The accelerated growth of the space sector in the UK demands an ever greater need to assess and quantify the impacts of this new and burgeoning industry, particularly when it comes to the safety and environmental consequences of such operations. In this article, Ruth Fain shares her experience preparing assessments of environmental effects (AEEs).
The UK is seeing a step change in space sector activity and capability, with both horizontal and vertical satellite launches from British soil scheduled within months. Aiming to become an international hub for commercial spaceflight and related technologies, and with one eye on the fact that only 10 countries currently have their own launch capabilities, the UK Government is committed to building one of the most innovative and attractive space economies in the world, supporting the growth of a robust and competitive commercial space sector.
With this acceleration comes an ever greater need to assess and quantify the impacts of this new and burgeoning industry, in particular the safety and environmental effects of such operations.
The Space Industry Act 2018, with the associated Space Industry Regulations 2021, provides the legal framework for the licensing of space, sub-orbital and associated terrestrial activities and sets out the requirements of the regulator, the Civil Aviation Authority (CAA).
Any organisation looking to operate a spaceport or launch vehicles from the UK is required to apply for the relevant licence, which includes undertaking an assessment of environmental effects (AEE). AEE must consider the effects from space operations on population and human health, biodiversity, air quality, water, noise and vibration, the marine environment, climate, land, soils and peat, landscape and visual impact and material assets (cultural heritage). With the regulations only just a year old, the first AEEs are only now being considered for approval by the CAA.
In this article Ruth Fain shares her experience of preparing AEEs. Ruth and her team have submitted two AEEs to the CAA for consideration to date; one for the SaxaVord Spaceport in Shetland, and the other for Skyrora Limited, a Launch Operator looking to launch the Skyrora XL launch vehicle in 2023. ITPEnergised is also currently assisting several other launch operators with the preparation of their own AEE.
What the approval process for an AEE involves
AEE is just one facet of the licence application for a spaceport or space launch operation. However, due to the nature of the assessment it can become a consuming factor in terms of both time and resource. Though the process may feel familiar given similarities to the environmental impact assessment process required under UK Planning regulations, there are key differences in geographical and temporal scope and the assessment methods needed to assess these. There is also a unique interplay between the spaceport and the launch operators which requires focus and cooperation.
The AEE process is split into four main stages – preparation and content of the AEE, conducting the AEE, Regulator review (and licensing) and post-licence continuous review. The Regulator review stage is also split into stages with Block A comprising the initial screening and feedback and Block B comprising full assessment and public consultation prior to determination of whether a licence can be issued.
The CAA has now issued guidance for AEE and in July 2022 followed this up with additional notes on Block A expectations. As we progress through the licence application process working with both operators and the CAA it is clear that the UK, through the CAA, is setting and maintaining a high bar for environmental protection.
Key considerations for AEEs
Understanding and making clear the geographical and temporal scope of proposed space operations is paramount to a successful AEE. The Environmental Zone of Influence will likely differ over the environmental topics considered, and representing and communicating this, and what it means in terms of receptor experience, is key. Equal to this is understanding how effects vary with time – whilst a single launch is a discrete and short-lived event, cumulative effects through time must be considered and reported to ensure the environment and identified human and ecological receptors are protected.
The physical mechanics of a rocket launch also adds a level of complexity to both air quality and noise modelling and depending on location and trajectory of the launch there may be a need for additional modelling to appraise the effects of sonic booms and marine chemistry interactions. With no previous assessments to work from, ITPEnergised has developed a team of specialists using partners from across the UK and USA to identify and apply best practice to the process throughout.
As with any novel industry, the lack of UK datasets to support AEE also poses a constraint. For the SaxaVord Spaceport AEE, it was necessary to draw on surveys and datasets from other countries, particularly regarding noise and ecological effects, and to undertake the assessment using a precautionary approach where data was scarce. As a result of this, and even though no significant effects are predicted within the AEE, SaxaVord is looking to undertake noise and ecological monitoring during a range of launches, covering launch vehicles of different size and scale, so as to develop a working database which they, the regulator and other interested parties may interrogate in the future.
Finally, the consideration of effects along the path of the launch trajectory is another bespoke and potentially complex area of assessment. Not only do the physical, chemical and biological interactions of return to earth debris need to be identified and assessed, but also socio-economic and geo-political factors of launching through multiple marine and airspace zones.
The inter-relationship and differences between AEEs for spaceports and launch operators
There is an obvious and highly necessary inter-relationship between the AEE for a spaceport and all associated AEEs for launch operators based at the same location.
In cases where a spaceport has only one launch operator engaged, such as Spaceport Cornwall and Virgin Orbit, because the AEEs can mirror one another exactly in terms of launch number and launch vehicle specifics, it can be possible to develop a joint AEE. However, where the spaceport is looking to develop as a multi-operator launch site this is not possible as there will be multiple AEEs for launch operators covering a range of different launch vehicles and operating situations.
In this case, the two AEEs may develop in parallel dependent on timing but will always be separate documents. Depending on the business case for each operation, and the progress along research and development pathways, critical elements of interplaying data may be missing at the time of either AEE preparation.
Whilst under the regulations it is possible to apply for a spaceport licence without knowing the full details of launch vehicles, the CAA guidance states that ‘the applicant must [determine and] base their AEE on a reasonable worst-case scenario, based on the representative launch vehicle(s) they are aiming to attract.’ This requires detailed analysis of the likely scale, fuel type and physical formats of the proposed (or envisaged) launch vehicles and their anticipated trajectories, as well as the maximum number of launches to take place over one year. Even then, the CAA notes that should the anticipated launch vehicles change before the licence is granted, a revised AEE may be required.
This level of complexity requires close collaboration with partners that may or may not yet have signed contracts from the outset of the spaceport AEE process. As a result of their early engagement, the spaceport may then allow the Launch Operator to access the original assessments, reducing duplication of effort and enabling refinement and focus of the existing assessments to meet the exact specification and flight path of the specific launch vehicles being assessed. This inter-reliance and cooperation between a spaceport and Launch Operator is exactly in line with the ethos of the regulations which aim for all parties to work collectively towards the safest and most environmentally secure operation.
At such an early stage in the development and determination of AEEs, transparency of approach and seeking insight and guidance from the CAA, has been a huge benefit. As the AEEs submitted to date progress and feedback from the regulator and the public is received, we continue to work with the spaceports and launch operators to refine our assessments and ensure efficiency of process for future applicants.
What is clear already is that with UK sights set on being the pre-eminent European location for satellite launches, the CAA as regulator is demanding thorough and robust environmental assessment and development of steadfast, practicable management plans to ensure that the UK can become a beacon for sub-orbital and orbital launches in this decade and beyond.
This article was written by Ruth Fain, Head of Corporate, Industrial and Manufacturing at ITPEnergised, and appeared in Satellite Evolution Global in October 2022. Please contact Ruth at ruth.fain@itpenergised.com if you would like further information.
