Select Committee on Science and Technology Written Evidence

Memorandum 90

Submission from the Aviation Environment Federation

  The Aviation Environment Federation is a UK-based NGO working to control and reduce the negative environmental impacts of all forms of aviation. We work with citizen groups and a wide range of other NGO's assisting with campaigns, policy development, communication activity and Government and institutional-facing advocacy on a worldwide basis. The AEF administers and provides observer status representation at three key bodies: The UN International Civil Aviation Organisation, the European Civil Aviation Conference both concerning the environmental performance standards of commercial and general aviation; and the UN World Health Organisation on transport, environment and health issues.

  Space policy is an area that we have not previously entered into but are grateful for the opportunity to comment. Our main concerns are the environmental impact of activities in space; the opportunities for technology transfer from space R&D and operations back into commercial civil aviation design, manufacture and operations; and the pointless efforts being put into space tourism.

  We would like to comment on environmental impacts and space tourism for this inquiry. Firstly a few general comments regarding space exploration, manned or otherwise, and the perceived lack of environmental performance standards and oversight both during launch/recovery, flight and inter-planetary transit/activity, including manned and remote landings:

    —  Environmental impact assessment in respect of launch site development and construction should be mandatory and studies published.

    —  The environmental impact of space launch and craft emissions in flight should be studied; as should the impact of space debris and all "leave behind" surface debris, intended or otherwise, on other planetary bodies.

    —  We are concerned about the application of nuclear power for space exploration and its safe use—again risk assessments should be publicly available.

    —  We understand that substantial risk assessment programmes are undertaken for both government and commercial space launches of all types—these should be published to ensure the sector's compliance with the concept of ALARP at least and should include third party and societal risk as well.

    —  All launches for all space activity should be insured—we understand cover through specialist insurers is available for around 25% of the total cost of a launcher, satellite payload and launch costs, with Government cover as a last resort.

    —  We believe current planning, health and safety and general environmental protection policies are applied satisfactorily to the manufacture of most launchers and satellite programmes but have some concerns about fuel production, transport and storage; we also have concerns regarding the safe disposal/recycling of old rockets, fuel tanks, launch towers, pads and sites in general.

  We are happy to acknowledge the significant contribution that wholly peaceful, scientific space exploration and research has made to mankind's knowledge, particularly in the field of climate change impacts. More effort needs to be made to ensure these continuing activities are as environmentally benign as possible.

  We would encourage the UK Government to conduct a desk research review of the points we raise above and instigate a discussion with a view to develop, as a minimum, a voluntary environmental charter for space exploration and tourism and further a realistic, unambiguous set of internationally agreed environmental performance rules and regulations as a best case outcome for all future space programmes.

  The second area we wish to comment upon is Space Tourism. We view this as an utterly frivolous and unnecessary enterprise. This is a Virgin Galactic statement regarding its environmental impact:

    "What effect will Virgin Galactic have on the environment?

    Space access and exploration is and will continue to be a key component in our ability to understand, measure and better manage the effects of climate change on earth. Already, much of the early evidence of the causes and effects of a warming planet has been derived from satellite technology not to mention its fundamental impact on meeting the basic requirements of a burgeoning global population. However, the technology that still delivers payloads and people to space has a high negative environmental impact and has remained essentially unchanged for half a century. Virgin Galactic is investing in a space access system that is radically different from what's gone before and many times more environmentally friendly. This, and the future technology that it inspires, will allow man to continue to reap space related environmental benefits without making an unacceptable contribution to the environmental problem."

  This statement is just public relations guff—no facts, no figures, no assessment, simply a vacuous paragraph. Taking payloads of the very rich for what is tantamount to a joy ride in the atmosphere and attempting to link this to real scientific endeavour is risible nonsense.

  At the moment, space tourism is limited to one company, Virgin Galactic, and its plans for limited joy rides into the earth's atmosphere from launch sites in California and in New Mexico, USA. The US Government and the Federal Aviation Authority have recently issued a set of rules governing such activity, "Human Space Flight Requirements for Crew and Space Flight Participants; Final Rule". We attach a pdf copy of this document for the Committee's information.

  This contains a set of rules the key ones of which are:

    —  All crew and passengers will have to sign a waiver exempting the US Government from any claims.

    —  All passengers will have to undergo medical checks and some pre-flight training.

    —  Safety records have to be maintained.

    —  On-board safety systems are documented.

  We would describe this document as "light touch" regulation designed to help a fledgling industry establish itself—this has been the lobbying strategy adopted by the proponents and supporters of leisure space flight activity.

  Whilst the noise, air quality and climate change impacts of launches from Mojave in southern California or the "spaceport" in New Mexico may well be very low, for the first few launches and passenger numbers, we would suggest that beyond the first few flights and in particular if and when ticket prices fall to levels significantly below the current $200,000 forecast and/or the first 1,000 passengers have been carried annually by Virgin Galactica, then normal commercial air transport standards of design, safety and environmental performance certification should apply although they may need to be adapted appropriately.

  We list below at Annex 1 a selection of media reports which give a flavour of the regulatory debate and the size of the market for space joy rides for Member's information.

  In conclusion with regard to so-called space tourism we feel that:

    —  Space tourism is the play thing of millionaires and is totally unrelated to any recognisable scientific endeavour or discipline whatsoever.

    —  Light touch regulation is acceptable only when numbers of flights and passengers are very small in number.

    —  Normal commercial air transport standards of design, safety and environmental performance certification should apply once 1,000 passengers a year are carried although they may need to be adapted appropriately.

    —  We view this as a rather pointless activity for thrill-seekers with more money than sense with little value for society at large. In fact, the only value we can see is that of the associated publicity for those brands involved.

February 2007

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2007
Prepared 17 July 2007