International licensing and reentry.

Summary

T-Minus Space Daily: International Licensing and Reentry

Release Date: February 22, 2025
Host: Maria Varmazes, N2K Networks

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Introduction

In this episode of T-Minus Space Daily, host Maria Varmazes delves into the intricate processes of international licensing and spacecraft reentry. She welcomes Sebastian Claus, CEO and co-founder of the European startup Atmos Space Cargo, and Dr. Ingo Baumann, partner at BHO Legal, to discuss Atmos Space Cargo's groundbreaking mission and the regulatory challenges they navigated to achieve their first reentry demonstration.

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Atmos Space Cargo's Phoenix Mission

Sebastian Claus introduces Atmos Space Cargo and their flagship project, the Phoenix capsule—a 100-kilogram payload return vehicle designed for applications in life sciences, space manufacturing, and defense. The Phoenix is set to launch from the Kennedy Space Center in Florida and return in international waters.

Sebastian Claus [02:12]: "Phoenix is a 100 kilogram class payload return vehicle for things like life sciences in space and in space manufacturing, but also defense applications."

Claus emphasizes his dual background in aerospace engineering and defense, which has been instrumental in steering Atmos Space Cargo from its inception in 2021 to its current team of 50 employees.

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Navigating International Regulatory Frameworks

The core of the discussion centers on the complex regulatory landscape that Atmos Space Cargo had to traverse. Maria Varmazes prompts the conversation by highlighting the challenges of operating across multiple countries.

Maria Varmazes [00:51]: "If you are based in one country, want to launch in another, and then reenter in a third territory... where on earth do you even start with that process?"

Sebastian Claus outlines the multifaceted licensing requirements:

1. FAA Payload Determination: Ensuring the capsule and its payload are safe for launch from U.S. soil.
2. German Regulatory Compliance: Despite Germany's robust space industry, the absence of a comprehensive space law necessitated a waiver from the German Space Agency (DLR) confirming Atmos as a German satellite operator.
3. International Telecommunication Union (ITU) Frequency Licenses: Securing the necessary frequency assignments.
4. Export Controls: Managing the legalities of exporting technology from Germany to the U.S.

Sebastian Claus [04:39]: "We needed to do what's called an FAA payload determination... Atmos is a German company, so it's registered in Germany."

Dr. Ingo Baumann complements this by detailing the technical aspects of ITU filings and the challenges posed by the lack of a unified space law in Germany.

Ingo Baumann [07:21]: "ATMOS has shown the complexity of the space industry and its regulatory and legal frameworks and how to navigate through them."

Baumann highlights the difficulties posed by relying on interim solutions, such as obtaining confirmation letters from German authorities, due to the absence of established space legislation.

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Challenges Faced and Strategic Approaches

Sebastian shares insights from his military background, drawing parallels between orchestrating complex operations like skydiving trainings and managing spacecraft reentry processes.

Sebastian Claus [04:39]: "I used that experience to conduct our first drop test... there are always operational and legal aspects involved."

The conversation reveals the proactive measures Atmos Space Cargo undertook, including early engagement with legal experts and establishing support networks in the U.S. to streamline the licensing process.

Sebastian Claus [16:58]: "You need to have people that have walked this path before and that know the right people also. And take your time."

Dr. Baumann reinforces the importance of early and serious preparation, especially for reentry missions, to avoid setbacks.

Ingo Baumann [19:05]: "Start early and take it seriously are the two best advices you can give."

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Future Outlook and Recommendations

As the space industry evolves, both guests offer strategic advice for emerging companies:

Sebastian Claus advises maintaining simplicity in mission planning to mitigate regulatory hurdles.

Sebastian Claus [21:10]: "Keep it simple. We chose to go to a reentry location over the Indian Ocean... that simplifies the whole regulatory situation."

He also underscores the continuous nature of compliance, hinting at future regulatory requirements for specialized payloads like biomedical research.

Dr. Ingo Baumann points out the need for enhanced international cooperation among regulatory bodies to streamline processes, especially for emerging sectors like on-orbit servicing.

Ingo Baumann [22:12]: "We all have to work on that and gain experience as fast as possible because otherwise all the market expectations... will not happen as predicted."

Claus adds that as more companies venture into reentry missions, the processes will likely become more standardized, although current collaborations between international authorities remain limited.

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Conclusion

The episode wraps up with insightful final thoughts from both Sebastian Claus and Dr. Ingo Baumann, emphasizing the ongoing challenges and the imperative for the space industry to develop robust legal frameworks. The discussion highlights the pioneering efforts of Atmos Space Cargo in navigating uncharted regulatory territories, setting a precedent for future international collaborations in space missions.

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Key Takeaways

• Complexity of International Licensing: Launching and reentering spacecraft across different countries involves multi-layered regulatory approvals.
• Importance of Early Preparation: Engaging legal experts and starting the licensing process well in advance are crucial for mission success.
• Need for International Cooperation: Enhanced collaboration among global regulatory bodies is necessary to streamline space operations.
• Continuous Compliance: As technology and missions evolve, so must the regulatory frameworks governing them.

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For more insights and updates on the global space industry, visit N2K Networks.

Transcript

[Maria Varmazes]

You're listening to the N2K space network.

[Dave]

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[Maria Varmazes]

Yes, it's cliche, but it's also true. We're always talking about the fact that space is hard, but the process to launch and re enter a spacecraft is extraordinarily complicated. Add to that, if you are based in one country, want to launch in another, and then re enter in a third territory, well, where on earth, quite literally, do you even start with that process?

[Sebastian Claus]

Foreign.

[Maria Varmazes]

Welcome to T minus deep space from N2K Networks. I'm Maria Varmazes. European startup Atmos Space Cargo has received regulatory approvals that it needs for its first mission to demonstrate reentry technologies. The company is based in Germany and is launching its Phoenix capsule from the United States and intends to return it in international waters. Sebastian Claus, CEO and co founder of Atmos Space Cargo and Dr. Ingo Baumann, partner at BHO Legal, walk us through the process of obtaining licenses for this very complex first mission.

[Sebastian Claus]

I'm Sebastian, I'm the CEO and one of the co founders of atmospace Cargo. I come from a double background. So on the one side I'm an aerospace engineer, did my bachelor's about atmospheric reentry and the master's about startup behavior of liquid rocket engines for reusability. And the other half of my background is a defense background. So I served 14 years as an officer in the German army, was a recovery specialist in special operations and founded the company in 2021 together with three co founders and we've grown the company to 50 employees. Now what we do is re entry technology. Specifically we built a vehicle that we call Phoenix. And Phoenix is a 100 kilogram class payload return vehicle for things like life sciences in space and in space manufacturing, but also defense applications. And we are launching Phoenix to space for the first time in two months from now in April. It's going to launch from the US from Florida Kennedy Space center. And Atmos is based in Europe.

[Maria Varmazes]

Thank you for that Sebastian. I appreciate that. And the other voice I think we'll be hearing from today. Ingo, would you mind Introducing yourself as well.

[Ingo Baumann]

Yeah. Ingo. Ingo Baumann. I'm partner at BHO Legal. BHO Legal is a rather small but highly specialized law firm based in Cologne, Germany. We are now 30 people overall, 20 lawyers. I'm leading our space and satellite team. My background is academic wise from the rather famous Cologne Institute of Air and Space Law, one of the very few dedicated institutes of that kind. And before establishing the law firm, I was for seven, eight years in house lawyer and later also manager in the German Aerospace center dlr. And from that background we established the law firm.

[Maria Varmazes]

Okay, so Sebastian, it's been really fascinating hearing about what you all are building. And I think one of the things that's also very fascinating to me about what you're making is also sort of the process that you all are going through as a European company that is going to be doing such a complex mission within the United States. I have to imagine that has been a very interesting process to navigate. And I was wondering, why don't we maybe start with what has that been like for you all?

[Sebastian Claus]

Yeah, yeah, it is indeed very interesting. So the thing is that in my old job in the military, I was already responsible to organize things like for example, skydiving trainings where you have very complex operations with several aircraft and helicopters and you need to get permissions to do those jumps. So there's always an operational aspect and a legal aspect involved in it. And so I used that experience to conduct our first drop test. So we did helicopter drop tests, for example, where you also need to get permissions from air traffic controllers, from the owner of the properties where you're dropping things, and then from environmental protection agencies and so on. So I think in your first drop test there were like 15 entities involved. So there was a good training, let's say, for what we need to do now, because now it's obviously on a much larger and more publicly visible scale. And so for this first launch that we are now conducting with Phoenix, I think there's like four aspects, aspects that we needed to get right. So I think the most important one we have just made public, we needed to do what's called an FAA payload determination, where the FAA is pretty much analyzing our capsule and the payloads that it's carrying. And it's pretty much saying that this capsule is safe to be launched on a US launcher from US soil. So that's aspect number one. Aspect number two is Atmos is a German company, so it's registered in Germany. And so the satellite is also treated as a German Satellite and INGO can explain that in more detail how that really happens. So in Germany we do not have a space law in that sense. So what we needed to get was a waiver from the German space agency DLR pretty much saying that, yes, ATMOS is a German company and this is a German satellite. And then on top of that, of course we needed to have our licenses for frequencies in place. So those come from the itu, the International Telecommunication Union. And then on top of that we need to be able to actually export the vehicle from Germany to the US and some of those things that we export, they fall under export control. So yeah, four different aspects and I think we can go into a lot of detail here together.

[Maria Varmazes]

Yeah, I was going to say each of those would be fascinating. So Ingo, I see you're ready to contribute something. By all means.

[Ingo Baumann]

Yeah. Well, as Sebastian shortly summarized, and what ATMOS has done here really shows the complexity of the space industry and its regulatory and legal frameworks and how to navigate through them. So first the ITU filings and the national frequency assignment that was done through the German administration, which is called Bundesnetzagentur or short B netsa. It's complicated as such, but it's less illegal. It's more a technical procedure. You have to fill out all these details in the forms of the itu, send it through the administration, administration, coordinate everything. That was rather smooth process on that side because also our German administration is very used to that and is also very supportive. So we had really open door, great support, also really hands on support how to fill out certain aspects and so on. So I think Sebastian, you can confirm that was really a very agreeable and well, working procedure. On the other hand, on the space law side it was let's say from the outset more complicated because here we had already two countries, Germany and the US and let's say an unusual payload with reentry by a new company, never flown before. So lots of firsts in that process and in any regulatory process, firsts make it always more difficult.

[Maria Varmazes]

Yes, of course. I mean people have never seen it before. So they go, okay, you're now forging a new path. What does this mean? There's no model to use. I imagine that is extremely difficult. And then add in that you're talking two different countries exponentially more difficult, I must imagine.

[Ingo Baumann]

Yes, exactly. And one of the speciality while German companies are launching with SpaceX and also rocket Lab all the time, as you know well known, our European launcher situation has been very bad over the last Months and even longer. So there was not much choice. And so every, every German operator wanting to launch something had to go and is still going to SpaceX. And while it's already a certain issue if you are just launching a normal satellite payload, a small satellite, et cetera, because on the US side things have become stricter. SpaceX is now asking for confirmation that the the client has all the necessary licenses and approvals earlier. And they are also way stricter and if you don't deliver the copies of all the licenses to their satisfaction, they simply don't launch you in the end. Mostly so far it has been managed, but there was also some situation a few months before we came where in fact a number of German customers were on some SpaceX and they were very late in bringing the necessary copies. Also because Germany is a well developed space faring nation with a very big and thriving industry, but has no national space law. And that is of course from an US perspective is surprising, no, everybody would expect, hey, it's Germany. While they should have a space law since a long time, there should be no issue to just send the copy of the license. But as we don't have a law, there is also no obligation to get a license and therefore there is also no procedure to get a license. And the solution to that is. But this is, let's say it's an interim solution and it's also, let's say, making making the German authorities a bit nervous is to issue upon request a kind of rather simple and short letter saying that yes, Germany is a party to the UN space treaties, is taking taking care to fulfill its international law obligations, but has currently no space law and therefore there is no obligations for license. And so it's a kind of short confirmation letter which you get. But because the number of German companies asking for that letter, and also again new companies, new technologies and also larger projects is increasing constantly. Our DLR agency is a bit nervous to issue all these letters because in the end without a legal basis, they cannot really control these activities for the moment. And while we are working on a space law since a long time, and also the current government has made quite big steps forward just ahead of a real draft. But now, as many of the audience may also know, our government failed and there will be new elections. And therefore this process of creating the space law was halted for another time. In fact.

[Maria Varmazes]

We'll be right back.

[Dave]

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[Maria Varmazes]

That sounds incredibly even more complex than I think the norm, which is already extremely complex for many people's point of view. But that is quite an ordeal there. Sebastian, I'm wondering if when you speak with your peers who are, you know, creating spacecraft within Germany, if what your advice has often been to them, given that you've been going through this incredibly complex process, what have you been advising your peers?

[Sebastian Claus]

It's a very good question. I think actually even though this is complex, the licensing for a launcher and you know, some of the companies that we speak to is ESA Aerospace and Rocket Factory, Augsburg and High Impulse, I think the licensing for a launcher is actually still way more complex because of the much higher risks involved obviously.

[Ingo Baumann]

Right.

[Sebastian Claus]

Like when you're talking about rocket stages that are fueled with like several tons of fuel and you launch that close to population, it's a completely different level of risk than we have here. So I would rather say that we are rather taking advice from them than us advising them. So sure, just to be a bit.

[Maria Varmazes]

Humble there, I appreciate that. I guess then I'll flip the question around. What advice did you get that maybe made this process more easy for you?

[Sebastian Claus]

I mean, one thing is for sure you need to take this very seriously.

[Ingo Baumann]

Right.

[Sebastian Claus]

So you have to start this process very early on and you have to get yourself some professionals to work with you. Right. Like, I mean, INGO is the best examples here, but we also got ourselves some support in the US So you need to have people that have walked this path before and that know the right people also. And take your time, take your time to do it. Right. Because if you don't do it, I mean, we all saw a launch of a US Company a couple of months ago that went to space and was not allowed to come back because licenses were not in place. So you have to take this very seriously.

[Maria Varmazes]

Yeah, absolutely. And you also had mentioned sort of the timeline. We're pretty close to launch for you all. So tell me a bit about the expected timeline and maybe what comes next.

[Sebastian Claus]

Yeah, I mean, for the, for the first flight now we're, we're looking at not earlier than April for launch. As you know, it's the space industry, right? So there, there have been delays on this mission, like on this rocket launch before, because one of the other payloads was not ready. It's not on our side. We cannot influence it, really. So that might still happen, but not earlier than April is when we're going to launch. And you know, since we're talking about legal aspects here, we have actually already filed for our second flight. So our second flight is supposed to come back to Santa Maria, the Azores, Portugal. So in the middle of the Atlantic Ocean instead of the Indian Ocean, like on this first flight now. And you know, speaking about taking this seriously, we filed for the reentry license already at the end of last summer. So we want to make sure that we have everything in place in time. Always.

[Maria Varmazes]

Fantastic. And Ingo, I think I want to ask the same sort of a similar question that I asked Sebastian about your advice, given that you do work with a number of companies who are going through their own various versions of sort of what we've been describing here. Given the complexities, I wonder, aside from start early, which makes a lot of sense, what else you would advise companies that are coming to you?

[Ingo Baumann]

I think Sebastian summarized it perfectly. Start early and take it serious are the two best advices you can give. And start early even ahead, because it takes time, regulatory processes take time. And then you may have things like summer holidays or Christmas holidays or illness of certain people or additional questions. And as we already said in our case, also a new company with a new payload and etc. Etc. And quite, quite some other European companies having normal payloads, small satellites, etc. For transport emissions. They simply realized if you come, if you come in, if you start preparing yourself in the last minute, you get into real trouble. You don't want to have even up to that, you cannot take the launch that you have to get off, that your mission is postponed, etc. Etc. So that's really the best advice we can give. Of course, as a lawy, I would always say take lawyers on board and as soon as it is involving reentry, I would definitely advise to do so. If it's a normal small submission, maybe even help with some logistic companies, it can be done without. I'm not recommending, but it's possible. But if we are talking about reentry vehicles, then definitely it's more complex.

[Maria Varmazes]

And certainly as we see more and more companies doing re entry, I imagine, you know, the needs will become more complex, but also hopefully the process will be a little more streamlined. Well, I guess fingers crossed on that. But gentlemen, thank you both so much for your time. I want to make sure I give you both the opportunity to sort of leave our audience with any final thoughts either about what we've discussed or anything else, truly. So Sebastian, why don't I start with you?

[Sebastian Claus]

Yeah, sure. So one advice that I can also give to everybody else that wants to go for something like this is keep it simple. Right? So in our specific case for reentry, we chose to go to a reentry location over the Indian Ocean, like in the middle of nowhere, where there's no islands, very little air traffic, very little shipping traffic. So that simplifies the whole regulatory situation a lot in comparison to actually landing such a vehicle, you know, let's say in the continental U.S. right, so, so that's one thing. And then the final remark would be it never stops. Right. Like this is only the first step for us right now. We're already looking at future challenges like for example, making sure that for biomedical research in space we have all the regulatory aspects in place, like you know, making sure that the vehicle is certified as a sterile environment for these special payloads. So it never stops. And you got to work with the right people for those.

[Maria Varmazes]

Absolutely. Ingo to you as well.

[Ingo Baumann]

Well, no, one thing which is really surprising is you. You may imagine that the authorities in Germany, in France, in uk, in the us they are in also in while at least regular exchange, that they know how, whom to call, that they know how to exchange, etc, so that processes can be simplified. It's a bit surprising to see that this is Absolutely not the case. They may meet also in our conferences from time to time, but a real exchange and collaboration between the main regulatory authorities is not really there. And that's a bit surprising. You would expect that. And that can make things also more complicated. And as we all know, the international space law is not really evolving. We have the old treaties, of course, step by step, but it takes a very, very long time. And okay, here in the case of Atmos, we were talking about a reentry vehicle. But another topic where these collaboration on international level between the authorities is or will be becoming super relevant is on orbit servicing or isam osam, however, which abbreviation you use because here you have the servicer object and the service the target object and they may come from two different countries. And then you have really the need for this interaction. And okay, that's still at the starting point. We have some demo missions. Technology is emerging, but the real market is not yet there. And that will be a real problem. So we all have to work on that and gain experience as fast as possible because otherwise all the market expectations which are surrounding these in orbit, servicing, etc. They will not happen as predicted.

[Maria Varmazes]

And that's it for T deep space brought to you by N2K Cyberwire. We'd love to know what you think of this podcast. You can email [e-mail] or submit the survey in the show notes. Your feedback ensures that we deliver the information that keeps you a step ahead in the rapidly changing space industry. N2K's senior producer is Alice Carruth. Our producer is Liz Stokes. We're mixed by Elliot Peltzman and Trey Hester with original music by Elliot Peltzman. Our executive producer is Jennifer Ibin. Peter Kilpe is our publisher and I am your host, Maria Vermazes. Thanks for listening. We'll see you next time.

[Sebastian Claus]

Foreign.

[Dave]

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