 According to the United Nations Office of Outer Space Affairs, over 11,000 space objects have been launched and recorded in their online index. But this number is set to increase significantly as private companies and governments intend to launch tens of thousands of satellites into low Earth orbit known as mega constellations. This trend is driven by the reduced cost of hardware and launch and the increased demand for low latency, high broadband internet to underserved locations. While US companies like Amazon, Canada's Telesat, and UK's OneWeb propose mega constellation satellites in the order of the low thousands, US-based SpaceX alone has announced plans to launch 42,000 satellites as part of its Starlink project. If this happens, SpaceX will be responsible for a five-old increase in the number of satellites launched by all of humanity. Of those 42,000, they plan to have 11,926 launched in orbit by 2027. Also, importantly, as the European Commission is currently studying the feasibility of a European-owned space-based communication system and the Chinese government has created a company dedicated to creating and operating a 13,000 satellite broadband constellation, the soft power political and security element is also present, much as we see with global navigation. This means that some actors may enter this vertical, even if the business case is not evident. One of the big questions is, does servicing this increased demand warrant all the increased risks to in low-earth orbit, the atmosphere, and on Earth? COVID-19 showed us the extent of the digital divide problem. Those connected were able to maintain business or find new opportunities and continue their education. Those who were not, whether in rural areas, indigenous communities or in developing countries, found themselves further marginalized. This leads some to question whether there is a right to be connected. While low-earth orbit is not the only way to be connected, proponents argue that it is cheaper and faster and this serves to bring many of the world's population into the 21st century. But should this goal be met at all costs? The astronomy community were one of the first communities to raise the alarm in a significant way about the risk posed to their activities by the brightness of satellite constellations, namely that the constellations cause streaks, diffuse background light, and cause radio noise that may prevent access to the sky. Essentially, two proposed rights are pushing against each other, the right to be connected versus the right to a dark and quiet sky. The space industry argues that there is no hierarchy to space activities and everyone is free to explore space subject only to the Outer Space Treaty. But as article one of the Outer Space Treaty highlights, the freedom of outer space is subject to the condition that space be explored and used for the benefit and in the interests of all countries. In this case, what is benefit and who gets to decide? We must promote dialogue to ensure that space activities are and continue to be beneficial for all of humanity. Untracked debris is also a big risk as this could lead to potentially dangerous in orbit collisions on a regular basis. Other less known risks include that satellite re-entries could deposit more aluminium into Earth's atmosphere and the cumulative impact of thousands of rocket stages on the oceans environment could be significant should these stages contain hazardous materials. But should we still be concerned as some operators seem to be listening? According to Telesat CEO, operators are following best practices regarding how to deal with debris and are designing satellites to minimise debris, protect the space environment and are launching into the lowest orbit so that trouble satellites can decay quickly. And in response to astronomy concerns, SpaceX has been meeting with the astronomy community regularly and are innovating around a coating called darksat and a sunshade to address the brightness of satellites. The issue is can we rely on the good faith of these actors? And some argue that what they're doing does not go far enough. For instance, in recent times, the news has reported controversy involving close approaches between a Starlink satellite and OneWeb satellites and the European Space Agency where coordination did not work well. With no space traffic management system or global space situation and awareness capability, we may hear more of these issues. So what do we do next? The International Astronomical Union has now decided to take the issue of light pollution to the United Nations Committee on the Peaceful Uses of Outer Space, requesting that they protect the night's darkness for the sake of advancements in astronomy. But astronomers are just one stakeholder. Mechanisms will be needed to balance interests and encourage coordination. Folian buyers argue in the recent edition of Nature Journal that to address the myriad of concerns that will affect all communities, international cooperation is urgently needed along with a regulatory system that takes into account the effects of thousands of satellites, including action for improved space situation and awareness, improved communication between operators and internationally adopted right-of-way rules. All right, excellent. Good morning, everyone. Good afternoon or a time-appropriate greeting for where you're at. My name is Chris Johnson. I'm the Space Law Advisor at the Secure World Foundation. This panel now deals with mega-consolations. After this, the first panel was very focused on terrestrial matters. We're now leaving the terrestrial domain and we're looking at the space domain. I really think that Timmy's introduction and her framing video puts out a lot of these issues that are at play. The fact that we have these competing legitimate uses. We have the use of the space domain for mega-consolations and all the benefits that they offer. But we have these other legitimate uses of the space domain like optical astronomy and the fact that there's these real challenges for space traffic management and space situational awareness. Luckily, we do have a panel with us who can really get into some of these issues. I don't think we're gonna find any perfect solutions but at least we're gonna be able to highlight and elucidate some of these issues. Joining me on my panel first is Tim Ferrara. Tim is the president of Telecom Media and Finance Associates, his own consulting firm based in Menlo Park, California which specializes in the technical and financial analysis of wireless and satellite ventures. Tim has over 25 years of a consulting experience across the telecom and satellite industries having worked for leading technical and strategy consultants in both the US and the UK. Mr. Ferrara, thank you for joining us this morning. Next we have Professor Hugh Lewis. Hugh is the head of Astronautics Research Group at the University of Southampton in the UK and has been working in the fields of space debris and space sustainability for over 20 years. He is a member of the UK Space Agency Delegation to the Interagency Space Debris Coordination Committee, the IADC, and is the chair of their working group too on modeling. He's also currently a member of the Royal Astronomical Society subgroup assessing the impacts of satellite mega constellations on optical astronomy. Professor Lewis, thank you for joining us as well. Next we have Randy Siegel. Randy's a partner at the law firm Hogan Lovells and has over 18 years of in-house general counsel experience. Her work focuses on satellite, wireless, drone and technology transactions. Randy's transactional and advisory experience has brought her throughout North and South America, Europe, Asia and the Middle East and on the most complex of international programs and legal issues. Randy, thank you so much for joining us. And last but not least is Andy Williams. Mr. Williams is the external relations officer at the European Southern Observatory where he supports strategic relations with current and future member states, the European Union and international organizations such as the UN. Prior to joining the European Southern Observatory, he worked as a senior policy advisor for NATO and as a physicist for the UK government. So first I'd like to speak with Mr. Farar. Tim, in that spotlight talk that we all just heard, Tim introduced this idea that there are tens of thousands of satellites that are predicted that are likely to be launched and enter into operation in the space domain. Largely from the US, Canada, Europe and likely as well China. Do these predictions seem to make sense to you from an economics and business standpoint? Maybe if you have some perspectives on that and is there really a market to support some of these plans? So, Tim, over to you. Thanks, Chris. Yeah, I mean, just in terms of a bit of personal history, I, you know, 25 years ago, I worked on a lot of the big Leo projects back then, ICO, Global Star, Iridium, Tel-Adesic for many years and then saw the aftermath of that with the many, many years of bankruptcy and litigation over the collapse of a lot of those projects. So, you know, that sort of colors my perspective, that, you know, while it's very true to say there could be tens of thousands of satellites launched, you know, if you go back 25 years, the predictions that people were making back then was that everyone's phone would have a satellite capability in it. There would be tens or even hundreds of billions of dollars spent on satellite broadband within a decade. And, you know, it just didn't happen because the economics didn't work out. And now, you know, here we are 20 years later and sadly, I'd say a lot of people have forgotten the lessons of the 1990s. You know, these things come around 10 years later or 20 years later when everyone's retired and forgotten about it. But, you know, we still face a lot of the same challenges. Yes, the technology has advanced, but the technology has advanced in terrestrial even faster than it has in satellite over the last two decades. And, you know, it's still really unclear. So, I think what I'm concerned about is that we see lots of statements about how awful everything will be with 40,000 satellites on SpaceX or 100,000 satellites on all the different companies combined because people look at what is filed with the ITU or what is filed with the FCC. And, you know, people make filings to stake out a position because they can only sort of step back from it later. They can't move forward and add even more satellites at a later date and keep the same priorities that they had. So, I mean, I guess my question for people like Hugh will be, you know, okay, great. You know, it may be terrible with 40,000 satellites, but what's the real, you know, if we take some sort of real rational point of view that maybe there's only four or 5,000 satellites that get launched, you know, and even that requires a lot of money to be invested over the next five to 10 years, which may or may not be available. Who knows what's gonna happen to the financial markets but is the situation a complete crisis and disaster with, let's say, four or 5,000 satellites? Or do we, you know, is it really only with 40 or 50,000 satellites that that becomes a problem? So, that's what I'd like to hear from some of the other panelists is, let's take some sort of, you know, what we view as rational, let's say, you know, SpaceX is saying already, you know, we can't launch a V-band satellite because there aren't any terminals and, you know, propagation is terrible and everything else. So, let's focus on what people's concrete near-term plans are. And if that's a terrible situation, then please, please tell us because that's gonna need a lot more urgent action than worrying about something that probably will never happen to the tune of 40 or 50,000 satellites. Yeah, I like that, thank you. That, I mean, those are good questions for Hugh. Yeah, I mean, the predictions right now, like he said, people are really worried about 40,000, 50,000 satellites, but what if it's only a fifth of that? Before you answer that though, I really wanna know, I mean, the challenges for mega-consolations that they pose to SSA and space traffic management and the debris issue, whether it's at the, this higher number that is possible or possibly a lower level, what does a, what do mega-consolations mean for space traffic management and, you know, our awareness of the domain? Thanks very much, Chris. That's a really good question. And I'm gonna thank Tim later for setting me up with a, actually quite a tricky question to answer as well. So a lot really depends on the attitude that these operators are gonna take into the space environment. You know, we've run computer simulations, which can show a really big impact on the space environment if the operator is perhaps not as advanced in their stewardship of the environment. Or we can see, you know, for the same number of satellites for a very similar type of setup, actually a rather benign situation. So we're kind of beholden really to the attitudes and the approaches that these operators take, both in terms of the impact on the orbital debris environment, but also in terms of space traffic management. You know, it's not necessarily been a great start. If we look at the particular encounters that SpaceX, for example, have had with Starlink constellation, you know, quite public events that have enabled us to really get some insight into the challenges. And it hasn't been great to be perfectly honest. And a lot needs to change going into the future to ensure that we don't run into even worse problems with respect to the space traffic management concerns and the orbital debris concerns as well. But I think, you know, there are some very good and very positive signs coming from the operators in terms of how they intend to operate. I think it's really just a matter of making sure that they actually stick to those kind of things. Well, I mean, I'll ask a more pointed question. If, you know, if we're, how worried are you on some of these issues now? How worried would you be if they, you know, only deploy and put into operation a fifth or, you know, a third of what they predict and what they aspire to? And how worried would you be if they really roll out everything and really get everything working on orbit of true global constellation, a mega constellation? What does that really look like? So to be honest, I'm really worried, really no matter the number of satellites that we're talking about because we're really into unprecedented territory. And it's being driven not by governments that tend to move in very slow fashion. It's being driven by companies and companies that aim to disrupt the market. And they're doing the same thing in their space environment. So if you take, for example, this fail fast fail often kind of mantra that is often associated with companies like SpaceX, potentially others as well. It's really about short-termism. It's not necessarily focused on the long-term issues. It's a philosophy that sets up the idea that there's no problem that you can't overcome. And you just iterate through those problems. So it works fantastically well for things like, you know, failures of components on rockets or on spacecraft. But when you're hit with societal issues and challenges, it really doesn't work well at all. And Orbital debris is one of those issues. Same thing with the astronomy issues as well. And really those companies aren't set up. They're a little bit naive in that sense. They don't necessarily have the foresight to be able to solve those problems in advance. They actually deliver almost test satellites onto orbit and then wait for problems to occur and then fix them quickly and fly a new satellite. And that doesn't work. And that really leads me to worry quite a lot about the impact that these constellations can have in the environment. Yeah, I mean, we run into that quite often where new users of the space domain think that they're the only or the first users of the space domain. And it just is not necessarily so. Thank you for that. We might have to come back to you. I wanna now go to Randy and talk about a little bit about the regulatory environment, the approval environment. Randy, what does it look like? What does the regulatory environment look like for mega constellations? Or you can use whatever term you want if you want to call it global systems or global constellations. What does that type of approval process look like? And where are we at on the regulatory front? Unless she can't hear us. In which case, we'll have to come back. Oh, go ahead, go ahead. I'm so glad that's him. Yeah, we hear you, go ahead. I just wanted to start off by saying, Tim, thank you for having the memory that I do going back to the 90s and Teladijic and all the mega constellations then. But I will tell you that this is different. Back in the 90s, when this happened, we always thought that they must know what they're doing. Right? These smart companies must know what they're doing led by smart money. And there has to be something there. It was too early for its times. I will tell you a lot of things that are happening now are very different, different in feeling than they were in the 90s. I genuinely believe that this is real. It doesn't matter to me whether it's 40,000 or whether it's 30,000 or 20,000. I think that Space Link and Kuiper are real. I think the Chinese will be going up with their mega constellations. We have so many other 100 to 1,000 constellations that are in existence as well. And the issues on light pollution, the issues on the environmental issues with aluminum particles from small stat launches and the issues of orbital debris are real. Regardless, with launching every three. Seems like she might get cut up a little bit. Rainey, we'll come back to you. I want to quickly go to Andy at ESO to really talk about the challenges for ground-based astronomy, optical astronomy. What does it look like now? And what are your predictions for the near term? And honestly, this issue really developed rapidly over the last couple of years. It really, it's not like it took us by surprise, but it really came up on us fast. So if you could tell us a little bit about that, educate us on the effects on your profession. Sure, so I just want to start up by saying, thanks for the invite and for considering astronomy as one of the stakeholders now in this issue of mega constellations. So I just want to reflect on Tim's question, which he put to us and just note that astronomy observatories have lifetimes of 30 or more years. So we have to plan long-term and we can only act on the basis of formal government plans, such as the ITU filings. So even though it might be the case that not all the filings are realistic, I mean, these are the things that we have to base our assumptions on for planning for the long-term. So if we consider the main projects in development, we can expect several thousand satellites overhead at any one time. And particularly just before sunrise and just after sunset, most of them will be illuminated by the sun and potentially detectable by a telescope. So if you live in a city, you might not notice anything unless you know exactly where to look. But if you go to a dark sky area, you will see tens or even hundreds of moving objects in the sky. And this is a change to this beautiful landscape, which is one of the few natural wonders that is accessible to every single person on the planet. And I really believe that the international community has to consider this. So from the perspective of astronomical science, well, the impact is really depending on the interaction between the telescope and the constellation system. So the basic impacts depend on the number of satellites, the size of the telescope, and the orbital altitude of the satellites, which is a very important factor. And overall, the impacts range from quite minor to some of the large narrow field telescopes that are looking at a very small patch of the sky to very severe for those facilities that need to do their science at twilight when there's more visible satellites. And the wide field telescopes that are looking at a large portion of the sky. So the largest of these at the moment is the Vera Rubin Observatory. And they're facing many percentage of images ruined and almost every single image having a satellite trail in the early hours of the night. So they're facing substantial extra cost to achieve their defined science goals. And you're right that this issue kind of really took us by surprise and our satellites have always been a problem. But I think the root of the issue here is that none of our environmental laws directly address the visual appearance or even the general sustainability of the space environment. And the optical spectrum is not managed in any way. So there's no regulation to compel space actors to take action or for governments to set a level playing field of rules. If we consider the radio sides, there are thousands of objects that are now transmitting and radio observatories were able to observe outside the slim portion of the spectrum that's protected by finding a local radio quiet zone which offers greater protection. But the issue is that these radio quiet zones can't offer any protection from space-based transmissions. So we're gonna have this problem of just much more background noise from these thousands of new antennas in the sky and the electronic noise that's coming from the satellites. So we've been working with the community. We've been working with the industry and I can go into some of more of those aspects later if you like. Yeah, certainly. I mean, listen, we have a lot of students that are also attending. If you can recommend any kind of background or document or something that summarizes many of these issues, please feel free to share it. But my question also is, well, actually hold on, you said satellites are always a problem. Satellites have always been a problem. Is that always, is that true that even if it was just a few satellites, that even that caused problems for astronomy? Yeah, so for radio astronomers, I mean, they know now that there's this big arc across the sky, which is the geostationary belt where there are satellites in there and essentially in certain frequencies, they just have to avoid this area. Satellites have been a problem from the optical side. I mean, already the Hubble Space Telescope is getting some percentage of its frames affected by streaks. But in general, the impact scales with the number of satellites. So just in the past two years, we've seen a, what is it, 2,000 new additional objects added. So the problem is increasing rapidly. And if you look at the projections, I mean, we could see 100,000 new objects looking at the ITU filings. And then this is getting into some serious impacts. All right, and I mean, are you coordinating with the folks like the space situational awareness folks and the space debris folks? Because you both have, I don't want to say grievances, but you both have issues that are talking about the same actors, the same users. You both have problems with the mega constellation operators. So is there some type of coordination already happening? Yeah, so the astronomy community has formed several national working groups and also we have a group that's under the auspices of the International Astronomical Union. And as part of these groups, we've invited experts in space situational awareness. So Hugh is a member of the UK Royal Astronomical Society group that's looking at this. And of course, this is important because part of the solution to the issue for astronomy, part of the solution is about finding ways to compel industry to share data on the trajectories of the satellites, predictions for the future. And of course, this is something that will also help the space situational awareness question. So I'd say this collaboration is just starting to emerge, but I think that a direction where we need to go in the future is to really work more closely together between these two communities. Okay, at the top of our panel, we had a poll for folks to weigh in on some of the topics if we can bring up the results of that poll. And we might have to revisit the poll near the end of the panel. So let's see, we asked the attendees, are the predictions about mega constellations numbering the tens of thousands of operational satellites in the next decade, overestimating, about right or underestimating? So it seems that they might be agreeing with Tim that almost half say that they're overestimating. So all right, it makes sense that if you say you're gonna launch or you aspire to launch tens of thousands and 40, 50,000 satellites, you might be overestimating it, you know, but, you know, let's say 34% says they're about right. I think that I wanted to highlight that, but even if it's not exactly what we're gonna meet, it seems like we're still gonna have some of these issues, a lot of these issues. I think it's important to not frame it as one side versus the other or binary operators versus, you know, optical astronomers or operators versus those who are worried about space debris and SSA. Does that make sense? Is there a way to not have this be totally a clash of legitimate uses? Anyone that wants to weigh in on that, you know? How do we not make it a clash? Oh, and I see Randy has joined us back again. Good. Randy, we've found a problem. How do we not make it a clash? Okay, well, my internet is working. This is why we need the mega constellation so there's better internet as well. I think that as, you know, it's not just commercial versus other, the astronomers and the orbital debris. I think we have to work on this together. We have to work because the internet, you know, you see what happened in countries and with people who didn't have internet during the COVID crisis and everything else. This is something that really the world does need in terms of having the satellite connectivity. The challenge is how to do it at the same time that the orbital debris in particular doesn't cause issues for destroying, like the plastic in the oceans and everything else. This is a global issue. And how do we have coordination with mega constellations being launched by folks like China if we're not communicating with them? These are global issues, although the US is ahead of all the other countries in terms of launches that it's flagging. This is the global problem that we have. And while a treaty United Nations type of process is not going to keep up with as we've learned over the years, is not gonna keep up with the rapidity of that's going on with advances. There's got to be some kind of a forum compromise that allows for remedies and doing the best thing as a global citizen because space is for everybody. And if we do it wrong, we're gonna create a problem that's gonna be the gift that gives for eternity. Responses, go ahead, you. Yeah, thanks, Randy's absolutely right. So thanks very much, Randy. I'm glad to have you back. One of the biggest issues that we have is that these mega constellations are regulated at a national level. And there is very little coordination that takes place between the regulators. So we can have a decision that's taken place in the US about a mega constellation there. And we can have a decision that's made in the UK or elsewhere in the world. And there's no sense that the combined effect of those two constellations going into orbit is being considered by either of those regulators. So we have that knowledge, we have the capability to make those kind of assessments, but there isn't any forum where that can be addressed and where the regulatory aspects can actually be sorted out. Andy, can you, you know, European Southern Observatories observer at Copolis and they just wrapped up, well actually it was a while ago they did the scientific and technical subcommittee. Can you give us, you know, were these discussions held at the international level at Copolis and any results or what's gonna happen next? Yeah, so I think the sort of issue here that has been touched on, I mean, the astronomy community is engaging with the industry and the industry are engaging with us and this is much appreciated. And you know, some companies have made substantial changes to the designs of their satellites like SpaceX. And, you know, we're having the situation of bilateral agreements, nondisclosure agreements between single observatories and companies. And okay, we can do this with five, but can we do it with 10? You know, what are the other countries going to do? So it, you know, it's just something that becomes unsustainable. And I think what we need is a global approach to this. So that's why the IOU works on this and, you know, made the first approach to UN Copius, as you said, at the Science and Technical Subcommittee. And we made a set of recommendations that amongst other things, you know, sets in basic requirements to mitigate damage to astronomy, to protect the night sky, to encourage governments to regulate on the matter and to create a norm of cooperation and consultation with the astronomy community over space activities. So, you know, in the discussion that happened with Copius, I was really pleased to see that many countries recognize the value of astronomy and the concerns that we have. But, you know, the problem in this system, it's so complex, it's linked to many other very, very difficult issues, such as, you know, the allocation of slots for low earth orbit or, you know, the ideas such as a carrying capacity for low earth orbit and, you know, all the problems with space sustainability in general, that's sort of, you know, there was a sense that no country could really kind of take a firm stake and say, right, you know, we're going to adopt these recommendations. So, you know, we got the, I think it was what we were expecting, which was basically carry on working, carry on studying the issue and report back next year. So, okay, I mean, that's a first step. But, you know, in this year, another 1,000 or 2,000 satellites are going to be launched. Can I just jump in here to something what Andy said? So, one of the regulatory requirements, not for the geospatial satellites, remote sensing, but for the connected broadband satellites is you have to get landing rights in countries. So, even though, for example, the United States is the one that flags the constellations from the US or the UK for one web, et cetera, you still need landing rights to go into countries. I think that that is a potential strategic negotiating leverage point other than just being good corporate citizens with the constellations to try to achieve all the goals that we have. Let's put China aside, because that's its own creature vis-a-vis the United States. But as to everything else and everyone else getting landing rights is critical to a lot of the businesses and could be a basis to begin a dialogue with the countries. But, I mean, let's be blunt here. A lot of this business is gonna be based on defense applications. Iridium got rescued from bankruptcy by the DoD because it felt it was a system that was gonna be critical to the US to preserve. And it would not be in the least surprising if a very large proportion of the revenue from some of these companies came from defense applications. And in that sense, how do you really as a national country that's concerned about its own technological advantage in space, how do you really concede to something like a UN body that they should control your strategic priorities? But Tim, even if the United, let's just go with your hypothesis that the DoD defense communities in the US is driving some significant portion of revenue for the constellations, not just Iridium as it had done, but some of the others. They need the deployment in other countries as well for their missions. And they do not control the deployment in those other countries. So, each of the other countries still has their own respective potential, I'm saying potential, gatekeepers to accomplish environmental or other orbital debris goals if theirs differs from that of the United States. Well, true, but of course the regulations applied to a post-forces agreement are not necessarily the same as the regulations applied for selling terminals to consumers in the country. So, completely agree that there will be limitations if for the commercial part of the business, if you can't get access to a wide variety of countries, you're going to have a big problem generating your business plan. But that may mean that some of these operators fall back even further and harder on defense applications where the leverage points are very different for getting access into a particular country if there's a war or a disaster or some other crisis that requires access. But I think, Tim, I mean, the, we can't forget the operators themselves. And certainly from an orbital debris point of view, they're probably best place to police themselves because if they cause debris issues in the orbits that they're in, then of course that's going to harm their own business. So in many senses, the orbital debris issue is also perhaps more easily managed thanks to the need to operate in a clean way. I think that the astronomy issue is outside of that because there is no incentive there for the operators other than the concerns being raised by the astronomy community to actually to behave in a different way. And the orbital debris is different. Absolutely, I mean, Iridium didn't, got most of what it wanted against Radio Astronomy back 20 years ago. And really, they had made some compromises. They've made some improvements in subsequent designs. But in the end, the objectives of the Radio Astronomers to keep them out of the band that was very close to a key observing band didn't really happen in the way that people wanted it to happen. So, yeah, it's a huge problem. And as I say, I mean, I would just take issue with Randy's statement that, you know, she said, you know, 20 years ago, we thought people knew what they were doing and it proved that they didn't and now it's different. And my view is it's not different. No one knows what they're doing. No one knows what the market is. You could go, you know, you look at what, you know, SpaceX was saying five years ago that they'd have $30 billion of annual revenue from this by 2025. No, sorry, it's not happening. I mean, it's just not. And no one actually knows what the market is. No one knows what the economics are. We're in an environment where endless money is being thrown at space. It's a huge investment theme. People are filled. People see these billionaires who they think must know what they're doing. And, you know, we're seeing all these SPAC companies which range from, you know, very ambitious to probably not going to work and take your pick. So, but people are still prepared to fund them. So it's a very difficult situation. How long the money lasts? How long people prepared to go on with that when they see the real results? I mean, you know, Iridium, everyone was going, how about this in 1998? Nine months later, it's in bankruptcy because, you know, there weren't any customers. And, you know, maybe today is different in the sense that people are more forgiving for maybe a year or two. But in the end, the proof's in the pudding and we're going to have to see how many customers these people actually serve and how much revenue they generate and whether it's sustainable. And I will just add one point about Iridium. You know, the big difference between Iridium and Global Star was that the satellites for Iridium lasted 20 years, which allowed them to build up a business, pay for a second generation system. Global Star satellites lasted seven or eight years and the company, you know, put the company behind the eight ball the whole time, it's always been a massive struggle for them. And so, you know, one of the key questions in my mind for all these systems is how long their satellites last? Because if they only last five years, then it's all very well to say, oh, good, they'll all be upgraded. But the economics get massively, massively worse for any system if you can only make money and have to ramp up over a period of three, four, five years before you have to replace it. That's true. I mean, we do see that idea of go fast and break things. Randy, you had something to comment? Yeah, I was going to say, Tim, two things. One is the economics of the systems are enormously different than when they, the Iridium and Global Star and that whole wave of bankruptcies happen in terms of what it costs to build these satellites that are often being built just next to the engineer's desk, maybe just literally or figuratively, I don't know. And the launchers are enormously different in cost and then they were back in the olden days. And so I will say to you that I do agree with you, certainly on the wave, space has become sexy and the number of companies that have been spacked in pre-revenue stages is astonishing to me in terms of the successful outcome. Time will tell how many of them are still standing in five years or have gone through bankruptcy. And most of the, a lot of the companies we saw in bankruptcy, then second owners were successful in building the business. So in five years, Tim, I predict and we'll talk again, you and I. This is on the record, by the way. This is on the record. I predict that it will not be the same as the 90s. Of course, there will be plenty of companies that have consolidated or gone away because this is not sustainable in all the numbers there are in each different segment that exists. There will be winner, but I think there will be winners that don't go through bankruptcy. And there will be, I think there will be. And so we'll five years, Tim, we'll touch base. I'll take the bet. Okay. I mean, yeah, you know, it's ironic, you know, the people who've been here a long time and it's, you know, I found one most ironic comments about, you know, when you tell us that said it was investing in OneWeb, they basically said the best thing about OneWeb is it's already had its bankruptcy. And that sort of indicative of the history here. All right, folks, for those who are watching and attending, we do have the possibility to submit questions through Mentimeter. We can put up the code for you to quickly find. Yeah, type that in at Mentimeter. And we already have a few questions that I wanna get to. Honestly, easy, this easy, the first question is dealing with this term that we use mega constellations. Why must we use the term mega constellations? They opine, it is an imprecise term that hints that the more satellites that are in a constellation, the more risk the constellation poses. It clouds that fact. Any reactions to that? And maybe solutions? Professor Lewis. Yeah, thanks, Grace. It's a good question. And my interactions with various companies, yeah, they dislike the term quite considerably. You know, if you take the literal meaning, then of course it is not accurate. But we use mega for lots of things that are big. It's slang for things that are big. And in this case, the constellations that we're talking about are bigger than the typical space systems that we're used to. So it perhaps isn't quite as bad as you might think. But yeah, I mean, across the community I'm in, we tend to try and use the term large constellation instead. But I mean, there's a history there. You know, back in the 90s, we had little leos, which were the data only small satellites like all calm. We had big leos, which was iridium and global star and telodesic was referred to as mega leo to distinguish it from iridium and global star. And to be indicative perhaps of broadband communication as well. So I think it's just really got picked up from there that in a way, even though it shouldn't, it refers to the broadband constellations rather than anything else. Yeah, I mean, there's the technically precise approach to finding the right term. And then there's like the effect it's gonna have. And if you call them global constellations or mega constellations, it, you know, sets an image in some people's minds. I don't think we have a real solution to it though. This next question kind of detailed, what is the current thinking on the best ways for constellation operators to exchange enough information to safely coordinate their constellations? So general SSA and how is that gonna work in the future? Especially between private and state-owned systems. Anyone would like to take a swing at that? That's a tough one. I mean, let me throw in just a little bit of thinking about sort of, you know, there's an issue of when you have, you know, thousands of satellites, you've got to have a high level of automation. That's what SpaceX has talked about for its constellation, that everything happens by remote control. So you do run into a problem with two systems. You know, if they're both automated, then how do they react to one another? They might both move in the same direction. So they, you know, both, you know, don't take themselves out of the path. They both think they're diverting and they divert the same way and they're still on a collision path. So I think there's two aspects of it. One is like, you know, you have to have rules between operators in terms of saying, if you're doing this automated, then, you know, we don't move, but the second stage to that is, if you're doing it automated, we have to trust that your system actually works. And so I think one of the rules here has to be that regulators have to impose more disclosure obligations so that people know and can verify that the other company, you know, is doing the right thing, is gonna move this way. You know, that, you know, they always, maybe they say they always move to the left or something. But you have to have validation. There has to be disclosure. It can't all be kept confidential. And you have to, you know, have confidence at what the other side is doing makes sense and that what you're doing is not, you know, making the problem worse rather than better. I believe, I agree entirely with Tim, but I also don't know that this can be fully accomplished with the mounting number of satellites out there, including failed satellites and other orbital debris without having some kind of centralized or coordinated equivalent of an air traffic controller. Someone that's either a intergovernmental body or some country that takes the lead that, you know, continues to tell the, that the operators have to disclose their information to the same way for aircraft, you have to say where you are with your aircraft so that you can coordinate and try to avoid a collision. So I don't know that it can be done exclusively between the operators. There's just too many of them and there's too many differences in the degree of self-supervision. Yeah, I mean, I think I would almost categorize into two things. One is monitoring all the stuff that's debris and can't be maneuvered. And then the operator, you know, knows it's not moving and they have to, you know, move themselves. And then there's the case of two satellites that are potentially controllable and what do the two operators have to do? And I think the cases that were cited in the introductory talk about ESA and Starlink and OneWeb, you know, all satellites that were under control and the issue there was the simple fact of like, well, who's going to move? Is it you or me? And not necessarily knowing what Starlink was doing, you know, when it was said to all be automated, well, who knows how that automation works? Which way does it move? Do you trust it? All of these sorts of aspects. So I think, you know, I completely agree with Randy that for the debris side, the stuff that isn't moving, there needs to be, you know, considerably monitoring lots of good information about that, responsibility put onto the operators. But then, you know, monitoring what the operators are doing, understanding, you know, the regulators have a responsibility to, you know, understand that their procedures are best practice and that what they, you know, how they're reacting relative to one another. Oh no, it looks like he froze for a second. But I think that really leads into this next question about what happens if a constellation operator goes bankrupt. So please display that next question. What happens when a constellation operator goes bankrupt with a partially deployed constellation? Is there contingency plans? And they say that it seems unlikely a buyer would emerge. So Randy, how would a national regulator, you know, even consider that? Are they thinking about something like that? And what do you think would happen? Well, first I think that spectrum, most of these systems have spectrum and they and or have ITU priority of some sort, which are both valuable commodities. And so I believe that even if it's a giveaway of a system that someone would assume in bankruptcy and most bankruptcy laws of most countries are pretty much the same, would assume the liability and to deorbit or to do whatever else it is for the constellations and or use the constellations for another purpose, particularly if they have spectrum and the like. So, you know, a partially deployed system can still be used for certain purposes and or a buyer could pivot and come up with a new business model for the spectrum for the system. There was speculation at some point with OneWeb that even if they didn't continue with that constellation, the spectrum alone was very valuable to someone. It's also worth pointing out that during the bankruptcy, the satellites paused in the orbit raising, for example, they didn't continue in the way that they could have done. Because of course, if no buyer emerged, then the safest thing to do for the environment would have been to deorbit those satellites and it's easier to do that from the less risky from the lower altitude. So I think the liability issue is a really good one because obviously the responsibility is going to fall to the launching states, you know, to take the necessary action at the cost, of course. So it's good to see that actually there was that pause with OneWeb in terms of their operations. I have a directed question, although it is, you know, many people could weigh in and it's this one about prospects for reforming the regulatory system. Someone asks, Randy, what are the prospects of reforming the regulatory regime to include things like light pollution? You know, when you apply for a frequency, when you apply for a launch license, it doesn't ask on there, are you affecting ground-based astronomy or, you know, it just isn't on there. Should it be, and if you were a regulator, you know, how would you take some of these equities into consideration? Well, the regulatory regime has been undergoing in the last five years significant evolution to try to actually be quicker on its feet because the, you know, some of the regulators and the ITU process and the FCC was a very slow one and wasn't addressed to a lot of the commercialization of space. And there was a real move in the last five years to try to accelerate and expedite regulatory approvals and to make it easier to go to space. I think that there are, though, a number of issues as the technology continues to evolve with large constellations, issues that no one thought of really, the light pollution when they were building it, et cetera. I think the FCC in particular has pushed back recently and said satellites are not governed by Environmental Protection Act. There's an ongoing case in DC that's by competitors, competitive satellite companies challenging the Starlink constellation. And I think that, you know, so I think that the regulators are gonna need also to kind of come together on some of these issues because these Leo constellations and large constellations, especially the ones that don't need landing rights in other countries, the other countries don't have a say on what those constellations are gonna look like and how it affects their territory. So it's not just, it shouldn't, I don't think it should just be the regulator of the existing country that has a say, but then that wreaks havoc. If you start imposing all these other requirements like light pollution, NEPA, everything else, then the speed that we've gained over the last five years to support commercialization and the space industry will become halted. And so it's a real trade-off. It's a real trade-off of how do we take into consideration these issues and at the same time, how do we support the commercialization of space? That's the dilemma, that's the paradox. Anyone else wanna weigh in? Should the regulators ask that question? Should it be on, you know, their application? Andy? Yeah, so I mean, at some point in the distant past, the FCC didn't consider space debris guidelines and then at some point they did. And of course, part of the logic behind its inclusion was that, you know, orbital debris affects the assets that is under-regulating kind of directly. But I mean, it's, you know, it would be trivial for a regulator to add in this extra kind of step that they have to do. But I think, as Randy said, it comes with a cost which is then imposed on that particular system. And I think that this is where really, as Randy said, we need the regulators to come together. And I mean, I think it would be possible and sort of agree that, you know, from a certain time, all the major spacefaring countries agree to include, you know, a certain set of minimum standards against light pollution. And, you know, I will also point out that there is actually a law that regulates, well, there's one single law that regulates light pollution from space. And this is the US law against space advertising, which, you know, sort of came in via, I think it was directed from the Congress. So it didn't sort of go through the regulatory process. So, I mean, it is possible. Tim, if we add these requirements, these questions on already to, you know, the mega-consolation prospects for mega-consolations, how does that change your prognosis and your predictions for the future? Would it actually slow down the growth of mega-consolations? Well, I think one of the issues that has to be considered is the, you know, degree to which it makes people flee to regulatory jurisdictions which don't have these rules. I mean, you know, it's already been a big issue in launch about, you know, to what degree do you have to post bonds? To what degree do you have to have insurance against casualties if something falls out of space and lands on someone's head? You know, all of these sorts of things is like, well, you know, for any satellite operator has to then take the decision of like, well, do I go to this country where it has these, you know, impositions? Maybe, you know, if that company is going to be really, if that country is going to be really supportive of me and help to lobby to get my stuff, you know, in the right place, regulatory-wise in terms of market access, then maybe that's a trade-off worth making. On the other hand, you're going to have a more fly-by-night operators going to countries which don't impose these rules and that doesn't help anyone. All right, thank you for that. Listen, last question, I have to ask it because it was upvoted so much and we have to face, you know, this conception, this idea, how do you avoid the concern that mega-consolations are essentially appropriating certain orbits? That the sole occupant of a particular orbit that's a concern, anyone want to weigh in? Well, I would say it's not just orbits. I mean, clearly that when there's a lot at a particular altitude, it gets very difficult for anyone else to launch that. I worry at least as much about appropriating spectrum and we have this dilemma between the US rules and the ITU rules, who has priority, who has to share, you know, Elon Musk said he doesn't respect the ITU like he doesn't respect the Securities and Exchange Commission, you know, when people say that sort of thing, you know, how do you resolve it? I don't know. All right, listen, last thoughts as we wrap it up, the idea that we have all these competing uses, I think we've presented kind of a whole buffet of issues and questions. Maybe we can get to any particular answers though but any last thoughts, please go ahead. So I think from my side, if I was in the position of an operator, I'd actually be quite frustrated. They've demonstrated perhaps the reliability of the systems, they've innovated towards smaller satellites that are more capable, they've addressed all of the IODC concerns on an individual satellite basis. Yeah, I'd be quite frustrated at the moment, you know, they've really pushed forwards really quite effectively and yet they're seeing all these concerns being raised still that the goalposts are shifting all the time but I think that's an ongoing process that they're gonna have to deal with. Fair enough, thank you for that. I wanna thank all my panelists for offering their wisdom and their expertise in this last hour.