Compliance: Definition and procedure

Different types of request

Preliminary Compliance: Definition and Procedure

 

Definition

A Preliminary Compliance or preliminary compliance certificate at the end of a development stage provides:

  • A statement of compliance at this stage of development,
  • Recommendations for achieving full compliance.

The Preliminary Compliance request, which generally takes place after the PDR (Preliminary Design Review) and preferably before the CDR (Critical Design Review), is a highly recommended process for any type of project in order to anticipate potential problems that could lead to non-conformities during the final request.

It can be requested by anyone responsible for the design or development of a critical system or sub-system, so it is not limited to operators, but also applies to manufacturers (platform manufacturers, equipment manufacturers, etc.).

The documents submitted after review by the CNES may be legitimately used later by the operator in support of its request for authorisation.

Responses to the recommendations made as part of the preliminary compliance shall be provided at the time of the final request for authorisation, in support of the file.

 

 

Procedure

Operators wishing to request a preliminary compliance certificate should contact the CNES FSOA Office. The documents required for the analysis shall be submitted on the FSOA platform. For preliminary compliance, it is not necessary to provide all the documentation requested for final compliance.

Request for authorisation: Definition and Procedure

 

Definition

Any authorisation to control a space object is given for all the technical operations necessary for this control, whether they are carried out by the operator itself or by one or more persons acting under its authority.

The control operation may concern:

  • The partial or complete lifetime of the satellite in orbit, from launch to de-orbiting
  • The life of the satellite from its launch to its actual transfer to an operator not subject to the FSOA.

There are therefore three forms of authorisation:

  • Authorisation for control and/or return to Earth: this type of authorisation is given for all the technical operations required for this control and/or return to Earth of the space object.
  • Authorisation to transfer control of a launched space object.
    • Transfer between two operators subject to the FSOA.
    • Transfer from an operator subject to the FSOA to an operator not subject to the FSOA.
    • Transfer from an operator not subject to the FSOA to an operator subject to the FSOA.
  • Authorisation to control and transfer control of a launched space object.

 

Procedure

The operator first contacts the CNES FSOA office and the DGRI. A compatible FSOA schedule is defined for the space operation. The FSOA application must be submitted on the FSOA discussion platform no later than 5 to 6 months before the launch date.

 

The official tool for discussions and submitting an FSOA application is the FSOA Platform.

The FSOA application consists of three sections:

  • An administrative section monitored by the Ministry of Space.
  • A technical section monitored by CNES.
  • A description of the characteristics of the payload for the French Ministry of Armed Forces.

For further details on the procedure to be followed, see the Authorisation process page.

Licence constituting authorisation: Definition and Procedure

 

Definition

The Licence is aimed at operators wishing to launch several satellites based on the same platform and with the same flight envelope. The operator may apply for a licence that constitutes authorisation. This means that the licence alone does not constitute authorisation for in-orbit control of the satellite. For each launch of a satellite covered by this licence, the operator shall provide the FSOA Office with all the information relating to the mission and the elements due, in response to the requirements set out in the order relating to the licence.

 

Procedure

In this case, the application is made in the same way as for a simple control application and the processing times are the same. The operator shall specify in the application document that it is applying for a licence constituting authorisation.

Once the licence has been obtained, the operator shall provide the CNES FSOA office with the documents specific to the licensed satellite to be launched according to a schedule defined in the licence requirements. It must also inform the Minister responsible for Space one month before the implementation of any operation covered by the licence.

It should be noted that there are also two other types of licence that can be used to reduce the time required to obtain authorisation, for operations that do not fall within the scope of a licence constituting authorisation (if they are too different).

  • Administrative licence: certifying, for a fixed period (ten years maximum), that a space operator can provide moral, financial and professional guarantees.
  • Technical licence:  certifying, for a specified period (ten years maximum), the compliance of systems and procedures with technical regulations.

In-orbit transfer: Definition and Procedure

 

Definition

In the case of an initial operator subject to the FSOA, an in-orbit transfer occurs when this operator hands over control of a satellite to another operator who may or may not be subject to the FSOA. In practice, a transfer often (but not necessarily, for example if one operator takes over another) involves a change of control centre (equipment and staff) and a change of administrative ownership.

In the event of a transfer to an operator not subject to the FSOA, the transfer will result in the closure of the FSOA file relating to this satellite, which will no longer be monitored by the FSOA Office.

A request for authorisation to transfer a satellite that has already been launched may concern (operator A transferring control to a receiving operator B):

  1. Operator A subject to the FSOA => Operator B subject to the FSOA.
  2. Operator A subject to the FSOA => Operator B not subject to the FSOA.
  3. Operator A not subject to the FSOA => Operator B subject to the FSOA.

Procedure

A distinction is made between the three cases 1, 2 and 3 mentioned above in the procedure to be followed:

  1. In the case of a transfer of control from an operator A subject to the FSOA to another operator B subject to the FSOA, there must be a joint request from the operator with control of the space object and the receiving operator. The receiving operator shall provide all the documents required for a request for in-orbit control.
  2. The procedure is simpler in the case of a transfer from an operator A subject to the FSOA to an operator B not subject to the FSOA. The request shall state the nature of the space object or group of coordinated space objects to be transferred and include information and documents:
    • proving that the receiving operator is not subject to the FSOA,
    • giving all guarantees that the space object or group of coordinated space objects to be transferred will be registered after the transfer and that the transfer will be notified to the Secretary-General of the United Nations.
  3. If an operator B subject to the FSOA wishes to regain control of a satellite from an operator A not subject to the FSOA, then it must follow the classic application procedure. => See “Request for authorisation »

A transfer may have been planned initially, or be envisaged at a later date.

  • If the request for transfer is initially planned, it is made jointly with the request for control authorisation; an Authorisation to control and transfer control can then be issued. This is the case, for example, with in-orbit deliveries, where the initial operator (in practice the manufacturer) hands over control of the satellite to its customer (the end user) once it has been put into position and/or tested to ensure that it is working properly. 
  • If the transfer request is made later, for example in the event that the initial operator wishes to sell the space object after a few years, then an Authorisation to Transfer Control is issued, in addition to the initial control authorisation.

Technical Event: Definition and Procedure

 

Definition

A Technical Event (TE) is an event not foreseen by the authorisation or a technical incident which occurs during the mission or the life of a space object and which affects the conditions of the space operation as authorised. A TE can also be linked to the end of life of the space object.

The operator must inform CNES immediately of any events not foreseen by the authorisation and of any technical incident (art. 7-II of decree 2009-643).

Any technical event will give rise to a new analysis by the FSOA office, which will, if necessary, propose to the Ministry of Space the corrective measures to be made to the authorisation granted. The Minister responsible for Space may then modify accordingly the authorisation granted.

A Technical Event may, for example, be issued following a technical anomaly such as the appearance of an in-flight anomaly or the loss of a satellite.

More generally, if after the authorisation has been issued the operator intends to proceed with:

  • A significant change in the conditions for implementing this operation.
  • A request to implement on-orbit servicing for a satellite already subject to the RT.
  • Any substantial change in the information provided under the administrative section.

In this case, the operator must immediately inform the Minister responsible for Space, who will refer the matter to the minister of defence and, if necessary, the president of the Centre national d’études spatiales (art. 7-I of decree 2009-643).

 

Procedure

The operator must submit the documents relating to the Technical Event on the FSOA platform:

  • Technical Event declaration document.
  • Technical justification and information documents.

The FSOA Office then deals with the Technical Event. It may ask the operator for further information to finalise its analysis.

Requirements may be added following this analysis, in which case the operator is informed via the FSOA platform. These requirements may, for example, concern:

  • Closer monitoring of flight equipment.
  • The development of new operating modes.
  • Preventive orbit change and propellant draining.

If new requirements are added, the authorisation order initially issued by the Ministry of Space will be amended accordingly.

Mission extension: Definition and Procedure

 

Definition

Operators may request a mission extension if they wish to extend their mission beyond the authorisation end date granted by the authorisation order.

 

Procedure

The decree 2009-643 of 9 June 2009 specifies that the extension application file must be provided to the Minister responsible for Space, by post or electronic means, at least six months before the end of the period mentioned in the authorisation order.

The Minister responsible for Space sends this file to the CNES, which reassesses the compliance of the systems and procedures with the technical regulations applicable on the date of the first request for authorisation. On the basis of the CNES notice, the Minister responsible for Space may, after giving the operator the opportunity to present its observations, modify the authorisation accordingly.

To compile the extension application file, the operator will be able to rely on the Best Practice Guide.

Disposal: Definition and Procedure

 

Definition

Disposal of a satellite may occur:

  • After the operational phase as set out in the order.
  • After the appearance of an anomaly (TE) that renders the satellite non-compliant with the Technical Regulations.
  • At the end of a previously agreed mission extension.

The disposal phase, which may consist of:

  • A de-orbiting/re-orbiting phase for a satellite equipped with a propulsion system or a suitable mechanical system (solar sails, for example).
  • A passivation phase:
    • Fluidic passivation.
    • Electrical passivation.
    • Passivation of mechanical energy.
    • RF passivation.

Via data from Space Track, the CNES FSOA Office observes the orbit of the de-orbited satellite until its atmospheric re-entry, if it takes place.

 

Procedure

See “Technical Event”.

On-orbit servicing operation: Definition and Procedure

 

Definition

On-orbit servicing” means a service carried out by a service vehicle that requires a rendezvous and/or approach and/or contact phase with a target object, such as inspection, capture, docking, in-orbit transfer, repair, assembly, fluid transfer and undocking. This is the definition given in Article 1 of the technical regulations.

In the case of an on-orbit servicing activity, the operator subject to the FSOA, whether providing or receiving a service, must have an in-orbit control authorisation. There are several different cases:

  • Case of an operator subject to the FSOA wishing to provide on-orbit servicing:
    • Before the start of the operation: the on-orbit servicing activity can be taken into account at the time of the initial application for control authorisation;
    • After the authorisation has been issued, it must inform the Minister responsible for Space without delay;
  • Case of an operator subject to the FSOA wishing to benefit from on-orbit servicing

In all cases, the operator wishing to provide or receive on-orbit servicing must, during the review of the application (before or after the authorisation application), demonstrate that this activity complies with the requirements of the Technical Regulations (Chapter V “Specific technical requirements for on-orbit servicing”).

 

Procedure

With the exception of cases in which the provision of on-orbit servicing is provided for in the control authorisation, any operator subject to the FSOA wishing to provide or benefit from on-orbit servicing must inform the Minister responsible for Space without delay. The operator shall provide a description of the contractual relationship, the sharing of responsibilities and the security guarantees between the supplier and its customer, accompanied by all the supporting documents required for this purpose, as well as proof of the service provider’s legal capacity to act (see Article 2 10° of the order of 23 February 2022 relating to the composition of the authorisation file). The operator may be asked at any time to provide additional information to the Minister responsible for Space, the minister of defence or CNES. CNES may also propose corrective measures to be taken in respect of the authorisation granted.