- Parabolic Arc
- September 28, 2023
A Closer Look at the UK’s Commercial Space Review
Following the release of the document, “UK Government Review of Commercial Spaceplane Certification and Operations: Summary and Conclusions,” almost all media attention focused on one element of the report: the 8 candidate sites for the nation’s first spaceport.
This laser focus is easy to understand. The fierce, tooth-and-nail competition to land some big government project will be fun to watch. And spaceports are super cool. Well, they are when space planes are actually flying to space. When like a decade goes by with people promising imminent spaceflights without a single one taking place, spaceports become a lot less cool. (I’m looking at you…everybody in Mojave!)
But, I digress. I went through the 80-page document and the 321-page technical report its based on so you don’t have to. Why would I do this? Because you guys are the best! You’re very welcome.
Key excerpts follow with commentary as appropriate. Read away!
SPACE TOURISM MARKET ANALYSIS
Spaceflight experience is expected to be the first market for commercial spaceplane operations….Market research undertaken by Surrey Satellite Technology Limited (SSTL) indicates that UK demand for such flights would start at around 120 paying participants per year, increasing to 150 per year by year three. A rough calculation based on the proportion of capacity of the two businesses that are most likely to be able to offer spaceflight experience in the next few years (Virgin Galactic and XCOR Aerospace) and their corresponding prices would indicate annual revenue from spaceflight experience of approximately US$19 million in year one and US$24 million by year three. In the medium term, it is expected that the number of spaceflights will increase in line with demand, up to perhaps 400+ participants in year 10, offering annual revenues of US$65 million…..
These projected revenue figures are dependent on a number of factors, such as the ability to reduce prices, the presence of appropriate weather conditions, supply sufficiently meeting demand and the possibility that the market for spaceflight experience could be a short-term bubble, with demand declining relatively quickly. However, if take-up is as predicted, then in only a few years time, annual revenues from spaceflight experience alone would outstrip the estimated capital costs of developing an operational spaceport at an existing aerodrome.
[Editor’s Note: This is a good sized market. XCOR’s Lynx carries one passenger, so if it captured the entire market that would mean 120 flights per year to start. Virgin Galactic’s maximum flight rate is uncertain. SpaceShipTwo is set up to carry six passengers. However, sources indicate that weight growth and engine performance has reduced the load to four. So, flying all 120 passengers would translate to 20 or 30 flights depending upon capacity.
These are just two examples. It should be noted that the UK is also eying other tenants for the spaceport, including Reaction Engines, Swiss Space Systems, Airbus Defense and Space, Bristol Spaceplanes, Stratolaunch Systems, and Orbital Sciences Corporations. These companies are developing crewed and un-crewed systems capable of suborbital or orbital launches.
Weather conditions in the notoriously cloudy UK will play a major role in determining whether space tourism takes root there. Passengers want to look down and see something other than bad weather. Virgin Galactic has canceled flight tests of SpaceShipTwo due to windy and overcast conditions in Mojave.
Companies will need to take weight these factors in deciding whether to operate in the UK. How much time will they likely to be grounded by weather? How much havoc do these delays create for wealthy clients who are often pre-0ccupied with business concerns and are on tight schedules? Is the spaceport conducive to other markets such as microgravity experiments and satellite launches, which would be less affected by overcast skies?]
SATELLITE LAUNCH MARKET
A large proportion of launch orders are derived from European demand. In 2012, 11 of the 25 recorded orders were from Europe. The only operational launch capability within Europe at the time of writing is in Sweden, and to date it has only been used for sounding rockets and scientific balloons. This suggests that a UK launch capacity would have a good chance of gaining some of these orders due to geographical proximity and lower costs – though it is important to be clear that, due to its northerly latitude, the UK is only suitable for launching satellites into polar orbit (as opposed to equatorial orbit).
The exact demand is hard to predict, and in the short term it may amount to only one or two launches per year; however, this would be expected to increase as spaceplane technology evolves….
A number of reviews have identified that the only suitable location in the UK for vertical launch is on the north coast of Scotland. This would require a new vertical launch spaceport to be built – so would not meet our goal of enabling spaceplane operations in the short term.
[Editor’s Note: Most rocket launches are to the east to take advantage of the Earth’s rotation. (Israel is the only nation that launches to the west, but not very often.) Continental Europe lies to the east of Britain, and you don’t want a failed launch coming down on a populated area (although this has never stopped the Russians and Chinese).
Some systems, such as Skylon and the Lynx Mark III, would reach suborbital space prior to releasing rockets they are carrying. So, those systems might work better from the UK once they are operational.]
Scientific Research and Development
Increasing access to space offers opportunities for advanced manufacturing and scientific research with potentially very large returns for the UK economy. Space environments provide exposure to microgravity, extreme radiation, vacuum and other stressors. These extremes allow for new insights into fundamental scientific processes and the development of new industrial capabilities and products of benefit to UK industry – even in as short a period as 4–7 minutes of exposure to the space environment.
Importantly, these are realised not simply through the ability to carry materials into space, but also through the entire process of preparation for, and analysis of, space travel. It is a very high-tech, research-intensive sector, which creates significant spillover benefits into other scientific disciplines. Industry commentators note that the spaceflight experience and scientific research and development (R&D) markets are highly complementary, because the costs of developing vehicles can be shared across the markets – the cost and risk of developing a product for just one market segment alone would be prohibitive.
Although it is always difficult to establish the monetary value of R&D to the UK economy, it is generally accepted as being extensive: it is estimated that spillover benefits from R&D generate a social return on investment of a further 20–50 per cent. For basic medical research, it is estimated that there is a perpetual return of £0.50 for every pound invested in biomedical research after the introduction of a therapy. It has also been shown that a £1 increase in public spending on basic biomedical research increases private spending by £2.20 to £5.50.
UK REGULATORY FRAMEWORK
[Editor’s Note: Lawyers for Britain’s Civil Aviation Authority (CAA) and Department of Transport (DfT) have concluded that space planes fall under the purview of the European Aviation Safety Agency (EASA), which is looking to put the vehicles under rigorous safety certifications. The process will be expensive and take years, and EASA hasn’t even begun to write the regulations. All this puts the 2018 target start of flights from a UK spaceport at risk.
However, British officials think they have found a way around the regulations….]
At this stage of their development, commercial spaceplanes cannot comply with these regulations: technology will need to be developed and mature before it can comply with the norms of commercial aviation….
However, there is an alternative option. Under Annex II of the EASA Basic Regulation, some categories of aircraft are excluded and remain subject to national regulation. These include ‘aircraft specifically designed or modified for research, experimental or scientific purposes, and likely to be produced in very limited numbers’. We recommend that we use this exclusion to allow initial spaceplane operations to take place in the UK, designating spaceplanes as ‘experimental’ aircraft for the short term.
Recommendation: To enable spaceplane operations to start from the UK in the short term, we recommend that sub-orbital spaceplanes are classified as ‘experimental aircraft’ and treated as Annex II aircraft under the EASA Basic Regulation. This will allow regulation of sub-orbital spaceplanes to be managed at a national level.
[Editor’s Note: This would be a short-term solution. UK regulations would be harmonized with those promulgated by EASA, with vehicle being certified between by 2030 or earlier. The big question is whether the EASA will allow it. A big fight could result between the British government and European regulators.]
AIRWORTHINESS & EXPORT RESTRICTIONS
- give due recognition to safety evidence verified within the FAA AST system;
- permit suitably capable operators to include the management of spaceplane design, production and maintenance risks as an integral part of an approved safety management system; and
- provide, in due course, a spaceplane certification and continuing airworthiness system aligned to that in use for international commercial aircraft operations.
However, it is important to underline here that this approach would only work for US operators if they are permitted, under ITAR [International Traffic in Arms Regulations], to give the CAA sufficient information about their safety management systems, including spaceplane design and manufacturing and maintenance processes. This requires that ITAR controls are addressed.
Recommendation: The UK Government should enter into early discussions with the US Government and the US sub-orbital industry to obtain appropriate export licences to commence operations in the UK.
Recommendation: In order to obtain a better understanding of the FAA AST licensing process and the safety performance of any US sub-orbital spaceplanes that are likely to operate in the UK, the DfT should agree a Memorandum of Understanding with the FAA AST.
Recommendation: Work should be commissioned to develop, within the airworthiness assessment approach, a methodology for giving due recognition to FAA AST licensing system assessments.
[Editor’s Note: With the U.S. government’s decision to leave reusable launch vehicles on the Munitions list, this whole area presents what the British call a sticky wicket. U.S. companies will be strictly limited in what they will be able to tell foreign nationals about vehicle design and safety. Such issues are worked around for satellite launches involving U.S. and foreign countries. However, the stakes are obviously much higher with human spaceflight.]
PASSENGER TRAINING, SAFETY & MEDICAL REQUIREMENTS
The FAA AST [Federal Aviation Administration Office of Commercial Space Transportation] has made clear that it accepts spaceflight is a high-risk activity; hence its regulatory approach is to focus on the protection of the uninvolved general public (also known as third parties)….
There is no UK or European regulation governing medical requirements for passengers in commercial air operations, but most individual operators have a medical advisory service for passengers with medical conditions and will determine whether they consider these passengers fit to travel. Spaceplane operators are likely to take a similar approach for their paying participants.
Overall, operators are likely to rely on participants giving specific, written, informed consent to their carriage on board a spaceplane and accepting the inherent risks. This is the intended practice in the US and is a reasonable approach for the carriage of participants on UK spaceplanes.
Recommendation: In order for sub-orbital spaceplane operations to take place from the UK by 2018 or earlier, a permissive regulatory framework needs to be established and be functioning at least one year in advance of planned operations.
Recommendation: The competent authority should ensure that medical assessment guidelines are reviewed once information has been gained from operational experience.
Recommendation: To further develop the regulatory framework, and help mitigate the risks to the uninvolved general public and spaceplane flight crew and participants, the Government should task the CAA with the detailed assessment of risks, and development of appropriate exemptions and special conditions to the ANO for sub-orbital spaceplanes.
[Editor’s Note: This initial approach mirrors the one being used by the United States, which focuses on passengers acknowledging the risks they are taking. The main focus is on protecting people on the ground who are not flying. The report also recommends leaving passenger training and medical requirements for participants in the hands of the companies for the immediate future.
The main question is how far Britain will be willing to go in terms of limited liability laws affecting spaceflight operators and vehicle builders and suppliers. Multiple American states have passed laws prohibiting lawsuits unless a passenger’s injury or death was caused by gross negligence or intentional harm.]
FLIGHT CREW LICENSING, TRAINING & MEDICAL REQUIREMENTS
A short-term solution: validating FAA AST processes
In the immediate term, this is not a problem. It is highly likely that initial operations will take place under a wet lease type arrangement: the spaceplane and its crew will be from the US and will have to meet FAA AST requirements.
Longer term: building a UK licensing model
If the UK is to become a lead player in the space sector, we will need our own cadre of spaceplane flight crew, and our own training and qualification systems. The foundations for these are likely to be established flight crew training programmes and qualifications, but additional elements will be needed.
This is exactly the process that has begun in the US, where a number of training organisations have built on their conventional flight training programmes to offer training in the additional skills necessary to maintain safety of the vehicle and the participants during spaceflight. These programmes have been approved by the FAA AST.
The UK has an established network of aeromedical examiners and aeromedical centres. With minimal additional training (possibly a one-week training course), these practitioners could undertake medical assessments of spaceplane flight crew.
Initially, it may be appropriate to assess each pilot pre-flight. Our knowledge of space medicine is still relatively small; in particular, there has been no experience of frequent sub-orbital missions, so it remains to be determined whether these have any unforeseen effect on pilot health or performance. Therefore, crew health should be monitored on a regular basis, to ensure that any effects of frequent exposure to this new environment are detected early.
Recommendation: The Government should ensure that medical requirements for spaceplane crew are developed at least a year before spaceplane operations commence in the UK, by international experts experienced in both aviation and space medicine, and that aeromedical examiners are trained to undertake the required medical assessments.
Recommendation: All flight crew must be suitably trained in the effects of high acceleration and deceleration forces.
Recommendation: The Government should explore with industry how sufficient and appropriate facilities can be made available to support the pre-spaceflight training of spaceplane flight crew in the long term – and in particular ensure that a modern long-arm centrifuge is available and accessible in the UK.
Recommendation: The competent authority should ensure that medical assessment guidelines are reviewed once information has been gained from operational experience.
SPACEPORT SELECTION CRITERIA
Identifying suitable locations for a spaceport is a complex balancing act. There are:
- essential operating criteria: based on available information about current spaceplane designs, a spaceport will need to be a large site and have a runway that is at least 3,000 metres (9,800 feet) long. For single-stage to orbit operations, such as SKYLON, a substantially longer runway will be required – potentially of around 5,000 metres (16,500 feet);
- safety factors: given our underlying priority of protecting the uninvolved general public, and the level of risk involved in spaceplane operations, the ideal location will be away from densely populated areas. It will also need the protection of segregated airspace;
- meteorological considerations: we know that strong crosswinds are likely to restrict initial spaceplane operations and that spaceplanes are likely to need to operate clear of cloud. There are also commercial issues involved here: being able to see the Earth from space is a key attraction of spaceflight experience, so if cloud cover restricts that, the experience may not live up to expectations;
- environmental concerns: there is a range of legislation for noise, air quality and use of hazardous materials that apply to aerodromes. These need to be considered with regard to the suitability of a site for spaceplane operations; and
- economic issues: a spaceport will need good transport links. Visitors (including spaceflight experience participants) must be able to get there with relative ease, but so must staff. Component parts may need to be brought to the site by sea. This must be balanced, therefore, with the safety requirement to have a remote location.
In general, for sub-orbital flights that are limited by cloud cover and wind speeds, locations in Scotland are likely to offer fewer hours of potential flight operations than locations further south in the UK. This is because, generally, hours of sunshine are fewer (cloud cover is greater), rainfall is higher and wind speeds are greater. The more challenging meteorological environment in these locations is, therefore, very likely to impact on the economic potential and viability of operations in these locations. Once sub-orbital spaceplane operators have confirmed their meteorological operating criteria, further in-depth investigation of these eight aerodromes can take place: the meteorological requirements for spaceplane operations may reduce the number of potential sites further.
[Editor’s Note: It’s been pointed out that six of the eight candidate sites are in Scotland, whose people could vote to secede from the United Kingdom on Sept. 18 and form their own nation. The report doesn’t address this possibility. However, suspicions have arisen that the large number of potential spaceport sites in Scotland is being used as a way to sway voters, despite the meteorological and geographical factors that weigh against building a spaceport there.]