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.

This aimed to compare international approaches to the Space Industry Regulations’ Modelled Insurance Requirement or MIR, which to date focuses on launch to orbit, and to explore if it is suitable to use a similar method or what alternative would be more appropriate.

The methodology applied was, first to conduct wide-ranging desk-based research into standards, policies, guidelines, regulations and the implications of international treaties. ISO 27875 and 24113 (both 2019) standards for “Space debris mitigation requirements” and “Re-Entry risk management” respectively, at the direct request of UKSA, were given a detailed review and formed a baseline for comparison against other approaches. Guidelines from NASA, ESA and the UN OOSA policy aimed at limiting the long-term presence of space objects in LEO after the end of their mission through controlled removal were reviewed and compared with US FAA regulations for commercial re-entry, plus those found in Australia, France and New Zealand. Third-party liability requirements for launch and space operations were also compared. Other applicable UK laws needing consideration in the wider context of commercial spaceflight for re-entry were identified.

The recommendations aim to achieve a balance between UK liability and placing requirements on a launch or satellite operator, bearing in mind the competitive commercial launch industry and regulations in the UK. The process of allowing a natural re-entry, should the Ec be justified low enough, does not place unnecessary requirements on the operator. It is understood however that requiring an operator to perform mitigations should the expected casualty be calculated as too high, will place design and/or operational requirements on the operator. These mitigations will be dependent and consistent with the level of expected casualty calculated for the mission but expected to keep the impact on the business case of the operator to a minimum. This approach taken is consistent with other regulatory regimes.