The critical role of environmental assessment in UK space activity licensing
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 of preparing several of the UK’s first assessments of environmental effects (AEEs) in these early days of Space Industry Regulations, including those of SaxaVord Spaceport, Rocket Factory Augsburg and Skyrora Limited; all of which have now received licences. Aurora is currently assisting several other launch operators with the preparation of their own AEEs.
The UK is in the midst of a step change in space sector activity and capability, with the first vertical launch from British soil scheduled within months. Aiming to become an international hub for commercial spaceflight and related technologies, 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.
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). An 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). Although not considered topics in themselves, an AEE also needs to demonstrate consideration of major accidents and disasters, transboundary effects and cumulative effects, in relation to the listed topics.
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 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 a spaceport and its 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),
- 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.
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.
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 stage tests and 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 operator
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, it is 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.
For the multi-operator situation, determining and assessing a ‘representative launch vehicle’ (or ‘RepLV’) to cover the majority of foreseeable launches from the spaceport can be beneficial to both parties, as it allows for business growth and development for the spaceport, and can also result in launch operators having only to submit additional assessments covering very specific elements of their operation, outside the envelope of the RepLV.
This level of complexity and interdependence requires close collaboration with partners that may or may not yet have signed contracts from the outset of the spaceport AEE process. Tricky, perhaps, but of mutual benefit to both parties and 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.
Environmental governance will underpin a responsible space sector in the UK
As development and determination of AEEs has progressed, transparency of regulatory approach and an availability for insight and guidance from the CAA has been a huge benefit. And with SaxaVord Spaceport and two vertical launch operators now licensed for UK launch, the expectations of the regulator and the data requirements from applicants are now much better understood, making for a smoother and shorter AEE process all round.
What has been clear from the outset of this industry is that with UK sights set on being the pre-eminent European location for satellite launches, thorough and robust AEE and development of steadfast, practicable management plans are rightly required by the CAA in order to ensure the UK becomes a beacon for sustainable sub-orbital and orbital launches in this decade and beyond.
A major milestone for assessment of environmental effects will be reached in March 2026 with the publication by ISEP of Good Practice Guidance for the Assessment of Environmental Effects to support the preparation, review and updating of AEEs. As co-founder and co-author of this guidance, Aurora is proud to be at the forefront of UK space regulatory response and working alongside expert co-professionals to deliver direction, recommendations and solutions to advance space sustainability.
An earlier version of this article appeared in Satellite Evolution Global in October 2022. Please contact Ruth at ruth@aurora-environmental.co.uk if you would like further information.
