Written Evidence Submitted by the British Standards Institution (BSI)
About the BSI
- BSI is the UK’s National Standards Body, incorporated by Royal Charter and responsible independently for preparing British Standards and related documents, and for coordinating the input of UK experts to European and international standards committees.
- BSI has over 115 years of experience in serving the interest of a wide range of stakeholders including government, business and society. As the UK’s national standards body, BSI has a public function in support of the UK economy and brings together stakeholders to facilitate the development of standards to underpin products and services. In this role, BSI provides the infrastructure for over 13,000 experts, who are the voice of UK economic and social interests, to be influential in the international standards organisations.
- BSI operates in accordance with a Memorandum of Understanding with the UK Government. BSI represents the UK view on standards in Europe via the European Standards Organizations CEN and CENELEC and internationally via ISO and IEC. BSI is a member of ETSI (The European Telecommunications Standards Institute) and provides support to DCMS through their membership of ITU (the International Telecommunication Union).
- This submission has been drafted with the support of BSI’s ACE/68 Committee, which acts as the management committee advising on standards in the following areas: Design engineering and production; Interfaces, integration and test; Operations and ground support; Space environment (natural and artificial); Programme management; European Co-operation for Space Standardisation; Space data and information transfer systems; Materials and processes; and Space debris. The Committee also serves the UK’s “mirror committee” for space standards, considering and making recommendations around developments taking place in ISO and CEN.
How standards of interest to the Space and Satellite sectors are developed
- The space industry is a key sector in driving economic growth. According to the UK Space Agency, the industry adds £7bln to the economy, supports 70,000 jobs and is growing four times faster than the rest of the economy. The UK presently enjoys 7% of the global space market.
- In developing products and materials that can support the Space and Satellite sectors, methodical and well-defined steps are taken to approve these for space applications. There is no leeway for failure in manned spacecraft projects. Product and materials requirements are set at different levels depending on performance, safety and reliability goals determined by spacecraft project managers. The materials and manufacturing processes in space system designs are cost drivers. Each system is managed by a different entity applying various M&P requirements.
- To ensure quality and reliability of such products and materials, there is a requirement for clear standardisation around the hardware and technology being used. The majority of standards in Space and Satellite technology emerge from the European Cooperation for Space Standardization (ECSS), of which the UK remains a full member. The UK also retains voting rights in CEN, and holds the same rights and responsibilities, as it did prior to Brexit.
- The ESCC secretariat is provided by European industry, including UK-based businesses (such as Airbus). Standards agreed by ECSS standards are usually proposed by industry, with these standards typically being progressed into CEN (European Committee for Standards), British and ISO standards. When initiating contracts for Space and Satellite applications, either for national Space Agencies or private companies, adherence to these standards have often become contractual requirements.
- It is important to note that while standards are voluntary, these provide confidence and certainty to operators within the designated sector, in this case those providing products and applications within the Space and Satellite sectors. While standards remain the minimum requirements, these drive improvements in their respective sectors, and a race to the top in terms of quality, safety and performance.
The contribution of standards to the Space and Satellite sectors
- Standards have assisted in the development of several applications and items of hardware. An example of an area of research that has benefitted from a clear and universal standard is that of space debris. This is a widely recognised challenge for operators of Space and Satellite technology, namely that the concentration of various objects in low Earth orbit (LEO) due to space pollution risks both collisions between these objects and satellites or spacecraft, and that such collisions could create further debris which could jeopardise future space activities. International cooperation has led to the agreement of guidelines into an overall standard, ISO Standard 24113, which details the most important requirements for Space debris mitigation. These requirements, which are updated on a regular basis to ensure that they reflect new technologies and current requirements, are commonly used when drafting contracts in this area.
- Development of ISO Standard 24113 was led by the UK, and it is now one of the most visible and internationally adopted standards for space technology, with all of the SE14 countries (including Japan, Russian and China) adopting this into their own national standards. However, it still needs to be recognised more widely. Greater numbers of private sector operators move into the Space and Satellite sectors (e.g. mobile phone providers), with one rocket now capable of taking up around 60 satellites per flight, and Constellation Systems growing at a faster rate as a result. This potentially places great pressure on the space environment. Satellites must be assured of being strong, robust, and secure as possible, and that they de-orbit as safely as possible at the end of their lifecycle. There is therefore a major need to ensure space companies that are putting satellites into space do so in a sustainable way. Private companies seeking to launch one or more satellites therefore need to understand their space obligations. Ensuring these businesses both recognise and pursue these standards will help protect the space environment for the future, and ensure the area around Earth remains commercially and ecologically sustainable.
Other areas in the Space and Satellite sectors that would benefit from standards
- Other areas in the Space and Satellite sectors where development and adoption of standards would support growth of the UK sector include space traffic coordination, Rendezvous and Proximity operations, as well as on-orbit operations. New standards frameworks are required, with the UK in a strong position to develop the first standard.
- For on-orbit operations, there is some activity being carried out in this area (such as communicating orbit data between operators, and early steps towards space traffic management), both from UK businesses and those in the European Union, however this remains an area of significant opportunity for UK-based firms. Since in addition to its reputation for high-class engineering, the UK is also home to significant expertise in related fields such as international law and insurance, which also require development to enable on-orbit services to develop fully. Areas for such consideration include technology and operations for rendezvous and docking, spacecraft modularity and related technologies to enhance serviceability, space surveillance and tracking, and future space traffic management procedures. Commercial development of these areas are, at best, at an early stage, and so are not yet ready for formal standardisation, but good practice can still be shared using Technical Specifications and other existing standards.
- Other areas of potential interest for development include commercial safety and security, with protection against attacks – whether cyber, terrorist, espionage, or hijacking – remaining a prominent concern among Space operators.
The importance of engaging with the sector and the standards communities
- In considering future policy and guidelines around the Space and Satellite sector in the UK, we urge government to ensure that its consults developers of standards as part of its industry engagement. This can help ensure that it remains informed of individual requirements needed to support the growth of the sector.
- An example of the requirement of such an approach is where the EU banned a number of materials, for example solder (lead and tin), under the Restriction of Hazardous Substances Directive. However, alternatives proved insufficiently strong or robust enough to work in space. While the EU granted an exemption to RoHS for military or space applications, and that components, solders and other applications continue with the more reliable tin-lead, it is not clear if this exemption will remain, or for how long. The UK must ensure that it listens to the Space and Satellite sectors to ensure this, and similar exemptions are granted for future legislation.