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
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