Written Evidence Submitted by the EMEA Satellite Operators’ Association (ESOA)




ESOA is a CEO-driven association representing 22 global and regional satellite operators including several companies with a vested interest in the UK including Inmarsat, Avanti, Astroscale, OneWeb, SES, Intelsat, Viasat, Echostar Mobile, ManSat, Telespazio, Airbus and TAS. We are pleased to submit our comments to the UK Parliament’s Science & Technology Committee’s Call for Evidence on UK Space Strategy and UK Satellite Infrastructure on behalf of the ESOA membership.


1/ What are the prospects for the UK’s global position as a space nation, individually and through international partnerships?


The UK has a strong and credible reputation in the world across a range of disciplines relating to space. These include engineering, science, regulations & law, broadcasting and data services, defence and environmental monitoring. The UK’s ability to foster International partnerships has proven to be invaluable in all of these disciplines and should continue to expand into the future. In recent years, the UK has placed space as one of its key economic development drivers with ambitious targets to be a leading global player. This is evident from the recently adopted Space Industry Act 2018 (SIA) which aims to enable companies to use cutting edge technology while also safeguarding public safety and minimising the impact of spaceflight activities on the environment. The UK government, industry and academia support of ESA and the list of government backed vehicles such as the UK Space Agency, Satellite Application’s Catapult, Civil Aviation Authority, Tech UK, the Leicester and Harwell Space Parks and programmes such as Launch UK and the Space Sector Export Academy are commendable initiatives to promote and educate the space economy.

The UK has every opportunity of becoming a leading nation in the global space economy. As space continues to weave its way into everyday life, the UK’s dependency upon space and its place in the global space arena requires:

  1. responsible regulation and spectrum management with respect to the continued and increasing space services provided by companies with UK interests noting that the UK is often seen as a benchmark/example for other nations and that space services need regulatory certainty in terms of access to spectrum on a viable and sustainable basis in existing ITU frequency allocations at L, S, C, Ku, Ka and Q/V bands which does not compromise quality of service offered to customers;
  2. protection of the nation’s space assets through international cooperation and support for satellite operators on the international stage; and
  3. leadership on initiatives and activities such as space debris mitigation and space traffic management.

    2/ What are the strengths and weaknesses of the current UK space sector and research and innovation base?


The UK has a strong and enviable historical track record in R&D and innovation. A key strength of the UK is the acknowledgment that space is a no longer an opportunity but is an essential element in the nation’s future. Space is now embedded in policy making across the entire range of national responsibilities such as supporting the UK’s Emergency Services Network and the global targets related to climate change and peaceful coexistence.


However, the UK is one of an increasing number of nations vying to become world leaders in the space economy. It is essential then that the UK continues to invest in innovation and education to ensure the next generation of entrepreneurs have access to an educated and skilled workforce. Arguably, the current UK investment in space and particularly education is geographically fragmented and exposes social inequality and gender discrimination. More needs to be done to open space to the masses and to close the divide.


Another weakness is the lack of a licence regime for launch and space flight. The UK can garner a national advantage through hosting its own launch facility, which will introduce diversity of supply and resilience into the space launch segment. Although the UK was an early advocate for a national launch facility, administrative delays and red tape appears to have delayed the licencing of space access and the UK is now playing catch up. This is now critical and must be addressed as a matter of urgency. The UK should not rule out the notion of partnering with other neighbouring nations to strengthen and accelerate its global position.



3/ What lessons can be learned from the successes and failures of previous space strategies for the UK and the space strategies of other countries?


It is important to acknowledge that the space ecosystem is now an integral and essential element of daily life without which people cannot function. Space can no longer be thought of in isolation from the everyday activities on earth. Previous strategies segregated space as an isolated domain of curiosity and primarily the responsibility of government and often did not consider it as a mainstream topic or a substantial contributor to the nation’s economy. The UK has an opportunity to accelerate the space economy by easing barriers to private enterprise and adopting a regime of regulations to encourage and foster innovation and access to space. Post-Brexit, the UK must shun protectionism and foster international cooperation and partnerships with allies, particularly in space.



4/ What needs to be done to ensure the UK has appropriate, resilient, and future-proofed space and satellite infrastructure for applications including navigation systems, weather forecasting, earth observation including climate change and communication including broadband?


As ESOA members provide satellite communication services, our response is provided in this context.


Technology development: Satellite communications continues to be the leading application for space-based technology. A key focus must therefore be the continued development of higher performance systems, on board processing, antenna design for beam forming networks, inter-satellite mesh communications, quantum key encryption, electric propulsion, and on the ground universal multi-band/multi orbit terminals.


Interoperability between systems: The UK should focus on creating a next generation workforce suitably skilled and knowledgeable in the entire range of space activities and their connection with terrestrial activity. The success of 5G, 6G and beyond will depend on a Network of Networks that can deliver ubiquitous and seamless services and satellite technology is key.



Research & Development Funding: Continuing support for R&D funding and encouragement for private investors is critical to a national space strategy. However, government should employ a hands-off approach and ensure parity between companies by, for instance, not offering preference to state-owned entities over existing national operators, noting that different players contribute in different ways. Government should also not discourage the creation of a local presence of foreign operators. A fair playing field must be upheld if the UK is to become a leading global space economy.


Spectrum Management: It is important for industry that the UK government provide assurances of stability and consultation when developing and enacting a space strategy. Guarantees on spectrum availability and interference prevention is critical to provide industry the confidence to invest in technology development for often 20-year life cycles. Satellite communications services need regulatory certainty in terms of access to spectrum on a long term, viable and sustainable basis in existing ITU frequency allocations at L, S, C, Ku, Ka and Q/V bands which does not compromise quality of service offered to governmental and civilian customers. Similar considerations apply to other important space services - such as earth observation, meteorological and navigation services - in their relevant ITU frequency allocations.


Space Debris Mitigation: The UK, as a signatory of the G7, the UN Long Term Sustainability (LTS) Guidelines (2019) and Artemis Accords, has shown strong leadership by recognizing the need to mitigate “the growing hazard of space debris and congestion in earth’s orbit”[1]. The UK should continue to take a leadership position in international regulatory fora (e.g. UN, ISO, IADC) to promote the development of forward-looking fit-for-purpose guidelines and norms which go further than the present UN 2019 LTS Guidelines and 2019 IADC Guidelines so as to more comprehensively assess the risks of in-orbit collisions involving space systems (especially large constellations in LEO orbits) and to robustly address the growing hazards of the space environment by ensuring that satellite systems are safe, can reliably maneuver to minimize the risk of in-orbit collisions and creation of additional debris and in the case of LEO satellites to rapidly deorbit (within 5 years of end of service life.  Beyond the commitment to create more robust international space debris mitigation guidelines, it is imperative that the UK (and other countries) ensure that systems launched from or serving the UK are safe and can reliably maneuver to mitigate the risk of collision and creation of additional debris.


Space Traffic Management: There are some significant issues that require cooperation and leadership on a global scale such as space traffic coordination and space security. The UK should be a leading participant in this cooperation leveraging the best practices of its existing national legal framework and regulatory experience and that of its operators, providing foresight and intelligence in shaping whatever governance may arise at the international level for the future. The UK should continue to be bold in its position, together with like-minded allied nations, against the weaponization of space. In this regard the UK should also encourage and develop lasting relationships with other nations. The UK should also encourage and develop lasting relationships with other nations, sharing knowledge, relevant data and skills on joint developments.

In parallel, the UK should consider the development of an ad-hoc space traffic management solution for the early detection of possible conjunctions and to support the determination of the most appropriate avoidance manoeuvers. Such capabilities will assist new entrants that potentially lack competency on orbital dynamics, to outsource such competences and scale up in a safe and sustainable way.


(June 2021)

[1] https://www.gov.uk/government/news/g7-nations-commit-to-the-safe-and-sustainable-use-of-space