. Unlike traditional satellites, OneWeb’s LEO satellites (which orbit much closer to Earth, in a pattern that covers the whole globe at the same time) do not suffer from the delay well-known to occur via geostationary satellites.

 

  1. A wide range of customer markets (aviation, land mobile, maritime, residential, traditional fixed) can all use OneWeb to receive affordable, fast, high-bandwidth and low-latency communications services.  Providing connectivity and increasing communications resilience to the hardest to reach locations, as well as for government applications and the aviation and maritime sectors is the very reason OneWeb is being built.

 

  1. OneWeb will be a wholesaler of services, providing business-to-business satellite services to telecommunication companies, governments and large-scale enterprise business users (as opposed to direct-to-consumer). This includes providing cellular backhaul to existing mobile network operators so they can extend their coverage to not spots and other areas where terrestrial network infrastructure investment is not commercially or geographically feasible.

 

  1. OneWeb has begun deploying its first constellation (Gen 1) of approximately 650 satellites which will deliver capacity spread evenly across the globe. Our current fleet of satellites is the second largest globally, with 218 satellites currently in orbit. Commercial services will start at the end of 2021 in areas above 50 degrees north latitude, including the UK, Canada, Alaska and Northern Europe, with full global coverage achieved by mid-2022.

 

  1. OneWeb is already in discussion with its customers about how to meet their requirements with a next-generation constellation (Gen2), that will complement the Gen1 satellites and add greater capacity and extended capabilities, with increased capacity targeted where it is most needed.  The Gen2 satellites are expected to be operational in just a few years and will be a further enabler to help UK government achieve its connectivity goals for 2025 and beyond.

 

 

What should be the aims and focus of a new UK Space Strategy?

  1. Effective space policy and supporting the domestic space sector is increasingly important, with growing competition over both the availability of space for constellations and the need for sovereign capabilities. This is most clearly apparent in the context of satellite communications, with it now recognised that communications networks are a vital part of UK critical national infrastructure (CNI) and growing consensus around the need for effective security and resilience measures.

 

  1. The Government’s OneWeb investment means the UK is now a leading space nation. The UK strategy should reflect this in the level of ambition it demonstrates. The space strategy should consider:

 

Current regulatory and legislative frameworks:

  1. To ensure the UK remains internationally competitive, UK space regulations need to be more outcome-focussed, better reflect the current and anticipated space market, and avoid over burdensome and over prescriptive requirements. There also needs to be greater analysis and recognition of how regulatory regimes in other countries attract operators and investors at the expense of the UK - negatively impacting the UK’s space sector.

 

  1. Although the recent Space Industry Act 2018 is welcome and paves the way for space launch in the UK, it should not be seen as ‘job done’. It will be essential to keep UK space legislation and regulations under constant review to ensure they are keeping pace as new technologies come on-line and other countries rapidly increase their space capabilities and ambitions.

 

  1. As an example, the following current regulatory issues are of concern for UK satellite operators, and large constellation operators in particular:

Licensing Fees

  1. The current UK satellite licensing charging regime is based on a 20-year-old conceptualisation of the space industry, i.e. a single large geostationary satellite launched on a single large launch vehicle. It does not reflect the current and future space market, including the requirement to launch multiple, identical smaller satellites as a constellation on a single launch vehicle.

 

  1. In such cases, where multiple satellites of identical design are launched on a single launch vehicle, the licensing fees need to be reasonable and proportionate, i.e. charged on a per launch basis (not ‘per satellite’ as is currently the case) to reflect the fact that the work required by the regulator to assess the satellite design and launch vehicle is the same for one satellite as it is for multiple satellites. In the US, the licensing process and fees are streamlined even further, with the US Federal Communications Commission charging on a ‘per-system’ basis, requiring a simple one-off fee to cover a whole satellite constellation.

 

  1. In March 2021, UK Government introduced a ‘refund scheme’ for constellation operators to allow operators to recoup some of the fees charged for repeat licenses. Whilst this was a welcome step, the resultant charges are still considerable. Further work to identify and assess the true cost burden of repeat licensing should be carried out so work and cost efficiencies for both the regulator and operator can be realised.

Insurance requirements

  1. Under current UK regulations, third-party liability insurance requirements for standard missions are set at €60m per occurrence. For missions that the regulator deems higher risk, it may be set at a higher level. However, there is no clear or transparent methodology by which the regulator determines whether a mission is higher risk. This creates significant uncertainty for established UK operators, as well as those considering operating from the UK.

 

  1. Without a proportionate, consistent, clear, objective and transparent methodology, operators are unable to consider appropriate risk mitigations, and are subject to significant uncertainty around the associated insurance burden - thus making the UK unattractive to innovative high value projects.

 

  1. Further, there should be a process that allows insurance requirements to be reduced during the period of in-orbit operations as greater evidence on the safety of the operations is demonstrated over time. This is important to ensure that innovative companies that pioneer new approaches to space in a safe and responsible way (such as those the UK is seeking to attract), are not unfairly penalised with higher-risk insurance requirements throughout the entire lifetime of their mission.

 

Spectrum

  1. It is important that the UK ensures a process for governing spectrum use so that new and innovative technologies (such as LEO satellites) can be effectively and flexibly deployed as they come to fruition. Key to this is ensuring a level of harmonisation of spectrum use on a regional and global basis so that the UK does not face unnecessary barriers to deployment of new space technology and suffer damage to its international competitiveness.

 

  1. One example is that licence exemption and free circulation for satellite earth stations in the UK (e.g. user terminals) are not currently provided for in the 14.25 – 14.5 GHz band. Therefore, satellite earth stations operating in this band can only be deployed following a lengthy coordination process with the users of (limited and decreasing) fixed service links.

 

  1. This places a significant constraint on the provision of satellite services in the UK, which does not exist in most other European countries. As a result, most satellite operators focus their offerings in the UK to the lower part of the band (14.0 – 14.25 GHz), causing congestion. This prevents the effective deployment of satellite services in the UK which have the capability to provide capacity throughout the whole 14.0 – 14.5 GHz band (such as OneWeb).

 

  1. Therefore, to optimise the provision of satellite services to the UK - and maximise the social and economic benefits that such services can deliver - licence exemption and free circulation for satellite earth stations for the whole 14.0 – 14.5 GHz band should be permitted.

 

  1. In addition, the UK auctioned off part of the 28 GHz band for use by terrestrial mobile systems for Fixed Wireless Access in 2000. This is unfortunate as the World Radio Conference-19[1] and most other nations have declined to use that band for that service.  Instead, most of the world is reserving the 28 GHz band for the very types of high-speed, low latency connectivity services that LEO satellites will provide.

 

UK Launch

  1. Having an affordable launch capability in the UK will be critical to ensuring a sovereign, resilient and reliable means to deploy and maintain critical UK satellite infrastructure.

 

  1. Overly burdensome and costly regulatory requirements (e.g. lengthy timescales to grant licenses) will prevent the UK from developing a commercially viable and sustainable domestic launch market. It is therefore essential that the UK’s spaceflight regulatory framework considers domestic and international commercial realities so that UK licensed launch operators can compete in the global launch marketplace.

 

Space Sustainability:

  1. Ensuring the long-term, sustainable use of space should be a major theme underpinning the UK’s entire space strategy - covering domestic operations, as well as a key aim for the UK to continue to promote and build consensus on internationally.

 

  1. OneWeb is dedicated to Responsible Space and is pleased to support the UK’s own vision of responsible space[2] with a sustainability framework and set of key commitments that are designed to protect the Space environment for generations to come. These include: employing responsible satellite design and operational practices, developing the space ecosystem, and supporting sustainable policy outcomes through collaboration with government and industry partners.

 

  1. However, today’s regulatory frameworks are unable to anticipate and manage the rapid acceleration of commercial space activity. International licensing practices therefore need to be updated to reflect the challenges this new level of activity presents to space safety. Specifically, the UK should advocate for better, more uniform safety practices internationally based on an up-to-date assessment of industry trends and practices.

 

  1. In order to achieve this, principal safety themes that the UK needs to promote include:

 

  1. Much is said about Space Traffic Management in the context of space sustainability. This is of global importance; however, it is important to note that outer space satellite traffic cannot be handled in the same way as air space traffic. Unhelpful parallels are often drawn with the current approach to air traffic control but there are significant differences between the two, e.g. satellite operators in outer space rarely share or cross the flight paths of others, they do not move assets towards fixed ports, and they do not take-off/land.

 

  1. The current traffic management approach of operators being responsible for controlling their own satellites, whilst adhering to national regulations and international best practice, and coordinating/sharing relevant data with other operators and stakeholders (as set out above) is the most proportionate and effective way to help ensure the sustainable and safe use of space.

 

What needs to be done to ensure the UK has appropriate, resilient, and future-proofed space and satellite infrastructure for applications?

Communication (Broadband):

  1. LEO constellations - such as OneWeb’s – will be an essential part of ensuring the UK (and the rest of the world) can meet future, greater demand for broadband services everywhere, all the time, for everyone. It is therefore essential that they are considered CNI for the UK’s communications backbone.

 

  1. The UK Government’s investment in OneWeb established a clear and strategic commitment to ensuring the UK has appropriate, resilient and future-proofed satellite communications infrastructure - not just as a domestic capability, but one with global reach. Specifically, it demonstrates the recognition and realisation of the benefits that the new generation of LEO satellites will bring, especially for providing resilient and ubiquitous broadband connectivity in support of both domestic and global objectives.

 

  1. LEO satellites offer a step change in capability over older satellite communication systems operating in higher orbits (typically geostationary) by providing affordable, fast, high-bandwidth and low-latency communications services that can fully support cloud-based applications and truly interactive modern Internet usage. They deliver:

 

  1. To ensure the UK can reliably have access to space communications infrastructure (both domestically and across the globe) upon which its critical infrastructure depends, it is essential that international rules on spectrum are adhered to. Globally agreed coordination rules at the International Telecommunications Union (ITU[3]) are specifically designed to deliver a transparent, fair, and coordinated approach to spectrum use throughout the world, to prevent interference between different satellite systems.

 

  1. When jurisdictions or operators ignore these rules (for geopolitical or commercial gain), satellite services can be significantly negatively impacted, leading to uncertainty for operators and the loss of critical services. Worse, other nations will themselves begin to ignore the ITU’s international treaty and create their own regimes as well, leading to endless erosion of international norms and comity.

 

  1. It is therefore important that the UK Space Strategy acknowledges the importance of spectrum to providing critical services and ensures that the UK takes a leading and proactive role globally to promote and defend international rules and best practice regarding the use of spectrum.

 

Navigation Systems:

  1. Satellite navigation and timing systems are critical to the national security of the UK and delivery of its essential services, ranging from financial services to energy networks. Further, the provision of secure and resilient UK space-based Position, Navigation and Timing (PNT) capability will be crucial to unlocking future transformational technologies such as autonomous vehicles and connected cities that will bring huge social and economic benefits.

 

  1. Given this critical national dependency, it is essential that the UK develop a capability to deliver resilient PNT services and reduce its reliance on foreign satellite systems. The UK’s Space-Based Positioning Navigation and Timing Programme (SBPP) programme is exploring this very issue.

 

  1. However, to achieve the goal of increased resilience and greater performance, it is important that the UK SBPP programme – and the wider UK Space Strategy – consider alternatives to the traditional Medium Earth Orbit (MEO) satellite systems utilised by the US Global Positioning System (GPS) and EU’s Galileo programmes. Key to this will be the active consideration of the delivery of PNT through LEO satellites (e.g. to augment signals from existing GNSS systems), which offer many benefits over solely MEO systems; including:

 

  1. To ensure the efficient and cost-effective deployment of an appropriate, resilient, and future-proofed UK PNT capability, opportunities to leverage existing and already planned satellite infrastructure must be explored. For example, OneWeb’s current Gen1 satellite constellation already has the potential capability to provide an enhanced, resilient timing service; and OneWeb’s Gen2 satellites will offer full PNT capability from 2026. By utilising the communications payloads of these satellite constellations for PNT, and with the advantage of being able to repurpose the (Ku) spectrum already allocated/secured (thus avoiding the challenge regarding L-band spectrum availability mentioned above), a sovereign UK PNT capability can be delivered in a cost-effective and technological resilient way.

 

(June 2021)


[1] World radiocommunication conferences (WRC) are held every three to four years. The WRC reviews, and, if necessary, revises the Radio Regulations, the international treaty governing the use of the radio-frequency spectrum and the geostationary-satellite and non-geostationary-satellite orbits

[2]United Kingdom: Update on our reporting approach for the voluntary implementation of the Guidelines for the Long-term Sustainability of Outer Space Activities[https://www.unoosa.org/res/oosadoc/data/documents/2021/aac_105c_12021crp/aac_105c_12021crp_16_0_html/AC105_C1_2021_CRP16E.pdf]

[3] The specialised agency of the United Nations responsible for all matters related to information and communication technologies.