Written Evidence Submitted by Rahim Talibzade

(SPA0066)

 

Rahim Talibzade[1]

United Kingdom As A Space Nation: a Snapshot of Current Capabilities And Lessons From Other Countries.

Abstract:

The first part of this written submission will provide a snapshot of the UK’s current individual and collaborative capabilities as a space nation. This includes an analysis of regulatory framework, joint space programmes and UK’s interaction with the international law. The second part of the paper will examine and evaluate key elements of space strategies of other nations, some of which the UK could potentially integrate into its own space development and some of which it would try to avoid. The paper will then conclude current prospects of UK as a growing space nation.

Introduction

Over the past two decades, United Kingdom (UK) has undergone rapid growth as a space-faring nation, growing to £16.4 billion in 2019 with an average growth rate of 2.8% since 2016[2]. UK as a growing space nation would rely on space due to the practical applications ranging from economic and commercial benefits to military and national security. Setting up its own UK Space Agency that formulates strategies, creating Space Command, developing regulatory framework, and joining more international space-related initiatives are just a few examples of the UK’s efforts to build its space-related capabilities. The paper will discuss effectiveness and shortcoming of such examples. Secondly, the paper will discuss legal aspects of space strategies of Luxembourg, United Arab Emirates, USA and China and comment on the aspects that the UK should potentially include or avoid in its own space strategy. In the conclusion, the paper will submit that the UK is taking firm steps to becoming a space nation whilst highlighting the need for continuous progress.

  1. Individual capabilities

First, the paper will review different individual capabilities of the UK as a space nation, in particular its regulatory framework and institutional capabilities.

 

  1. Regulatory framework

The paper will look at how UK’s current legislation contributes to its status as a space faring nation as well as what steps UK has taken on a regulatory level to finetune its legislation.

Outer Space Act 1986 (OSA)[3]

OSA is the first and fundamental legislation for regulating launch and operation of space objects and space activities in the UK or overseas territories. The paper starts with the analysis of its scope outlined in Article 1.

Under Article 1, the first two subparagraphs provide a wide provision regarding the launch and operation of space object. In practice it would apply to both objects that are launched in Earth’s atmosphere, such as Low Earth Orbit satellites as well as objects launched into deep space for exploration. However, the third provision regarding “any activity in outer spaceis a significantly wider, “catch-all” provision. Such activities in outer space could potentially include satellite communication activities, space awareness activities via tracking and monitoring, logistical support, manned spaceflights, planetary exploration and manufacturing using resources from outer space. However, each of those activities would require its own set of rules in order to facilitate a competent management over the activity as well as clarity for private companies and entrepreneurs. For instance, manned space flight as a prerequisite for developing space tourism, would require a lot of safety precautions and relevant insurances.

Article 5 regarding terms of license is also essential.  The first four provisions, Article 5(2)(a-d) are considered standard. However, Article 5(2)(e) is an interesting one as it “requires” under (i) to prevent contamination in outer space or adverse changes in Earth’s environment. Although a good start for potential planetary protection, the provision does not define “contamination” at all, echoing a classic flaw of the Outer Space Treaty 1967 (Article IX)[4]. This could mean that breaches could have occurred already but may not qualify in the eyes of the Secretary of State. Neither are the “adverse changes” defined which reduces prospective enforcement of this provision. As will be seen later in the paper, other space nations have their own COSPAR provisions that provide a greater clarity.

Article 10 stipulates the obligation of private actors to indemnify government against any claims that could potentially be brought against the UK. The provision mentions potential limits (Article 10 (1A)) but does not specify which projects will have such burden, enabling one to conclude that any project, regardless of its scale, will be subject to heavy onerous requirements. This could have a negative impact on much smaller projects, such as Cubesats that wouldn’t be able to shoulder such a burden.  The 2015 Amendment to the OSA however ensured that the licensee’s amount of liability would be specified in the license which somewhat alleviates the situation.

Having analysed OSA legislation, it is viable to conclude that, as the UK’s oldest space legislation, it would have many potential flaws some of which are still in place. However, it played an important role in establishing UK’s space industry on a legislative level. The paper will now examine the Space Industry Act 2018 that is yet to come into force but addresses many previous flaws.

 

Space Industry Act 2018 (SIA)[5]

SIA was created to address the regulation of space activities within the UK territories. This analysis will highlight new developments and improvements within the Act, rather than analyse the Act extensively.

Firstly, SIA 2018 has a unique feature that could facilitate space tourism industry which at the moment appears to be in development. Granting permissions for spaceports is now a possibility under the act (Article 12 (1)) under the terms of the license. In particular, under Article 12 (4), operator can carry out launch activities that are purposefully left undefined.

Secondly, there is now a higher calibre of safety included due to the training regulations. Such training regulations could also be included as part of spaceport operator’s responsibility in conducting activities and services associated with the space port (Article 18 (1) (a)).  Under Article 18 (4) it is a requirement to not allow an unqualified individual to take part in said activities, which could include space tourism.  Schedule 2 further supplements the training regulations. This makes UK more adept at being a space nation with its developed, specialized regime for the manned spaceflights.

The SIA 2018 legislation overall is an improvement that factored in multiple consultations from key stakeholders, such as commercial actors. The Act includes sophisticated elements, such as Schedules that provide more guidance and suggestions which promote certainty for investors and entrepreneurs in space. The helpful insurance regimes would assist with smaller projects, such as Cubesats, that don’t have to carry the same high insurance burden as the OSA had imposed. Secondly, the establishment of appeal board in Section 60 (supplemented by Schedule 10) demonstrates the focus on expertise and speed of resolution. Companies would be able to dispute decisions of the Secretary of State, thus, giving a fair opportunity for commercial actors to resolve disputes effectively and receiving appropriate remedies, such as renewal of license, as opposed to the classical litigation route that would be a lot more time-consuming and might provide difficulties in finding an expert judge in such areas of law.

 

  1. Institutional capabilities

The paper will look at the additional institution that UK created to integrate itself into space field.

Space command

Space Command has been one of the UK’s most recent military developments designed to protect assets in space, thus mirroring the USA’s Space Force. It is staffed from the Royal Navy, British Army, Royal Air Force, and Civil Service[6]. Its budget in 2021 is expected to be around £51.8 million[7]. It develops the UK’s capability of space-orientated warfare and counteracting hostile powers, such as Russia and China, as outlined in the UK’s recent defence review[8]. Enhancement of space awareness and control over space capabilities, such as UK’s Space Operations Centre, Skynet and Satellite Communications are some of the primary functions of Space Command. This will enable effective monitoring of the UK’s space assets and designing strategies to defend and counter-attack when appropriate; this would include early warning missiles.

Secondly, effective coordination with the ground forces, whether of the UK or its allies, is another purpose of the Space Command. Moreover, via Space Command, UK will continue to contribute to Combined Space Operations[9] Initiative along with Australia, Canada, France, Germany, New Zealand, and US. This will include Operation OLYMPIC DEFENDER which is currently led by the US Space Force. This is an important involvement of UK as a space superpower and with its own space unit, UK took a step towards deeper engagement with space and its space allies.

It is important to note, that whilst US puts its Space Force in space as “war-fighting domain”[10], the UK does not frame the function of the Space Command in a similar way. According to the Department of Défense’s Space Strategy published in 2018[11], the emphasis was on the development of its defensive capabilities. This is a good balancing approach for UK as a superpower with relatively new space force and would allow UK to continue its current foreign policy with other countries.

Such development, although in its early stages, demonstrates UK’s propensity and capability towards expanding its military in space dimension.  It also demonstrates the UK’s progress as a space nation in developing sophisticated institutional mechanisms to navigate space, albeit much development is still in progress.

 

  1. Partnerships

The next part of the paper briefly looks at the partnerships that UK has. This is divided into the treaties that the UK has signed as well as key joint collaboration programmes.

  1. Treaties

UK actively participates in the international space law. It ratified the fundamental Outer Space Act 1967, the Rescue Agreement 1968, the Liability Convention 1972 and the Registration Convention 1975[12]. UK did not sign the Moon Agreement 1979 however the Moon Agreement was not considered as a successful treaty and many countries did not sign it. The UK also recently signed the USA’s initiative Artemis Accords[13]. This demonstrates that the UK as a space nation is fundamentally in support of the international space law.

  1. Joint collaborations

As a space nation, UK maintains collaboration through joint programmes with other space actors.

UK-United Nations (UN)

The UK has for the first time joined the UN initiative[14] to support “the future sustainability and safety of outer space” and address matters of serious issue, such as space debris. In the long term, UK would be keen to support Guidelines for the Long-Term Sustainability of Outer Space Activities. Contributing £85,000, UK is keen to sponsor UNOOSA project as part of its UK Space Agency’s National Space Innovation Programme. Such behaviour further puts UK on the international scale as a space nation.

UK United States

UK and US signed “U.K.-U.S. Technology Safeguards Agreement”[15] which would allow American companies to launch its rocket from the British soil. Such treaty would come into force after the   Space Industry Regulations. The agreement concerned the usage of UK’s spaceports and safe export of sensitive technology that would be ITAR compliant. This signifies UK’s growing capability as a nation with capable spaceports as opposed to previously using other launch sites, such as Baikonur, Kazakhstan. The agreement would also benefit the development UK’s space expertise and commercial innovation across its supply chains; all of this would be a seamless process that would reduce due diligence and bureaucratic processes that are common in launch projects.

UK- European Space Agency

UK established an annual contribution of £374 million per year[16] to the European Space Agency (ESA). This would allow the UK to partake in ESA’s projects despite UK’s companies being excluded from the Galileo procurement contracts as a result of Brexit.  Such projects are of an essential importance that help gain the status of a space nation: returning the first samples from Mars; an early-warning system for solar storms; research in space technology to deliver high-speed mobile technology; removing space debris, and the space station that orbits the Moon named ‘Lunar Gateway’[17]. UK’s continuous contribution would also enable internal commercial growth and calibre of companies needed to partake in this project. It would open up an opportunity for competition for the UK companies, thus increasing UK’s status as a hub that facilitates growth of space start-ups. Similarly, it would benefit in reducing political tensions derived from Brexit that resulted in UK’s limited participation in some of the ESA’s projects as well as losing access to EU’s Galileo system.

UK-India

Recently, UK and Indian billionaire Sunil Mital had jointly bailed out OneWeb out of bankruptcy. Continuing the joint expansion of OneWeb’s network, UK government launched 36 satellites from Vostochny Cosmodrome in Russia[18]. This firstly promises a potential collaboration with India which is also a growing space nation. This is especially important in the recent context of India launching its own anti-satellite missile system (A-SAT) which is a technology that UK doesn’t have at the moment[19]. Secondly, such OneWeb launch develops UK’s own capability in launching its satellites that it now owns for the commercial and civilian purposes. Further potential would lie in providing high-speed, low-latency satellite services to the maritime industry and Internet of Things projects[20].

UK-Japan

Coinciding with the time of writing, UK Space Agency and Japanese Aerospace Exploration Agency (JAXA) had signed a Memorandum of Cooperation[21]. This is an important step after the history of collaborations between UK and Japan in space field. This includes Japan’s leadership of the world’s first commercial debris removal demonstration operated from Oxfordshire as well as collaboration between UK’s and Japan’s commercial actors to develop inRange[22] (in-orbit telemetry relay service for rockets[23]). Given that UK and Japan share a history of developing their space capabilities early but then slowing down with further development, including the military capabilities[24], such potential cooperation would become important in future political and commercial collaborations.

 

  1. Space strategies of other countries - legislative mechanisms

The paper will look at the other space strategies that other countries have undertaken from legislative perspective and analyse what the UK could learn and integrate into its own strategy.

 

Luxembourg

Luxembourg was one of the first countries that developed its own space resources exploitation. Firstly, the paper will star with analysis of the Article 1 of the Law of 20 July 2017 on the exploration and use of space resources[25], which is the core of the entire act:

“Space resources are capable of being owned”

This is a clear message to the private actors that they have a legal basis for establishing their space exploration ventures for extracting and owning resources and is of the essence. Article 2 then establishes the requirement for a written permission.

Article 7 is an interesting mechanism that establishes a test for the operator. Under Article 7(2):

“The operator to be authorised shall have a robust scheme of financial, technical and statutory procedures and arrangements through which the exploration and utilization mission, including the commercialisation of space resources are planned and implemented. The operator to be authorised shall furthermore have a robust internal governance scheme, which includes in particular a clear organisational structure with well defined, transparent and consistent lines of responsibility, effective processes to identify, manage, monitor and report the risks it is or might be exposed to, and adequate internal control mechanisms, including sound administrative and accounting procedures, as well as control and security arrangements for its technical systems and applications”

This imposes a requirement that, subject to the operator’s own capabilities, he would have to establish procedures and arrangements that would make a mission possible in the first place. The operator would be responsible for setting out effective processes and consistent lines of responsibility which naturally would vary from operator to operator. However, the ultimate outcome is that the resulting framework would be mission compliant.

Similarly, Article 8 has an element of the objective test for the “sound and prudent operation”. Under Article 8(2), the criteria would include reputation of the operator, financial soundness of the shareholders, and successful due diligence for money laundering. This demonstrates a higher threshold for receiving such a license which, naturally, would increase the calibre of the applicant companies and their missions.  Finally, Article 10 provides for the risk assessment and insurance coverage. Although appears to be a standard provision, it includes the need for risk assessment which would increase chances of success. These elements place responsibility on operators to demonstrate such due diligence.

Moreover, any company can participate in such missions for exploration of resources whilst being 100% non-Luxembourg owned as long as the operator is a legal person with a registered office in Luxembourg that complies with relevant conditions. Such an element would be particularly relevant to the UK for the purpose of being seen as a space nation that promotes diverse business start-ups with lower barrier of requirement.

Overall, Luxembourg’s legislation is sophisticated, and UK would benefit from implementing a similar legislation.  Firstly, by allowing the mission for exploration of resources in the first place and placing a specific legal set of rules for it would be a great start. This would give investors certainty and confidence in the legislative regime and its guidance which in turn would result in more entrepreneurship ventures and stimulate the space economy. Given that the UK is already known as the financial hub of start-ups and investments, it would be only natural for the UK to extend its regime to such an emerging area.  Having such a framework would still require many details as will be seen in the next case study however it would be a good start for UK’s space resources industry. Finally, it would be important to ensure that UK complies with its international obligations and does not in any way condone appropriation or exercise of jurisdiction over the celestial bodies in question.

 

United Arab Emirates (UAE)

UAE is one of the countries that only recently started developing its space legislation. The relevant legislation here is the Federal Law No. (12) of 2019[26]. The federal law covers regulation of space sector and specific space activities that are outlined and defined within the legislation. This is the strong aspect of the legislation.

Article 1 covers a lot wider range of activities as opposed to the UK’s “space associated activities”. It also includes key definitions of “Space Activities”, “Space Objects”, “Space Debris”. Sometimes, such provisions would be vague, e.g., “Outer Space” being defined as “the area above Earth’s atmosphere” which could cause difficulties due to the ambiguity. However, the definitions strengthen the prospective legislation as it makes following the rules easier for companies.

Article 4 is the next important provision as it outlines regulated activities. Once again, this is absent from the UK’s legislation. This is an important element that grants certainty to companies which will know which one of their potential ventures is going to be regulated by the relevant legislation. In no particular order, a wide range of examples in the UAE legislation include:

Articles 5-7 for the transparency purposes establish legal basis for the Emirates Space Agency and outline objectives and competencies in a very clear and coherent manner. Private actors could appreciate the duties of the Emirates Space Agency. UK has a potential for that as the UK Space Agency has most, if not all, of the functions related to space regulation. This simplifies the regulatory mechanism of the space agency, making it easier to approve missions.

The next part of the legislation is split in an interesting manner. For instance, whilst Luxembourg had its own separate legislation dedicated to the exploration of space resources, UAE incorporates it as a mini-regime. For instance, Article 14 of Chapter 3 is regarding the permits for Space Activities. As Space Activities were already defined, this makes the length of Article 14 appropriate without the need to discuss or cover individual activities; in fact, it mirrors UK’s legal provisions about the flexibility of licensing conditions as done under Article 14(2).

Article 16 provides a special mini-regime for the manned spaceflights. In this case, for instance, UK has more sophisticated regime, as its Schedule 1 in SIA 2018 provides for the training and safety regulations that are far more extensive. Similarly, Article 18 regarding the exploration of space resources is another example. It would be the only provision along with Article 14 and definitions that would cover space resources. In comparison with Luxembourg’s legislation, it would lack a lot of detail.

However, it is submitted that a mini-regime is more effective in developing legislation and covering space-related matters than the complete absence of it. For instance, in UK’s SIA 2018 (Schedule 1 (1) (g))[27] there is reference to the space debris guidelines as part of consideration for the license which is a relatively limited engagement with space debris issue. In UAE’s federal law, Article 19 dedicates its provisions to space debris mitigation making it more effective and enforceable. For instance, there is a higher duty where operators are to inform the UAE Space Agency of the measures and plans to mitigate for space debris. Article 22 supplements that, by putting into context any collisions in space and potential steps to resolve that. The result is more certainty to the start-ups which now have higher incentive to follow such space debris provisions.

Overall, UAE’s legislation goes into details and definitions as well as covers a wide range of activities, all in one legislation. It establishes UAE Space Agency and its competencies in a transparent and coherent manner. It has legislative mini-regimes for different sub-activities, some of which may sometimes lack details and leave a lot in the hands of the Cabinet, akin to the UK’s Secretary of State and his discretion. However, such mini-regimes also provide some guidance to private actors rather than omitting them completely. UK could learn from potentially implanting such mini-regimes or defining its terminology in greater detail. Equally, it could also focus on such unattended matters, as space debris and space resources extraction.

 

United States of America (USA)

One aspect of the United States’ legislative prowess included its successful integration of COSPAR guidelines into its space agency NASA. COSPAR guidelines[28] are fundamental for the planetary protection policy which is a set of rules required to prevent backward or forward contamination, i.e., bringing bacterial back to Earth or to the new planet. This is essential for space exploration in order to avoid environmental contamination of Earth, and especially other planets to avoid long-term contamination. The COSPAR guidelines are not mandatory under the international law however can be transposed into the national legislation. The USA’s policy was incorporating it into NASA’s policy requirements, for instance, Planetary Protection Provisions for Robotic Extra-terrestrial Missions under NPR 8020.12[29]. Moreover, there are mission classifications. Missions can range from Mission I (no protection required) to Missions IV and V (respectively, high standard for ensuring sufficient safeguards to avoid contamination of another planet and high standard of protection required to prevent Earth’s contamination upon return missions). The person in charge of assessing the missions and planetary protective measures is designated planetary protection officer.

At the moment, UK does not have its own planetary protection policy or compliance framework with COSPAR guidelines. The current situation is that UK has to comply with ESA’s COSPAR guidelines[30] that it integrated on behalf of all the member states that partake in ESA’s missions. However, if the UK decides to pursue its own missions, it will need to eventually integrate COSPAR guidelines into its own legislation to attain independence from other space agencies’ guidelines. It would also establish its status as a highly compliant space nation with a focus on responsible space exploration.

 

China

As the superpower, China has the least information on its space legislation. It does not have any space legislation besides licensing requirements[31]. It has underdeveloped space laws related to separate areas, such as planetary defence, planetary protection policies, space traffic management and natural resources. Although, it is important to note that China has a lot of individual missions, such as aiming to build independent space station[32] and current mission to explore Martian surfaces[33] for new discoveries. Overall, however, lack of detailed legislation and transparency would naturally reduce foreign investment into country’s space programmes or development of start-ups.

The lesson here for UK would be to continuously maintain the transparency of its legislation and clarity to ensure boosted investor confidence both on domestic and international levels. The lack of transparency in legal rules or absence of the rules in the first place (similar to the absence of mini-regimes as described above) would deter the kind of commercial interest that UK as a space nation would need to uphold. Secondly, it is important for the UK to develop its own high-calibre missions to continuously maintain its image as a space nation. Previously, UK had taken a backseat and its strategy lacked high-calibre space exploration missions.

 

Conclusion:

This paper looked at the UK and its individual legislative and institutional aspects, and partnership aspects, such as the treaties and joint collaboration programmes. The paper then reviewed different space strategies of other countries from a legislative perspective and put forward the elements that UK would benefit from and elements that would be detrimental to it. Overall, the paper summarizes that the UK has good prospects of becoming a fully-fledged space nation as seen from its current legislative efforts, joint collaborations on a wide range of space missions and actively developing its institutional military capacity as a superpower. The focus on commercial space is also starting to develop given the legal efforts and consultations taken from academia and the private actors. However, it is submitted that the UK would need to take more active efforts to address its current gaps and prevent stagnation or falling behind in its space endeavours. Having reviewed Luxembourg, UAE, USA and China, one can observe the strengths and weaknesses that such countries have in their space strategies. The UK would benefit from legal mini-regimes that can cover the current gaps, including integration of COSPAR guidelines, as well as from sophisticated national space legislation in the context of transparency and accountability. Such steps are likely to further the UK’s status as a space nation which will be diverse in its endeavours and freely integrate its space capabilities across areas of commercial and military applications.

 

(June 2021)


[1] LLB (2018) graduate from London School of Economics and LPC (2020) graduate from BPP University

[2] know.space, “Size & Health of the UK Space Industry 2020,” 2020, www.know.space.

[3] UK Government, “Outer Space Act 1986” (1986).

[4] United Nations General Assembly, “A. Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer Space, Including the Moon and Other Celestial BodiesUnited Nations, Treaty Series, Vol. 610, No. 8843.,” UNOOSA § (1967), https://doi.org/10.5771/9783845266343-225.

[5] UK Government, “Space Industry Act 2018” (2018), http://www.legislation.gov.uk/ukpga/2018/5/contents/enacted/data.htm.

[6] Ministry of Defence, “Guidance UK Space Command,” 2021.

[7] Parallel Parliament, “Written Questions - UK Space Command,” 2021, https://www.parallelparliament.co.uk/question/2878/uk-space-command-finance.

[8] Ministry of Defence, “Defence in a Competitive Age,” 2021, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/971859/_CP_411__-_Defence_in_a_competitive_age.pdf.

[9] Ministry of Defence, “Guidance UK Space Command.”

[10] United States Space Force, “Spacepower, Docrine for Space Forces,” 2020, https://www.spaceforce.mil/Portals/1/Space Capstone Publication_10 Aug 2020.pdf.

[11] Ministry of Defence, “UK Poised for Take-off on Ambitious Defence Space Strategy with Personnel Boost,” 2018, https://www.gov.uk/government/news/uk-poised-for-take-off-on-ambitious-defence-space-strategy-with-personnel-boost.

[12] Joanne Wheeler and Vicky Jeong, “The Space Law Review : United Kingdom,” in The Space Law Review, 2nd ed. (The Law Reviews, 2020), https://thelawreviews.co.uk/title/the-space-law-review/new-zealand.

[13] UK Space Agency, “International Treaty: The Artemis Accords,” 2020, https://www.gov.uk/government/publications/the-artemis-accords.

[14] UK Space Agency, “UN and UK Sign Agreement to Promote Space Sustainability,” 2021, https://www.gov.uk/government/news/un-and-uk-sign-agreement-to-promote-space-sustainability.

[15] “UK-US Technology Safeguards Agreement (TSA) for Spaceflight Activities: Understanding the TSA,” 2021, https://www.gov.uk/government/publications/ukusa-agreement-in-the-form-of-an-exchange-of-notes-between-the-united-kingdom-and-the-united-states-of-america-on-technology-safeguards-associated/uk-us-technology-safeguards-agreement-tsa-for-spaceflight-activi.

[16] The Institution of Engineering & Technology, “UK Commits to Continuing Membership of European Space Agency,” The Institution of Engineering & Technology, November 29, 2019, https://eandt.theiet.org/content/articles/2019/11/uk-commits-to-continuing-membership-of-european-space-agency/.

[17] The Institution of Engineering & Technology.

[18] Thomas Seal, “U.K. Launches First Satellites With New Space Partner India,” BloombergQuint, December 18, 2020, https://www.bloombergquint.com/business/u-k-launches-first-satellites-with-new-space-partner-india.

[19] India Global Business, “Why Does India’s Space Adventure Cause Unease in the UK,” 2019, https://www.indiaglobalbusiness.com/igb-archive/why-does-indias-space-adventure-cause-unease-in-the-uk-india-global-business.

[20] Mike Schuler, “Latest Launch Brings UK-Based OneWeb’s Satellite Internet One Step Closer to Commercial Service,” 2021, n.d., https://gcaptain.com/latest-launch-brings-uk-based-onewebs-satellite-internet-one-step-closer-to-commercial-service/.

[21] UK Space Agency, “Strengthening Space Ties between the UK and Japan,” 2021, https://space.blog.gov.uk/2021/06/25/strengthening-space-ties-between-the-uk-and-japan/.

[22] UK Space Agency.

[23] Inmarsat, “Inmarsat Selected by UK Space Agency to Develop Satellite-Based Rocket Launch Telemetry System,” Inmarsat, 2021, https://www.inmarsat.com/en/news/latest-news/government/2021/inmarsat-selected-to-develop-satellite-based-rocket-telemetry.html.

[24] Alexandra Stickings, Aki Tonami, and Jun Nagashima, “Security at the Frontier UK – Japan Perspectives on Cyberspace , Outer Space , The,” 2021, https://www.chathamhouse.org/sites/default/files/2021-04/2021-03-30-UK-Japan-security-perspectives-Taylor-et-al.pdf.pdf. p. 17

[25] Luxembourg Space Agency, “Law of 20 July 2017 on the Exploration and Use of Space Resources.” (2017), https://space-agency.public.lu/en/agency/legal-framework/law_space_resources_english_translation.html.

[26] UAE Government, “Federal Law No. (12) of 2019” (2019), https://www.moj.gov.ae/assets/2020/Federal Law No 12 of 2019 on THE REGULATION OF THE SPACE SECTOR.pdf.aspx.

[27] UK Government, Space Industry Act 2018.

[28] COSPAR, “COSPAR ’ s Planetary Protection Policy” (COSPAR, n.d.), https://cosparhq.cnes.fr/assets/uploads/2019/12/PPPolicyDecember-2017.pdf.

[29] NASA, “Procedural Planetary Protection Provisions for Robotic Extraterrestrial Missions Responsible Office : Office of Safety and Mission Assurance SPECIAL ATTENTION : ONLY USE NID 8020 . 109A , NASA Interim Directive : Planetary Protection Provisions for Robotics,” 2021, https://nodis3.gsfc.nasa.gov/npg_img/N_PR_8020_012D_/N_PR_8020_012D_.pdf.

[30] European Space Agency, “Planetary Protection,” 2021, https://www.esa.int/Science_Exploration/Human_and_Robotic_Exploration/Exploration/ExoMars/Planetary_protection.

[31] Cara P Cavanaugh et al., “An International Perspective on Planetary Protection Policies ( Presentation ),” The Institute for Defense Analyses, 2020.p5-p6

[32] Jonathan Amos, “China Space Station : Shenzhou-12 Delivers First Crew to Tianhe Module,” 2021, https://www.bbc.com/news/science-environment-57504052.

[33] Cavanaugh et al., “An International Perspective on Planetary Protection Policies ( Presentation ).” P5-p6