Review of Insurance Requirements for Orbital Re-entry

UKLSL, supported by Deimos Space UK and Alden reviewed approaches to setting insurance requirements for re-entering space objects for the UKSA Space Engineer’s office.

UK Launch Services Ltd (UKLSL), in collaboration with Deimos Space UK and Alden, conducted a comprehensive review of approaches to setting insurance requirements for re-entering space objects on behalf of the UK Space Agency's Space Engineer's office.

The objective of the study was to compare international approaches to the Modelled Insurance Requirement (MIR) specified in the Space Industry Regulations, which currently focuses primarily on launch to orbit. The aim was to determine if the MIR could be applied to re-entering space objects or if an alternative method would be more suitable.

The study employed a methodology that began with extensive desk-based research, encompassing standards, policies, guidelines, regulations, and the implications of international treaties. Specifically, ISO 27875 and 24113 standards for "Space debris mitigation requirements" and "Re-Entry risk management" were reviewed in detail, forming a baseline for comparison with other approaches. Guidelines from NASA, ESA , and the UN Office for Outer Space Affairs (UN OOSA) related to controlled removal and long-term presence of space objects in Low Earth Orbit (LEO) were also evaluated, along with regulations from the US Federal Aviation Administration (US FAA), Australia, France, and New Zealand. Furthermore, third-party liability requirements for launch and space operations were compared, while considering relevant UK laws within the broader context of commercial spaceflight for re-entry.

Based on the findings, the study puts forth recommendations that aim to strike a balance between UK liability and the imposition of requirements on launch or satellite operators. It takes into account the competitive nature of the commercial launch industry and UK regulations. The study recognises the potential for natural re-entry if the expected casualty (Ec) is justified to be low enough, which would not impose unnecessary requirements on the operator. However, if the expected casualty is calculated to be too high, the study suggests that operators should be required to implement mitigations. These mitigations would be proportional to the level of expected casualty for the mission while minimising their impact on the operator's business case. This approach aligns with other regulatory regimes and ensures a comprehensive yet practical framework for insurance requirements.

Overall, the study conducted by UKLSL, with the support of Deimos Space UK and Alden, provides valuable insights into setting insurance requirements for re-entering space objects. The recommendations put forth aim to promote responsible practices in the industry while considering the specific needs of launch and satellite operators operating in the UK.