The Space Law Review: United Kingdom

Introduction to the national legal, regulatory and policy framework

i The UK's space programme

The United Kingdom's (UK) original space programme commenced in 1952. The first launch of a British satellite, Ariel 1, on a United States (US) rocket occurred in 1962, making the UK the third nation in space. The Prospero satellite, also known as the X-3, was then launched by a British rocket in 1971. The UK remains a leader in space, particularly as a thought leader in regulation.

In 2010, the industry, government and academia collaborated to create the Space Innovation and Growth Strategy (IGS). As a result of the IGS, the UK Space Agency (UKSA) was created, a National Space Policy was published and several regulatory changes were implemented. A space cluster was also established in Harwell, south Oxfordshire, leading to the creation of the Satellite Applications Catapult and the European Space Agency's European Centre for Space Applications and Telecommunications.

The space sector is a key growth area for industry, academia and the government, with the ambition of gaining 10 per cent of the global space business by 2030. As at 2020, £360 billion of the UK's gross domestic product was supported by satellite services.2

One of the goals of the UK government is to ensure that it continues to have a globally competitive and progressive regulatory regime, leading the global effort to make space more sustainable.

ii Legal framework

The UK was one of the early pioneers to adopt national space legislation to regulate the space operational activities of non-governmental (private commercial) entities in 1986 following Norway, Sweden and the US. The UK is also one of the founding Member States of the European Space Agency, having ratified the Convention for the establishment of a European Space Agency3 on 28 March 1978. The UK has ratified the four core United Nations (UN) space treaties.4 It has not, however, signed or ratified the Agreement Governing the Activities of States on the Moon and Other Celestial Bodies 1979.

History of the UK government's space policy

In the early 1980s, the government instructed the Space Division of the Department of Trade and Industry to establish an ad hoc committee to assess how UK space activities should be organised and make recommendations.5 In 1985, this committee became the British National Space Centre (BNSC), which was the government agency responsible for coordinating space policy. The UKSA was established on 1 April 2010 to replace the BNSC.

In July 2021, the Civil Aviation Authority (CAA) became the UK's space regulator. It will license space companies and their activities under the Space Industry Act 2018 (SIA) and the Outer Space Act 1986 (OSA), as described below. At the time of writing, the CAA has not yet granted any licences.

In September 2021, the UK National Space Strategy6 was published, which sets out the UK government's ambitions for the UK's activities in space, bringing together civil and defence policy. This was followed in October 2021 by the publication of the Scottish Space Strategy.7

Outer Space Act 1986

The OSA was the basis for the regulation of activities carried out in outer space by organisations or individuals established in the UK, in its Crown dependencies and in certain overseas territories8 until the SIA entered into force in 2021. Space activities carried out in or from the UK or by UK entities overseas were governed by the OSA. The OSA required entities that procured an overseas launch or operated a satellite in orbit from the UK to hold a licence.

Moving forward, the SIA and the regulations and rules made under it will regulate spaceflight and associated activities carried out in and from the UK, as described below.

The OSA, plus the amendments made to the OSA by the Deregulation Act 2015,9 will continue, however, to apply to and regulate activities carried out overseas by UK entities, such as:

  1. the procurement of an overseas launch of a space object; or
  2. the operation of a satellite in orbit from an overseas facility by a UK entity.

Space Industry Act 2018

The SIA received Royal Assent in March 2018 and came into force in July 2021. The SIA governs all space-related activities carried out in or from the UK, such as:

  1. the procurement of a UK launch (space or suborbital);
  2. launch (space or suborbital) and return (re-entry);
  3. the operation of a satellite in orbit from a UK facility;
  4. the operation of a spaceport in the UK; and
  5. the provision of range control services in the UK.

The SIA creates a high-level framework for commercial spaceflight operations and enables launches to take place from the UK. The following regulations and other documents provide the detailed provisions required to implement and apply the SIA:

  1. the Space Industry Regulations 2021 (the Regulations), which make provision to enable the licensing and regulation of spaceflight activities (including launch and in-orbit operations), spaceports and range control services;10
  2. the Spaceflight Activities (Investigation of Spaceflight Accidents) Regulations 2021, which establish a spaceflight accident investigation body and make provision as to the conduct of accident investigations;11
  3. the Space Industry (Appeals) Regulations 2021, which outline the decisions made by the CAA that may be appealed by a licence applicant or licence holder, and create the decision-making body to hear appeals and set the procedures and timescales for making and deciding appeals;12 and
  4. the Regulator's Licensing Rules, which support the CAA's power relating to the granting and renewal of operator, spaceport and range control licences under the SIA.13

In addition to the above, the Air Navigation Order applies to anyone intending to undertake the launch of a vehicle in the UK that is not capable of operating above the stratosphere (around 50km altitude).

The UK government has also published the following:

  1. Guidance on applying for a licence;
  2. Principles and guidelines for the spaceflight regulator in assessing ALARP and acceptable risk;
  3. Guidance for launch operator and return operator licence applicants and licensees;
  4. Guidance for spaceport licence applicants and spaceport licensees;
  5. Guidance for range control licence applicants and licensees;
  6. Guidance for orbital operator licence applicants and licensees;
  7. Guidance for the assessment of environmental effects;
  8. Guidance on security matters for applicants and licensees;
  9. Guidance on the investigation of spaceflight accidents;
  10. Guidance for applicants and licensees: Conduct of appeals of decisions made by the regulator under the Space Industry Act 2018 and the Outer Space Act 1986;
  11. Guidance on liabilities under the Space Industry Act 2018; and
  12. Guidance on duties for all licensees under the Space Industry Act 2018 including monitoring and enforcement by the regulator.

Regulation in practice

i OSA and SIA licence requirements

Licensing procedures and requirements

There are different licensing requirements for:

  1. different types of operator licences:
    • launch operator (in relation to launching a launch vehicle, or a carrier aircraft and a launch vehicle);
    • return operator (in relation to returning a launch vehicle, launched elsewhere than the UK, to land in the UK or UK territorial waters); or
    • orbital operator (in relation to procuring the launch of a space object into orbit, operating a space object in orbit or conducting any other activity in outer space (including lunar activities));
  2. a spaceport licence; and
  3. a range control licence.

The requirements for each licence are set out in the Regulations.

Applying for a licence

Applications for licences must be made in writing by completing the applicable forms, as specified in the Regulator's Licensing Rules, and must include any other information that the CAA may specify (such as an assessment of environmental effects in relation to the application for a launch operator or spaceport licence). The application fee is £6,500 per licence. This is a one-off fee.

Certain 'eligibility criteria' will need to be met and evidenced as set out in Regulations 5 and 6 of the Regulations on the submission of the licence application for the application process. When completing the application forms, the applicant must confirm that the proposed licensee and all persons named as taking on a prescribed role meet the eligibility criteria. Where appropriate, the licence applicant must nominate suitably competent and qualified individuals for each prescribed role (under Regulations 7 to 11).

Applications should be submitted well in advance of the planned date for when the activities will take place. The more complex the activity the more time that should be allowed for the application process. For reasonably standard activities, six months should be sufficient, for more complex activities at least 12 months should be allowed for the licence process. The completeness of information contained in the forms will also influence the length of the review period. Once an application is submitted to the CAA, the CAA will confirm receipt and begin to assess the licence application against a series of criteria. Section 8(3) of the SIA contains a new criterion that the licensee must be a 'fit and proper person', as follows:

(3) The regulator may not grant an application for a licence under this Act unless satisfied that—
(a) the applicant has the financial and technical resources to do the things authorised by the licence, and is otherwise a fit and proper person to do them;
(b) the persons who are expected to do, on the applicant's behalf, any of the things authorised by the licence are fit and proper persons to do them.

The CAA will consult with various government departments, agencies and statutory bodies in deciding what, if any, conditions to include in a licence.

Monitoring and enforcement

Licensees are expected to provide information to the CAA to enable the government to fulfil its international obligations, including the obligation to exercise 'authorization and continuing supervision' (an obligation on licensing states under Article VI of the Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer Space, including the Moon and Other Celestial Bodies 1967 (the Outer Space Treaty)) and to conduct monitoring of the licensed activities. This will include the provision of:

  1. annual satellite health check reports for orbital operation licensees;
  2. possible post-launch status reports for constellation orbital operation licensees; and
  3. evidence of the annual renewal of insurance covers, where appropriate.

Ongoing licence, authorisation and filing conditions must also be complied with, including annual reporting and monitoring requirements, the provision of information, access to premises (where relevant) and other conditions.

If licensees fail to comply with licence conditions and the violation poses a risk to those involved, to national security or to the UK's international obligations, the Secretary of State for Business, Energy and Industrial Strategy (BEIS) may grant an enforcement authorisation. Other consequences include a fine, up to two years' imprisonment or life imprisonment in certain circumstances.14

Spectrum filing requirements

The national administration representing the UK before the International Telecommunication Union (ITU) is the Office of Communications (Ofcom) by direction of the Secretary of State for Digital, Culture, Media and Sport under Section 22 of the Communications Act 2003. Ofcom carries out the assignment of orbital positions and frequencies through its filing obligations in accordance with the Procedures for the Management of Satellite Filings 2019.15

Applicants for a CAA licence are required to evidence that they have access to spectrum and that the requirements of the ITU are satisfied concerning orbital positions, as applicable, and frequency assignments. The CAA will check as to whether orbital positions and frequencies have been assigned to the applicant or are in the process of coordination.

Registration of space objects

On the launch of a space object, the CAA will provide the licensee with a registration questionnaire to complete, based on the requirements of Article IV of the Convention on Registration of Objects Launched into Outer Space 1975 (the Registration Convention). The CAA will then submit this information to the UN on receipt from the licensee.

The CAA maintains two registries:

  1. the registry of space objects where the UK is the 'launching State' under the Registration Convention and Article VII of the Outer Space Treaty;16 and
  2. the supplementary registry of space objects17 where:
    • licences have been issued but where the UK is not the launching state for that space object (e.g., following the transfer of a space object to a UK entity by a non-UK entity); or
    • it was jointly determined that another launching state should register the relevant space object (e.g., where the UK authorises the launch only and another state registers the satellite that is operated by a non-UK non-governmental entity).

The UK registries contain information as required under the Registration Convention, and additional information, such as the name of the owner or operator and the date of disposal or decay of the space object.

Indemnity, liability and insurance coverage requirements

Liability and indemnity under the OSA

Before the Deregulation Act 2015 came into force, Section 10 of the OSA required licensees to provide an unlimited indemnity to the government for damage or loss arising out of activities carried on by a space object under the licensee's control. The Deregulation Act 2015 placed a limit on the liability of licensees under Section 10(1A) of the OSA. After the implementation of the Deregulation Act 2015, a licensee must indemnify the government against any claims brought against it in respect of damage or loss caused by the licensed space activities up to the limit on its liability that is specified in their licence.

Liability and indemnity under the SIA

In relation to liability limits and indemnities under the SIA, Section 36 of the SIA removes the limit of liability provided in the Deregulation Act 2015. Section 36(1) of the SIA states that:18

(1) A person carrying out spaceflight activities must indemnify—
(a) Her Majesty's government in the United Kingdom, or
(b) a person or body listed in subsection (2),
against any claims brought against the government, or the person or body, in respect of damage or loss arising out of or in connection with those activities.

However, this is subject to:

  1. Section 12(2) of the SIA, pursuant to which an operator licence may specify a limit on the amount of a licensee's liability under Section 36 in respect of activities authorised by the licence; and
  2. Section 4(4) of the SIA, pursuant to which regulations may provide that Section 36 does not apply to a person to the extent that the person is carrying out activities exempted by or under the regulations, or where regulations may specify the maximum amount of a person's liability.
In-orbit liability and insurance under the SIA

In relation to the operation of satellites under orbital operator licences, the standard insurance requirement of the CAA is that licensees must take out third-party liability (TPL) insurance cover against liabilities arising from each licensed activity (i.e., the launch and in-orbit phases of a mission). It is a requirement that the government is named on the insurance policy as an additional insured. For standard missions, the TPL insurance requirement is €60 million.19

The UKSA introduced changes to the in-orbit TPL insurance requirement on 1 October 2018 so that, where an operator has more than one standard satellite mission, the UKSA may use its discretion to allow all the operator's standard-mission satellites to be covered under a single 'any one occurrence' TPL insurance policy. These changes are now implemented by the CAA. The CAA has further discretion to offer the operator the option to add an aggregate limit (at such level as the UKSA determines to be appropriate) to the operator's per-occurrence TPL policy after a certain number of satellites have been launched by the same operator. The operator's indemnity to the government will continue to apply in respect of each licence set at €60 million per licence (with each satellite licensed individually).20

The CAA also has the discretion to waive the TPL insurance requirement for low-risk small satellite missions launched to an operational altitude below that of the International Space Station, although the operator's indemnity limit will remain €60 million per licence (with each satellite licensed individually).

The CAA tends to define higher-risk missions as licensable missions that:

  1. are novel in nature or scale;
  2. use techniques, technologies or systems that are unproven;
  3. present a higher risk of high-value TPL claims; or
  4. present third-party risks that are not well characterised.

With regard to the above, the CAA may require a higher per-occurrence or a higher aggregate TPL limit, depending on the risks of each mission. These requirements will be considered on a case-by-case basis, and are set following an appropriate risk assessment.

The factors that will be considered by the UKSA during the risk assessment include the:

  1. heritage and reliability of the technology;
  2. orbital parameters;
  3. contingency plans and redundancy of the planned mission;
  4. manoeuvrability of the satellite and the capacity for it to be tracked;
  5. estimated value of satellites in nearby orbits;
  6. orbit-raising and de-orbiting plans, including the value of satellites that may be encountered during the procedures;
  7. operational practices followed by the operator; and
  8. performance of similar space systems on orbit.

At the date of finalising this chapter, the UKSA has published a 'Call for evidence to inform orbital liability and insurance policy'.21 While this does not set out specific proposals, it outlines a range of possible options identified in relation to:

  1. a potential alternative model to traditional TPL insurance;
  2. potentially lowering the limit of operator liability for orbital operations;
  3. views regarding a fixed or variable liability limit for orbital missions; and
  4. the use of alternatives to insurance as forms of security to meet an operator's liability obligations.

The closing date for responses is 3 December 2021. The responses will shape the future insurance and liability policy of the UKSA.

Launch liability and insurance under the SIA

In relation to launch operator licences, the government has applied the concept of a 'modelled insurance requirement' (MIR), which is similar to the US's maximum probable loss approach. The amount of TPL insurance for launch activities is determined by the MIR process conducted by the regulator. The MIR will be used to calculate the minimum amount of TPL that will be included as part of the relevant licence condition. The process takes into account the amount of insurance available in the market.

Mandatory space debris measures

The Guidance for orbital operator licence applicants and licensees (the Guidance) lists the standards that comprise the criteria by which licence applications are assessed. This includes various international space systems' standards defined by the International Organization for Standardization, international guidelines related to space debris mitigation defined by the Inter-Agency Space Debris Coordination Committee and safety standards defined at the European level by the European Cooperation for Space Standardization.

Despite the Guidance requiring applicants to describe any design feature of the spacecraft in terms of impact protection from debris or micrometeoroids, this is not to be interpreted as a licence condition for satellites to be designed with space debris shields or to have any other impact protection measures. This information is requested as part of the licensing process for information only, rather than to establish a specific requirement for operators, which would be beyond the international debris mitigation measures.

Safety and national security requirements

The CAA must be satisfied that the intended operations will not jeopardise public health, the safety of persons or property. It will assess this based on:

  1. system design, functionality and performance;
  2. system qualification, track records and reliability; and
  3. mission risk assessment, including safety plans and procedures, safety requirements and constraints.

The CAA will also assess whether the proposed activities will compromise national security or the UK's ability to carry out its obligations under international treaties and agreements.

Therefore, the CAA will only issue a licence on behalf of the Secretary of State for BEIS if public health and the safety of people and property are reasonably protected, the UK's international obligations under the international treaties are adequately protected and UK national security is not impaired.

ii Transfer of a licence

The government requires prior authorisation for both the transfer of ownership and the transfer of the operational control of a satellite. The transfer of a licence requires the CAA's consent on the fulfilment of certain conditions.22

The in-orbit transfer of a satellite from one licensed operator to another operator within the UK usually requires the receiving operator to apply for a licence.23

There have been several examples of space objects being transferred to commercial entities in the UK from entities or international organisations in other states and being added to the UK national space registry. There are also examples of the transfer of a space object from the UK, for example on the sale of a space object, to an entity in another state. In these cases, the transfer has been at an international level through the agreement of states, or the UK and an international intergovernmental institution.

iii Breach of a licence

Under Section 12(1) of the OSA and Section 54 of the SIA, fines may apply if a person, for example:

  1. launches or operates a satellite without a licence;
  2. knowingly or recklessly makes a statement that is false in a document for the purpose of obtaining a licence;
  3. fails to comply with the conditions of a licence; or
  4. fails to comply with any prescribed regulations.

The amount of a fine is not defined in the OSA or the SIA and is not limited on indictment, but certain limits are included in the OSA and the SIA.24

Distinctive characteristics of the national framework

The UK was one of the initial states to adopt national space legislation to regulate the space operational activities of private commercial entities.

The UKSA and the CAA are among the first regulators globally to establish licensing conditions for and grant licences to constellation operators and in-orbit service providers, and in relation to active debris removal missions and small satellite launches.

The CAA and the government more generally seek to remain thought leaders in space law and regulation with the implementation of the SIA and its secondary legislation, which offer many tools to achieve the desired outcomes.

The government takes an outcomes-based approach to regulation, rather than a prescriptive approach. It often encourages applicants to develop their own solutions to achieve the regulatory outcomes necessary.

Unlike many regulators, the current insurance requirements under the OSA and the SIA are policy-based rather than prescribed in regulation. This allows quicker adaptation to government requirements as necessary.

The government has adopted a similar approach to the US's maximum probable loss methodology in relation to assessing the limit on liability for launch-related activities, which is likely to incentivise the relevant licensees to minimise the risks associated with their launch-related activities and provide certainty and clarity, which will assist insurers, investors and management teams alike.

Current developments

i SIA

The SIA regulates space activities, suborbital activities and associated activities carried out in the UK25 through the following categories of licences:

  1. launch operator;
  2. return operator;
  3. orbital operator;
  4. spaceport; and
  5. range control.

Under the SIA, a single entity will be able to apply for more than one licence. For instance, a spaceport operator will be able to apply for both a spaceport licence and a range control licence.

Spaceflight operator licence

The SIA uses the term 'spaceflight operator licence' to refer to both a launch operator licence and a return operator licence.

A launch operator licence will be required to launch a launch vehicle or a carrier aircraft carrying a launch vehicle from the UK. A return operator licence will be applicable to a non-UK licensed launch operator seeking to re-enter a launch vehicle from orbit and land in the territory of the UK or have the launch vehicle recovered to the UK from UK territorial waters.

Orbital operator licence

An OSA licence will be needed by UK entities operating a satellite from overseas, whereas a SIA orbital operator licence will be required by UK or foreign entities operating a satellite from the UK.

Spaceport licence

A spaceport licence will be required for the operation of a spaceport, which is defined as 'a site from which spacecraft or carrier aircraft are launched or (as the case may be) are to be launched'26 or 'a site at which controlled and planned landings of spacecraft take place or (as the case may be) are to take place'.27 This includes both horizontal and vertical launches.

The scope of activities covered by a spaceport licence also includes ground operations, such as the provision of a safe ground environment for launch activities and keeping the public in the vicinity of the spaceport safe from risks associated with pre- and post-launch activities. These activities include storing, transporting or the loading and unloading of propellants and engine testing on-site.

Range control licence

A range control licence will be required to permit the provision of range control services for operations authorised under spaceflight operator licences from a designated site defined in the range control licence, such as tracking, surveillance and boundary control.28

Identifying and securing the 'range' and hazard areas are fundamental to the carrying out of spaceflight activities safely and securely. Spaceport operators and spaceflight operators will be required to work closely with the range control service provider to ensure that the operation of the spaceport and the provision of spaceflight services align with the range requirements prescribed in the SIA and the relevant regulations.

ii Brexit

The UK public voted to leave the European Union (EU) on 23 June 2016 and the UK withdrew from the EU at 23:00 GMT on 31 January 2020.

In terms of spectrum management, the UK is no longer subject to European Commission decisions and initiatives on the harmonisation of spectrum allocations and use across the EU. In addition, the UK is no longer included in the EU process for the planning of the ITU World Radio Conferences and instead now has a direct unfettered relationship with the ITU, with the UK being subject to the full Radio Regulations of the ITU.

The UK's membership of the European Defence Agency also ceased on Brexit unless the UK government negotiates an administrative arrangement that allows non-EU Member States approved by the European Council to participate in its projects and programmes. UK companies will also be excluded from EU space programmes, including Galileo and the European Geostationary Navigation Overlay Service, unless a bilateral agreement, similar to those in place with Switzerland and Norway, is reached. In this regard, the government published its intention not to use Galileo for UK defence or critical national infrastructure, and its plan to explore alternatives by investing £92 million in an 18-month programme to design a UK global navigation satellite system.29

The UK's membership of the European Conference of Postal and Telecommunications Administrations and the European Space Agency are not affected by Brexit as these organisations are independent of the European Union.

iii UK National Space Strategy

The UK government published the long-awaited National Space Strategy on 27 September 2021. The UK's vision described in the National Space Strategy is as follows:

We will build one of the most innovative and attractive space economies in the world, and the UK will grow as a space nation. We will protect and defend the UK's interests in space, shape the space environment and use space to help solve challenges at home and overseas. Through cutting edge research, we will inspire the next generation and sustain the UK's competitive edge in space science and technology.

The objectives of the UK government, both civil and military, are set out in the 10 Point Plan within the strategy as follows:

  1. capture the European market in commercial and small satellite launch;
  2. fight climate change with space technology;
  3. unleash innovation across the space sector;
  4. expand the UK's horizons with space science and exploration;
  5. develop the UK's world-class space clusters;
  6. lead the global effort to make space more sustainable;
  7. improve public services with space technology;
  8. deliver the UK Defence Space Portfolio;
  9. upskill and inspire the UK's future space workforce; and
  10. use space to modernise and transform the UK's transport system.

Work is now underway to implement the National Space Strategy.

iv Long-term sustainability of outer space

In June 2019, the UN Guidelines for the Long-term Sustainability of Outer Space Activities of the Committee on the Peaceful Uses of Outer Space (the LTS Guidelines) were adopted. In January 2021, the UK signed an agreement with the UN to support international efforts to promote space sustainability by identifying examples of the sustainable use of outer space through a series of events and outreach efforts.

In October 2021, the UK announced a further collaboration with the UN Office for Outer Space Affairs to support a collaborative effort to advance global awareness on space sustainability and how best to implement the LTS Guidelines.

v Australia Space Bridge Framework Agreement

The UK Department for International Trade and the UKSA, in partnership with the Australian Trade and Investment Commission and the Australian Space Agency, signed the UK–Australia Space Bridge Framework Arrangement on 23 February 2021. The Framework Agreement aims to enhance and improve government-to-government collaboration, and industry-to-industry collaboration, between the two countries on space programmes, technology, trade and investment (including commercial contracts), and research and education.

Outlook and conclusions

The outlook for the UK space industry is bright, and the UK industry (civil and military), academia and the government are collaborating to ensure that this is the case.

The UKSA is now looking to implement thought-leading policies covering close-proximity missions (including in-orbit servicing and active debris removal) and the distribution and export of Earth observation data. It will also continue to assess requirements for the regulation of large constellations, including streamlining of the licensing process in this regard.

The launch of small satellites from the UK in 2022, as anticipated, will be the catalyst for additional commercial vigour within the industry, offering the UK the long-awaited ability to have sovereign launch capability.

To ensure continued success, the UK has created a National Space Programme and established a National Space Council consisting of representatives at the highest levels of government. The UK also recently published the National Space Strategy,30 setting out its long-term plans to strengthen its status as a world-class space nation. It will shortly publish a Defence Space Strategy.31

We look forward to supporting the industry and government to achieve further success in the future.

Footnotes

1 Joanne Wheeler MBE is the managing partner at Alden Legal Limited. The author would like to thank Elise Feider at Alden Legal for her assistance with this chapter.

3 Convention for the establishment of a European Space Agency (CSE/CS(73)19, rev. 7).

4 These are the Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer Space, including the Moon and Other Celestial Bodies 1967; the Agreement on the Rescue of Astronauts, the Return of Astronauts and the Return of Objects Launched into Outer Space 1968; the Convention on International Liability for Damage Caused by Space Objects 1972; and the Convention on Registration of Objects Launched into Outer Space 1975.

5 Millard, D, 'An Overview of United Kingdom Space Activities 1957-1987', https://www.esa.int/esapub/hsr/HSR_36.pdf.

8 Section 2 of the OSA.

9 https://www.legislation.gov.uk/ukpga/2015/20/section/12/enacted, which required that a 'licence must specify the maximum amount of the licensee's liability to indemnify Her Majesty's government in the United Kingdom under section 10 in respect of activities authorised by the licence'.

14 Section 33 of the SIA.

18 With regard to the person or body listed in subsection (2), this includes the Health and Safety Executive, the Office for Nuclear Regulation and the Civil Aviation Authority.

20 ibid.

22 Section 15 of the SIA.

23 It may be possible to novate a licence under certain circumstances.

24 Section 12(2) of the OSA and Section 54 of the SIA.

25 Section 1(1) of the SIA. See Section 1(4) of the SIA for the definitions of a 'space activity' and a 'suborbital activity', which together are referred to in the SIA as 'spaceflight activities' as per Section 1(6) of the SIA.

26 Section 3(2)(a) of the SIA.

27 Section 3(2)(b) of the SIA.

28 The terms 'range' and 'range control services' are defined in Sections 5 and 6(1) of the SIA respectively.

31 The vision for which is 'To secure freedom of action in space, fully exploiting its military and civil potential'.

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