EN   EN 
 
 
 EUROPEAN  
COMMISSION   
Strasbourg, 15.2.2022  
SWD(2022) 30 final  
 
COMMISSION STAFF WORKING DOCUMENT  
 
IMPACT ASSESSMENT REPORT  
 
Accompanying the document  
Proposal for a  
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL  
establishing the Union Secure Connectivity Programme for the period 2022 -2027  
{COM(2022)  57 final}  - {SEC(2022)  77 final}  - {SWD(2022)  31 final}   
 
 EN          1     EN  Table of contents  
1. INTRODUCTION: POLITI CAL AND LEGAL CONTEX T ................................ ................................ ..........................  3 
2. PROBLEM DEFINITION  ................................ ................................ ................................ ................................ ...............  8 
 The core problem  ................................ ................................ ................................ ................................ ................  8 
 Problem drivers  ................................ ................................ ................................ ................................ ...................  9 
 Who is affected, in what ways and to what extent?  ................................ ................................ ...........................  15 
 How will the problem evolve?  ................................ ................................ ................................ ..........................  16 
3. WHY SHOULD THE EU AC T? ................................ ................................ ................................ ................................ ... 19 
3.1. Legal basis  ................................ ................................ ................................ ................................ ........................  19 
3.2. Subsidiarity  ................................ ................................ ................................ ................................ .......................  19 
4. OBJECTIVES: WHAT IS TO BE ACHIEVED?  ................................ ................................ ................................ ..........  21 
4.1. General objective  ................................ ................................ ................................ ................................ ..............  21 
4.2. Speci fic objectives  ................................ ................................ ................................ ................................ ............  21 
4.3. Consistency with other policies and objectives  ................................ ................................ ................................ . 21 
5. WHAT ARE THE AVAILAB LE POLICY OPTIONS?  ................................ ................................ ................................  23 
5.1. Definition of options  ................................ ................................ ................................ ................................ .........  23 
5.2. Option 0: Baseline  ................................ ................................ ................................ ................................ .............  24 
5.3. Option 1: Fully Public  ................................ ................................ ................................ ................................ ....... 25 
5.4. Option 2: Public -private -partnership: EU Concession  ................................ ................................ ......................  25 
5.5. Option 3: Service procurement from a non -EU private constellation  ................................ ...............................  26 
5.6. Other Options discarded  ................................ ................................ ................................ ................................ .... 27 
5.7. Summary  ................................ ................................ ................................ ................................ ...........................  28 
6. WHAT IS THE IMPACT OF THE POLICY  OPTIONS?  ................................ ................................ .............................  29 
6.1. Economic impact ................................ ................................ ................................ ................................ ...............  29 
6.2. Social impact  ................................ ................................ ................................ ................................ .....................  33 
6.3. Environmental impact  ................................ ................................ ................................ ................................ ....... 34 
7. HOW DO THE OPTIONS COMPA RE? ................................ ................................ ................................ .......................  36 
7.1. Effectiveness  ................................ ................................ ................................ ................................ .....................  36 
7.2. Efficiency  ................................ ................................ ................................ ................................ ..........................  38 
7.3. Coherence  ................................ ................................ ................................ ................................ .........................  41 
7.4. Feasibility  ................................ ................................ ................................ ................................ ..........................  41 
7.5. Comparison summary  ................................ ................................ ................................ ................................ ....... 42 
8. PREFERRED OPTION  ................................ ................................ ................................ ................................ .................  43 
8.1. Concession as the Preferred Option  ................................ ................................ ................................ ..................  43 
8.2. Implementation of the Concession  ................................ ................................ ................................ ....................  44 
9. HOW WILL ACTUAL IMPA CTS BE MONITORED AND  EVALUATED?  ................................ .............................  45 
 
ANNEX 1: PROCEDURAL INFORMATION  AND FOLL OW-UP OF COMMENTS FR OM THE REGULATORY SC RUTINY 
BOARD  ................................ ................................ ................................ ................................ ................................ .........  48 
ANNEX 2: STAKEHOLDER  CONSULTATION  ................................ ................................ ................................ ...................  83 
ANNEX 3: WHO IS AFFE CTED AND HOW?  ................................ ................................ ................................ ...................  95 
ANNEX 4: CAPACITY DE MAND GROWTH  ................................ ................................ ................................ .......................  98 
ANNEX 5: ENVIRONMENT AL IMPACT  ................................ ................................ ................................ ...........................  100 
 
 
 EN          2     EN   
Glossary  
Term or acronym  Meaning or definition  
CAPEX  Capital expenditures  
COMSATCOM  Commercial Satellite Communication  
EDA  European Defence Agency  
EEAS  European External Action Service  
ENISA  European Union Agency for Cybersecurity  
ESA  European Space Agency  
EUSPA  European Space Programme Agency  
GDP  Gross Domestic Product  
GEO  Geostationary Earth Orbit  
GOVSATCOM  Governmental Satellite Communication  
IoT Internet of things  
ITU International Telecommunication Union  
Latency  Amount of delay, measured in milliseconds (ms), that occurs in a round -trip data transmission to a satellite.   
LEO  Low Earth Orbit  
MEO  Medium Earth Orbit  
MILSATCOM  Military Satellite Communication  
M2M  Machine to Machine  
OPEX  Operational expenditures  
RR Radio Regulations (ITU)  
QKD  Quantum Key Distribution  
 
 
 
  
 
 EN          3     EN  1. INTRODUCTION : POLITICAL AND LEGAL C ONTEXT  
The culmination of a long political process  
Satellite communication s provide ubiquitous  coverage, which is complementary to terrestrial 
networks  (ground -based in a form of cable links such as fibre broadband or wireless). Satellite 
communication can provide the means for seamless digital communication in areas where terrestrial 
networks are a bsent (e.g. oceans, during flights), have been destroyed (e.g. during flooding events, or 
forest fires) or where local networks cannot be trusted (in crisis situations, or for diplomatic services 
in third countries).  
Governmental satellite communication i s conceived to bring a tangible contribution to the objectives 
for a strong, secure and resilient European Union. It is now an integral part of the Space Strategy for 
Europe1, the European Defence Action Plan2and the European Union Global Strategy.  Moreove r, the 
notion of governmental satellite communication with an EU dimension was first raised and welcomed 
in successive Councils  since 20133. 
The adoption of the Space Regulation on 28 April 2021 constituted a first step towards this resilience 
objective, through the establishment of a dedicated EU GOVSATCOM  component4.  
 
Yet, the international system evolves rapidly with geopolitcal shifts affe cting the EU more 
systemically. New ambitious actors, demonstrations of force by various means, regional conflicts, 
terrorism, cyber threats, growing migration pressures and destabilisation strategies featuring cyber 
warfare and disinformation create a mul tifaceted nexus of systemic challenges for the EU’s overall 
security status.  
 
Acknowledging the changing nature of the above challenges, the Strategic Compass  process5 has 
initiated a ‘ review of the Union’s civilian and military capability needs in light of the evolving  security 
situation and provide a coherent vision on the future military forces and civilian capacities’6. 
Governmental operations, and in particular security -related missions cannot be conducted without 
guaranteed access to satellite commun ication services7. A space -based secure communication 
shield across the EU that would protect our economy and society from various threats  becomes thus 
increasingly critical .  
 
This includes the need to develop future -proof cryptographic systems  that offer unprecedented 
levels of secure communications by resisting to future  quantum comp uting attacks . The European 
Quantum Communication Infrastructure (EuroQCI)8 initiative aims at  developing such a capability in 
the Union.  
                                                           
1 Space Strategy for Europe COM(2016) 705 final  
2 European Defence Action Plan COM(2016) 950 final  
3 Dec. 2013 EUCO ,    Dec. 2014 COMPET Space,   May 2015  FAC Defence   
4 EU GOVSATCOM in Regulation (EU) 2021/696 of the European Parliament  and of the Council of 28 April 2021 establishing the 
Union Space Programme and the European Union Agency for the Space Programme and repealing Regulations (EU) No 912/2010, 
(EU) No 1285/2013 and (EU) No 377/2014 and Decision No 541/2014/EU  
5 Towards a Strategic Compass - European External Action Service (europa.eu)  
6 Memo_ -_strategic_compass_ -_final.pdf (europa.eu)  
7 EU Institute for Security studies  (2021)  – Securing Heavens - How can space support t he EU’s Strategic Compass  
8 European Quantum Communication Infrastructure (EuroQCI) | Shaping Europe’s digital future (europa.eu)  
 
 EN          4     EN   
Moreover, the Commission Strategic Foresight report9 identifies digital hyper -connectivity and 
technological transformation as one of the prevalent megatrends of the next half century , 
underpinned by an unprecedented demand for services, for ex. in data economy and finance. Increa sed 
connectivity of objects, places and people will result in new products, services, business models, and 
life and work patterns. The number of connected devices globally might increase from 30.4 billion in 
2020 to 200 billion in 2030. At the same time, h yper- connectivity results in an increased risk of cyber -
attacks and network outages, in both digital and physical world, e.g. essential infrastructures like 
pipelines and energy grids. This will results in a much higher need for secure connectivity than 
expected even a few years ago10, especially for security actors.  
 
These technological advances lead global satcom connectivity to be increasingly handled as 
strategic asset.  To that end, several major government -backed projects with a variety of connectivity  
strategic objectives are underway.11 These strategic infrastructures initiated by all major space powers 
highlight the growing need for governmental services to ensure a resilient connectivity to support not 
only their security operations, but also to conn ect critical infrastructures, manage crises as well as to 
support  border and maritime surveillance.  Additionally, the social footprint of connectivity services 
for citizens  increases with technological advances: for instance, e -health and e -education in remote 
areas and smart mobility in urban centres are regular examples of use cases beyond strict governmental 
contexts.  
The global multifaceted changes and challenges prompte d the political acknowledgement of the need 
for space -borne secure connectivity in a series of high -level policy documents urging for action. In 
particular:  
 
 In March 2017 the Council Political and Security Committee endorsed the High Level Civil 
Military User Needs for Governmental Satellite Communications12, recognising that satellite 
communication plays an indispensable role in security and defence related governmental 
communication. In particular, satellite communication is used when other, ground -based,  
means of communication are not possible, reliable, or available. Satellite communication is an 
essential tool for a range of governmental missions and operations, especially in crisis 
situations or cases related to security and defence.  
 In March 2019 the European Council stressed that the EU needs to go further in developing a 
competitive, secure, inclusive and ethical digital economy with world -class connectivity13.  
 Due to the lack of terrestrial communication systems in the Arctic, the European Council 
conclusions of 21 November 2019 on ‘Space solutions for a sustainable Arctic’ space 
infrastructure is stressed for its ‘important role in guaranteeing reliable communication and 
high speed network connectivity’14. 
 The European Council conclusions of 1 -2 Oct ober 2020 call for strategic autonomy while 
preserving an open economy and new industrial alliances, including on secure 
telecommunication networks15.  
                                                           
9  Strategic_Foresight_Report_2021_en.pdf (europa.eu)  
10 Commission Staff Working Document Executive Summary Of The Impact Assessment GOVSATCOM, SWD/2018/328 fin al - 2018/0236 (COD)  
11  Such as the US Space Development Agency’s ‘Transport Layer’, a constellation of 300 to more than 500 satellites in LEO) rangin g from 750km to 
1200km in altitude, or the Russian Roscosmos ‘Sfera’, a constellation of 640 satellites at  an orbit of 870km.  
12   EEAS(2017) 359  
13  Conclusions of the European Council meeting (21 and 22 March 2019), EUCO 1/19  
14 Council Conclusions on Space sol utions for a sustainable Arctic, 21 November 2019 , 13996/19  
15  Conclusions of the special meeting of the European Council (1 and 2 October 2020), EUCO 13/20 ,  
 
 EN          5     EN   The secure connectivity initiative is mentioned as a mean ‘towards an innovative, resilient and 
competiti ve Union space sector to realise the opportunities of New Space’16 in the 
Competitiveness Council Conclusions on New Space for people  in May 202117.  
 In the same vein, t he European Council conclusions of  21-22 October 2021 stresse d ‘the 
importance of digital  connectivity, including through assessing the feasibility of further 
developing secured space based connectivity ’18. 
 The EU Space Programme is recognised as sharing the common goal of sustainable 
connectivity as the EU connectivity agenda in the European C ouncil conclusions of 12 July 
2021 on ‘A Globally Connected Europe’19. 
 Space -borne resilient communication capacity contributes to the European cyber shield, as 
proposed in the Commission cyber security strategy20.   
 The European Commission’s ‘Action Plan on  synergies between civil, defence and space 
industries’ o f 22 February 2021, states that it aims to ‘enable access to high -speed connectivity 
for everyone in Europe, and provide a resilient connectivity system allowing Europe to remain 
connected whatever h appens’21.   
 The 2021 Strategic Foresight Report22 identifies Digital hyperconnectivity as ‘driving the 
transformation. It results in an increased convergence of industries, products, technologies and 
services.’ It therefore sets the need for the EU to ‘ackn owledge the EU space infrastructure as 
strategic and maximise the benefits of new technologies, such as (…) or secure 
communications and Earth observation for secure connectivity.’  
 The Joint Communication on ‘The Global Gateway’23 announces that ‘The EU wil l work with 
partner countries to deploy digital networks and infrastructures such as submarine and 
terrestrial fibre -optic cables, space -based secure communication systems as well as cloud and 
data infrastructures  [...]’ 
In conclusion, improving safety, se curity and resilience  for its citizens, protecting European values and 
interests and ensuring technological non -dependence and industrial competitiveness becomes an 
urgent and complex task for the EU.  The Union has to charter its position within the increasingly 
competitive strategic environment by e nsuring Europe is prepared not only for the unprecedented 
challenges facing it right now but also to support its ambition to be a stronger and more autonomous 
power on the global scene.  
To that end, Presid ent von der Leyen, considering  the strategic importance of the in -built global 
sovereignty space systems offer, included the EU space -based secure communication system  in the 
State of the Union 2021 Letter of Intent under  the section A Europe fit for the d igital age24 - as a key 
initiative to be carried out in 2022.  
                                                           
16     New Space comprises start ups, mid caps and SMEs in the Space industrial ecosystem . 
17  New Space for People – Council Conclusions, 28 May 2021,  9163/21 ,  
18   Conclusions of the E uropean Council meeting (21 and 22 October 2021 ), EUCO  17/21  
19  A Globally Connected Europe - Council Conclusions July 2021  
20   JOIN(2020) 18 final  
21   Communication from the Commission to the European Parliament, the Europe an Council, the Council, the European Economic and Social 
Committee and the Committee of the Regions - Action Plan on synergies between civil, defence and space industries: 
https://ec.europa.eu/info/sites/default/files/action_plan_on_synergies_en_1.pdf  
22  Strategic_F oresight_ Report_2021_en.pdf (europa.eu)  
23 JOIN(2021) 30 final  
24 State of the Union 2021 letter of intent (europa.eu)  
 
 EN          6     EN  Governmental s atellite communications :  state of play  
Satcom present various degrees of security . There are globally operating private companies 
(Comsatcom25) and nationally -owned and –operated military satcom systems ( Milsatcom26). Each 
type of system is designed for its primary users, ranging from TV broadcasting for millions of global 
users (commercial satcom), to supporting specific military operations (military satcom). Whereas the 
latter add resses exclusive, highly niche use cases requiring a very high level of availability, security, 
and robustness, commercial satcom address a wider global market with less security features.  
The use of satcom by public authorities ( Govsatcom ) is a case in -between, requiring higher security 
standards than commercial satcom but less than military ones. Satcom is a strategic asset, closely 
linked to national security. Hence, public users tend to favour either government -owned or public -
private solutions27 or make use of specific accredited private providers. The close public -private link 
in the satcom sector is also apparent from the fact that most current privately -owned satcom operators 
were originally public entities (often intergovernmental, such as In marsat, Eutelsat, Intelsat) which 
were privatised in the 1990s.  Commercial providers’ role in Govsatcom type services is most often 
limited to public -private partnerships (PPP), and there is therefore no functioning, competitive market 
that could serve all  governmental users.  
Governmental satcom can provide crucial new capabilities  – guaranteed access to secure satellite 
communications for all security actors28 in the EU and in Member States29 and will enhance the 
effectiveness of civil protection and humanitarian interventions in the EU and globally. It relies on 
space -based communication systems because they are the only viable option in situations where 
ground -based systems are non -existent,  disrupted or unreliable. They are also indispensable in 
remote regions and in the high seas and the airspace hence offering resilience and redundancy.  
 
Governmental use cases have been developed  in close cooperation between the Member States, the 
Commiss ion, the EEAS, the European Defence Agency (EDA), and the European Space Agency 
(ESA)  by consulting Member States and EU Satcom end -user communities  and formalised in the High 
Level Civil Military User Needs for Governmental Satellite Communications docume nt30 
(HLUN)  and was endorsed by the Council's Political and Security Committee in March 2017 . They 
are grouped in the following three pillars:  (i) surveillance,  (ii) crisis management (including civil 
protection and humanitarian operations in natural or man -made disasters); (iii) connection and 
protection of key infrastructures.   
i. Surveillance.  
This includes land and maritime surveillance, border surveillance, the fight against illegal activities, 
and the monitoring for potential environment disasters (oil spills, forest fires). Surveillance 
                                                           
25 COMercial SATellite COMmunications  
26 MILitary SATellite COMmunications  
27 Such as Germany’s Satcom BW or Luxemburg’s GovSat  
28The term 'security actor' is also used in A Global Strategy for the European Union’s Foreign and Security Policy (2016) and d efined 
as both private and public actors which act in the inter est of public safety and security, in both civil and military domains.  
29 National police -, defence - and border protection forces and the maritime communities;  the civil and military Common Security and 
Defence Policy (CSDP) missions; EEAS and Commission, FRONTEX, EMSA, the Emergency Response Coordination Centre 
(ERCC)  
30 EEAS(2017) 359 , High Level Civil Military User Needs for Govern mental Satellite Communications  (HLUN)  
 
 EN          7     EN  operations typically need various manned or un -manned connected platforms (ships, airplanes, 
satellites, drones) for ‘intelligence, surveillance, re connaissance’ missions (ISR). Civil and military 
actors may be involved at national and EU level. Secure satcom will play a major role in the 
provision of maritime surveillance services, as a central part of the EU coast -guard functions 
characteri sed by cooperation among three EU agencies ( European Maritime Safety Agency , 
FRONTEX and European Fisheries Control Agency ). Secure satcom will in particular enable 
enhancements to current services such as monitoring for potential environment disasters, or  
commun ication with the Remotely Piloted Airborne Systems (RPAS) beyond radio line of sight.  
 
ii. Crisis management, including civil protection and humanitarian operations in natural 
or man -made disasters  
Multiple actors collaborate at the local, regional, national, or international level and across civil -
military boundaries. The EU's military and civilian CSDP missions and operations alone currently 
occur in around 15 theatres, involving some 6  000 deployed EU staff. The response to disasters is 
coordinated at EU lev el in the EU Civil Protection Mechanism, which currently includes the 
Emergency Response Coordination Centre (ERCC) of the European Commission. Here, too, secure 
satcom is a critical enabler for successful operations.  
 
iii.  Key infrastructures.  
This includes a  wide range of national infrastructures, such as  nuclear power plants and energy 
systems (e.g. command and control of smart grids), dykes and dams, and essential transport systems 
(e.g. airports, major tunnels or bridges), as well as EU infrastructures suc h as Galileo and 
Copernicus. While all major infrastructures require communications, only a subset need secure 
communications and cannot use ground infrastructure. For example, remote operational sites of 
Galileo currently use commercial satellite communic ations. Transport infrastructures are usually 
managed and controlled by public and/or private actors, and some safety -related aspects are 
managed by governmental entities. Almost all security - or safety -critical applications could benefit 
from EU Govsatcom  capacities, either as primary or backup solutions.  
 
 
At EU level, apart from national Govsatcom systems, the EU GOVSATCOM component  under the 
EU Space programme  has been established . Its aim is to optimise the use of existing satcom  capacity  
for governmental users on the basis of pooling and sharing of available national and private EU satcom 
resources. Due to the limited lifespan of a satellite (approximately 15 years for GEO satellites) several 
of the governmentally owned infrastructures th at will constitute part of the pooling and sharing of 
GOVSATCOM will need to be replenished  in the coming decade31.  
For this reason EU GOVSATCOM foresaw:  
- Phase 1 , from today until approximately 2024, during which the demand will be aggregated 
across EU an d Member States , and across civil and military boundaries. The EU 
GOVSATCOM capacity will be procured (via service level agreements) from Member States 
with national systems and spare capacity, and from accredited commercial European satcom 
and Service pro viders . 
                                                           
31 PwC (2016) 'Satellite Communication to support EU Security Policies and Infrastructures'  
 
 EN          8     EN  - From 2024 onwards, when many of the existing national assets will reach their end of 
operational life and where the need for additional bespoke capacities could be envisaged, the 
legislator has urged the Commission to continuously assess the evolution of satcom needs with 
regard to supply and requires ‘taking into account new risks and threats, as well as new 
developments in technology’. Should this evaluation ‘reveals that this approach is insufficient 
to cover the evolving demand, it sho uld be possible to take a decision to move to a second 
phase  and develop additional bespoke space infrastructure or capacities through one or several 
public -private partnerships, e.g. with Union satellite operators.’ 32  
 
► Satcom have become a critical component on which several governmental operations 
and critical infrastructures heavily rely. A guaranteed access to secure satcom 
resources has therefore been initiated at EU level to reinforce the resilience of these 
operations . 
 
2. PROBLEM DEFINITION  
 The core problem  
Both governmental user needs and the satcom  solutions are changing rapidly. Under the increasing 
threat levels and increasing importance of real time needs, in particular for Machine to Machine (M 2M) 
and I nternet of Things (IoT) , user needs ar e moving towards higher security solutions, low latency33 
and global coverage .  However, the current EU Satcom assets cannot meet th ese new needs .  
The core problem for this initiative is therefore:  
‘There is a growing mismatch between governmental  needs for secure , reliable and diverse satcom 
services, and available EU and Member State satcom solutions.’  
The core problem can be described by the below problem tree, based on an analysis of the risks and 
problems identified in stakeholder inputs34 and an analysis of the evolution of the threat and 
geopolitical environment.  
                                                           
32 Regulation (EU) 2021/696 of the European Parliament and of the Council of 28 April 2021 establishing the Union Space 
Programme and the European Union Agency for the Space Programme and repealing Regulations (EU) No 912/2010, (EU) No 
1285/2013 and (EU) No 377/2014 and Decision No 541/2014/EU , recital 104  
33  Latency: amount of delay, measured in milliseconds (ms), that occurs in a round -trip data transmission to a satellite.   
34 From HLUN, consortium and ENTRUSTED study . A classified note summarises these needs.  
 
 EN          9     EN     
   
Figure 1: Problem tree  
 
 Problem  drivers  
2.2.1.  Threat level increases and it is changing in nature  
As clearly documented in a range of EU policy documents  (see section 4.3), the threat level against 
EU Member States and institutions is increasing, and changing in nature , leading to increased risk s to 
citizens, governments , EU institutions  and their interests .  
Hybrid threats: The 2016 joint  Communication on  a ‘Joint Framework on countering hybrid threats ’35 
has described how t hreats have become more 'hybrid', and are taking increasingly non -conventional 
forms as state - and non -state actors perform a range of hostile and subversive activities below the 
threshold of traditional warfare. The 2020 joint staff working document repor ting on the 
implementation of this framework36 has highlighted that h ybrid threats are growing in frequency and 
impact and increasingly  blur the strict distinction between civilian and security actions and responses. 
These new forms of attacks set new requi rements for the level of preparedness of Member States and 
the EU in order to be resilient. The staff working document identifies, among other capabilities, Satcom 
as ‘the area where space solutions deliver cross -cutting capability in countering hybrid thr eats’ with 
                                                           
35  JOIN/2016/018 final  
36 COM_SWD(2020)0153  

 
 EN          10     EN  secured Satcom  as an enabler of ‘support (to) security critical missions, with the ability to exchange 
sensitive information worldwide in a hybrid threats environment ’37.   
Cyber threats: The joint Communication on ‘ EU's Cybersecurity Strategy for the Digital Decade ’38 
has reminded to which extent Cybersecurity  had become an  ‘essential part of Europeans’ security. 
Whether it is connected devices, electricity grids, or banks, aircraft, public administrations or hospitals 
they use or frequent, people deserve to do so within the assurance that they will be shielded from cyber 
threats. ’ The EU’s economy, democracy and society depend more than ever on secure and reliable 
digital tools and connectivity. Cybersecurity is therefore essential for build ing a resilient, green and 
digital Europe . With expanding digitalisation comes also increased security risk. More advanced 
cybersecurity responses have therefore become a matter of urgency.  
During the pandemic the amount of cyberattacks has increased, with  ‘some affecting critical 
infrastructure essential to managing th e crisis ’39.  In 2019 European critical infrastructure s were hit by 
almost 450 cybersecurity incidents.  The annual cost of cybercrime to the global economy in 2020 is 
estimated to be €5.5 trillion40. 
Technologies by ill -intentioned actors are evolving fast . As the threat landscape is changing, so is 
the technology behind the attacks. Satcom security -related features are therefore an important area of 
technology evolution: anti -jamming and ot her security -related features, secure hosted payloads, optical 
communications, Quantum technologies including Quantum Key Distribution, Highly Elliptic, Low 
Earth Orbit small satellites (mega -) constellations allowing better infrastructure resilience -frequency 
user equipment, and integration with ground -based communication systems (5G).Without resilient 
and innovative technology  the EU risks becoming increasingly vulnerable to ill -intentioned actors.    
The rise of quantum computers  adds an additional threat to the list. With their fundamentally 
improved capabilities, it is expected that quantum computers will be able to decrypt content that is 
currently encrypted. The threat is therefore already present due to the ‘harvest now, decr ypt later’ 
principle. This means that data which are sent today, can be stored and decrypted when a sufficiently 
powerful quantum computer becomes available, which may be the case 15 -20 years from now41. 
Therefore, sensitive data which need to be protected for more than 15 years are already at risk today 
when sent with currently accepted encryption techniques. Without any countermeasures, the problem 
will become larger and larger. In an increasingly interconnected world, vulnerabilities are not only 
related to critical infrastructure directly, but also for non -critical digital infrastructures that can pose a 
structural risk when exploited systematically42. 
Increase of natural disasters : Climate change is driving an increase  in natural hazards  and disasters , 
such as storms, floods, and wildfires43. Over the last 50 years, the number of recorded disasters has 
                                                           
37 Idem  
38  JOIN(2020) 18 Final  
39 Declaration by the HRVP, on behalf of the EU, on malicious cyber activities exploiting the coronavirus pa ndemic  
40  JRC (2020) , Cybersecurity – Our Digital Anchor  quoted in  JOIN(2020) 18 Final  
41  McKinsey (202 0) A game plan for quantum computing  
42 Rethinking strategic autonomy in the d igital age - Publications Office of the EU (europa.eu)  
43 https://www.eea.europa.eu/publications/europes -changing -climate -hazards -1/climate -hazards -indices  
 
 EN          11     EN  increased from an average of occurring every 30 days in the 1970s to every seven days the last three 
decades44. Many such natural disasters  lead to the brea kdown of terrestrial communication networks, 
with severe, and sometimes deadly consequences for those affected by  the disaster in the first place.  
Prime examples are the recent  flood s in Belgium and Germany , where terrestrial communication 
networks were down , and fires in Greece and Spain in summer 2021.    
  
Figure 2: Number of reported natural disasters in Europe, 1950 -2020 45 
 
► The increasing hybrid and cyber threat levels and propensity of natural disasters drive 
the changing needs of governmental actors towards higher security, reliability and 
availability of commensurate satcom solutions . 
 
2.2.2.   Evolving nature of secure governmental satcom needs  
Traditionally, satcom has been used for voice communication  and data transfer  in remote areas (e.g. at 
sea), but the nature of use cases is rapidly evolving, driven by both technological developments and 
geopolitical shifts.   
The use cases  below are taken from the ENTRUSTED study46, where they were identified by Member 
States’ experts as the most prominent examples of the evolving Govsatcom demand . 
Machine to Machine ( M2M) and Internet of Things (IoT ): there is a  rapidly growing  need for 
capabilities that can support the connectivity that underlies M2M and IoT applications , which is 
                                                           
44 WMO atlas of mortality and economic losses from weather, climate and water extremes (1970 –2019), page 40  
45 EMDAT (2020): OFDA/CRED International Disaster D atabase, Université catholique de Louvain – Belgium ( (emdat.be)  
46 A network of Users for governmental Satellite Communications  (including Member States and EU agencies) under the 
‘European Networking for satellite Telecommunication Roadmap for the governmental Users requiring Secure, 
inTeroperable, innovativE and standardiseD services ’ (ENTRUSTED) study. Detailed outputs are classified.   

 
 EN          12     EN  expected to use both space and terrestrial infrastructure .  M2M and IoT provides connection between 
one or more application s that communicate with each other in order to monitor and control themselves 
independently and autonomously. Governmental use -cases of IoT  frequently require autonomous and 
secure satellite communications  solutions. For example IoT systems related to major  water dam 
protection, or systems related to critical infrastructures . The global trends show  an increased usage of 
secure M2M for event detection and alerting via deployed sensors in relation to for example border 
protection47.  
Typical ly M2M  and IoT  communications  require  low data rate s and especially low latency , whereas 
existing communication infrastructures are usually designed to transmit high bandwidth , but with high 
latency . This new mix of needs has b een confirmed by governmental stakeholders .48 
Move towards autonomous transportation: in addition, stakeholders of the HLUN  identified the use 
of Remote Piloted Aircraft Systems (RPAS)  as a technology that is expected to play a significant 
role.  
The user community for RPAS is very diverse, covering  needs in border surveillance, maritime 
community, law enforcement missions, civil protection, humanitarian aid, EU external action, 
Transportation and space Infrastructure49. The replacement of piloted aircraft with RPA S will create 
cost-saving and efficie ncy gains for the operations. However, in order to succeed, they require a 
robust, continuous communication link to command the RPA S and retrieve the data from 
sensors. For long -range RPAS this can only be provided by secure satcom .  
A study by the Single European Sky ATM Research  (SESAR) Joint Undertaking  underline  that the 
governmental assets are expected to dramatically increase (See figure 3 below)50.   
 
                                                           
47 ESSCS, D110, page 27  
48 Further details on use -needs are recapped in a classif ied note.  
49 PwC (2017) Study in support of the Impact Assessment of an EU GOVSATCOM initiative page 213  
50 A study by the Single European Sky ATM Research (SESAR) Joint Undertaking, projected in their 2016 Drones O  

 
 EN          13     EN  Figure 3: Total fleet size (Current through 2050) (Source SESAR)  
 
Automation will also enable other means of transportation to become driverless: Remote piloted 
vessels  are expected to emerge between 2025 and 2030, and will generate a growing demand for 
moderate throughput, highly resilient and highly secure satellite co nnectivity services51. Secure 
satcom is the only option to provide these remotely piloted vessels with communication and 
connectivity systems due to its potential for global coverage.  The land -based transportation models, 
such as autonomous vehicles and tra ins will also be relying on terrestrial communication, but secure 
satcom will play an important role as back -up systems in order to create resilience.  
The cumulative combination of technological developments with the identified use -cases testify to a 
significant evolution of EU secure satcom needs.  
 
  Polar Regions  RPAS  M2M 
communication 
and IoT  
Surveillance  Border surveillance and control     
Maritime surveillance and control     
Crisis 
Management  Maritime emergencies     
Humanitarian aid     
Civil protection     
Law enforcement interventions     
EU external action     
Forces deployment     
Key 
infrastructures  Transport infrastructures     
Space infrastructure     
Institutional communications     
Other key infrastructures     
Table  1: Fields of application and specific use cases of evolving Govsatcom services (source: 
ENTRUSTED ) 
 
Increased global coverage needs:  With proliferating global tensions and fiercer strategic competition, 
the frequency and level at which the EU and its Member States are called upon to act in a global setting 
are increasing. This may be in multilateral, EU, regional, or national frameworks and may be in the 
civil or defence, and increasing in mixed civil and  defence settings. All these missions and operations 
rely on satellite communications services, either from private entities, from national systems, or from 
partner systems such as the US W ideband Global Satcom (WGS) . Crisis management mission and 
operatio ns are likely to take place anywhere in the world, but with a priority for neighbouring 
areas of Europe52 (Africa, Mediterranean, Middle East Asia, Arctic, Atlantic). This is all the more 
                                                           
51 ESSCS, D110, page 41  
52 EEAS(2017) 359  
 
 EN          14     EN  important because our strategic partners are reconsidering their prio rities, and require a 
suitable level of preparedness and capabilities from their EU partner . 
► In all, the governmental satcom needs evolve towards low latency and more global 
coverage.   
2.2.3.   Current EU satcom assets do not allow to  meet these evolving needs  
Initially, satcom has been relying on geosynchronous (GEO) spacecraft. Technical progress53 has 
allowed the emergence of non -geosynchronous -orbit (NGSO) communications constellations, 
comprising low -Earth -orbit (LEO) and medium -Earth -orbit (MEO) satellites to emerge and gradually 
offer connectivity services comparable in performance to terrestrial infrastructures in terms of latency54 
and bandwidth.  
 
Figure 4: Comparison of GEO, MEO and LEO performances  
There is not today any EU LEO and MEO operational or project capabilities that could meet the 
evolving governmental user needs. Figure below  illustrates  this gap . The current and committed 
Satcom capacities providing governmental services at the disposal of the Member States, are all based 
on a reduced number of GEO assets, covering mainly Europe. The majority of the capacity is dedicated 
to military missions, with a strong governance control (from owned infrastructure  to stringent public 
private partnership) . Moreover, due to certain military requirements these Milsatcom capabilities are  
unsuitable for Govsatcom applications .  
Additional LEO and MEO assets  would fil l several  capacity gaps for governmental users since:  
1. The lower altitude of these new LEO /MEO  satellites compared  to GEO reduces the latency 
making it suitable for demanding applications such as : beyond line -of-sight communication 
and collaborative operations  (for instance  Frontex activities that involve multiple  entities on 
several air, land and naval platforms) , drones, telesurgery, et c. 
                                                           
53 Through the use  of non -geosynchronous -orbit (NGSO) communications constellations, including low -Earth -orbit (LEO) and medium -Earth -orbit 
(MEO) satellites  
54  Latency: a mount of delay, measured in milliseconds (ms), that occurs in a round -trip data transmission to a satell ite.  

 
 EN          15     EN  2. Its orbits  would allow to cover  high latitude s (Arctic and Antarctic regions)  as well as the  Indo-
Pacific region  where no governmental service is currently available . 
3. The resilience of the service is higher thanks to the large number of small interconnected LEO  
satellites , compared to a limited number of GEO  satellites  where each failure would disrupt 
service provision . 
 
  
Figure 5:  Civilian and defence users of the different tiers of satellite communications (Commercial, 
Governmental and Military) at GEO, MEO, and LEO.  
Figure above  exemplifies the absence of EU solutions in this MEO/LEO higher security -critical area  
compounded where third -countries flag a considerable investment effort.   
► The absence of EU solutions  in higher security -critical areas is compounded by an 
absence in the technology -edge Low Earth orbit - where third -countries flag have a 
considerable presenc e. Therefore the available satcom resources of EU GOVSATCOM 
need to be complemented with new capabilities meeting these increased and evolving 
needs.  
 
 Who is affected, in what ways and to what extent?  
Those primarily affected by the identified problem are the EU and EU Member States' 
governmental actors. By extension, the mismatch will also affect, directly or indirectly, the 
security and safety of all EU citizens.  
The aggregation of factors such as cyber and hybrid th reats, ill -intentioned use of technologies, and 
the evolving nature of secure satcom needs requiring a global outreach and low latency affects EU 
Member States which are confronted with  a decreased level of resilience of their secured 

 
 EN          16     EN  communication infrastructure, leading to  limitations in their missions and operations , or in some 
cases may need to refrain from activities  that they would undertake if sufficient and adequate secure 
satcom  services would be available to them. Such limitations impair directly the capacity of the EU 
and its M ember States to act autonomously to protect their interests. Such impairment does, in turn, 
curtail sovereignty, increases technological dependence and w eakens competitiveness. On a wider 
scale, this problem could affect the credibility of the EU as a security actor  on the global stage.  
EU citizens  have become acutely aware of the importance of secure and reliable communication 
during crisis situations, and the effect of the absence of such systems for security actors who protect 
them. Although they may not always be aware of the lack of suitable sa tcom solutions, the effects will 
be felt as a general lack of communication in crisis situations (due to outage of ground based systems), 
and the inability of civil and security actors to deal rapidly and effectively with the situation (e.g. 
without means of communication it can be very difficult to quickly assess the damage in a disaster area 
and the deployment, operation and coordination of first intervention teams, critical for saving lives). 
The withdrawal of EU M ember State actors in Kabul revealed cha llenges to the EUs ability to rescue 
and evacuate its citizens beyond its borders; the catastrophic floods in Germany and Belgium in July 
2021, and the forest fires in Greece in summer 2021 demonstrated the acute need for reliable and robust 
communication means. The general conclusion is that when governmental actors do not have access 
to the right tools to carry out their complex mission, citizens suffer from the consequences . 
 How will the problem evolve?  
The problem will evolve both on the demand side and  on the supply side . As shown above , the 
demand is expected to increase and is expected to become more differentiated.  
On the supply side the provision of satcom services is a complex interplay between national decisions 
for governmental  systems, and deci sions of private companies regarding new investments in satcom 
commercial systems. Since the Govsatcom market segment is relatively small  (compared to the needs 
of the private sector) , and none of the EU M ember States has sufficient market power to leverage fully 
private solutions, it is unlikely that future EU and M ember States Govsatcom needs will be 
spontaneously met by EU private actors : Cost modelling analyses performed by ASD Eurospace55 
highlight that the magnitu de of the investment would require a commitment of the public sector to 
alleviate the risk.   Industrial stakeholders have also confirmed this assessment of the market.56 
Although some EU Member States have national satcom systems, none of the EU M ember States is 
planning to develop a global low latency system in the coming decade . As a consequence, as shown in 
the figure below,  the EU will see a market decline in the number of communication satellites per region 
compared to the rest of the world.  
                                                           
55 Trade association of the European Space Industry  (ASD document available here). Annex 3 – Stakeholders consultation further 
expands the rationale  
56 It is worth highlighting that the lack of a ‘technology push’ offer from Industry does not constitute a market failure, but rather a 
logical outcome for such a product that (i) requires several hundred -millions upfront non -recurring cost and (ii) that wou ld not be 
marketable for B2C commercial applications.  
 
 EN          17     EN   
Figu re 6: Communication Satellites to be Built and Launched, 2020 -2029, Euroconsult study  
This decline, both in number of satellites and relative bandwidth share is driven by the launch of 
currently planned US Low Earth Orbit mega constellations able to provide low latency services. 
Individual systems may be renewed, and may partly be used in t he EU GOVSATCOM pooling and 
sharing scheme, but this is unlikely to cover the additional, evolving satcom needs. Technological 
advances mean that a low latency global satcom constellation is now within the technical possibilities, 
whereas this was not yet the case a few years ago. This will further strain an already scarce access to 
frequencies.  
 
 
Figure 7: Forecast of Satcom mega -constellations, 2010 -202957 
 
Risks of reduced access to frequencies and orbital slots  
The portfolio of EU -available frequency filings that would allow to establish a LEO infrastructure is 
facing strong attrition  over time. Wireless data communication most commonly uses radio frequency 
(RF) transmission of electromagnetic waves through space  and the atmosphere. However, the laws of 
physics makes only a certain portion of this ‘radio spectrum ’ feasible for use by satellites, due to 
atmospheric and propagation signal losses. This usable range is in turn further restricted by competing 
                                                           
57 Source: Satellites to be Built and Launched, 2020 -2029, Euroconsult (2020)  

 
 EN          18     EN  demand fr om other radio uses, such as terrestrial mobile phone systems, and is ultimately limited by 
the international Radio Regulations, a n international  treaty based regulation that allocates what 
frequencies can be used for what purpose.  
A well as defining frequ ency allocation, the Radio Regulations, written by nation parties to  the 
International Telecommunication Union (ITU), define a set of rules and procedures that must be 
followed before any satellite system can use frequencies in space.   This is based on a f irst-come, first 
served principle, which determines a regulatory priority when new systems apply to use the same 
frequencies.   Late comers are required to observe this priority, especially during the international 
coordination process. The priority system means that the holders of later ‘junior’ filings need to 
negotiate access to the spectrum with everyone in front of them, without assurance of access.  Filings 
must be brought to use in a limited timeframe: the maximum time span between the initiation of th e 
filing process and the actual operation of the satellite amount to seven years  
In recent years, due to a general increase in the use of space and the huge growth in mobile phone use 
and online  videos, the demand for radio spectrum has increased almost exponentially, driven both by 
the requirements of new technologies and market players as well as demand from the mass market. As 
a result, radio spectrum auctions have realised billions of dollars for governments around the globe.    
 
Figure 8: non GSO filings as of 15 Dec 2021 (source: ITU)  
While there are today senior filings that can be used to serve EU governmental needs, a failure to bring 
them into use in the coming years would deprive the Union of a unique window of opportunity58. 
► Without timely bringing -into-use of available EU filing for relevant radio frequencies, the 
EU risks its ability to secure future satcom capabilities that can meet governmental needs.  
 
                                                           
58 Details on current filings under consideration are recapped in a classified note.  

 
 EN          19     EN  3. WHY SHOULD THE EU ACT? 
3.1. Legal basis  
The initiative will be based on Article 189 TFEU, which provides the legal basis for the EU to act in 
space policy matters, and provides the legal basis to establish EU space programmes:  
1. To promote scientific and technical progress, industrial competitiveness and the 
implementation of its policies, the Union shall draw up a European space policy. To this 
end, it may promote joint initiatives, support research and technological development and 
coordinate the efforts needed fo r the exploration and exploitation of space.  
2. To contribute to attaining the objectives referred to in paragraph 1, the European 
Parliament and the Council, acting in accordance with the ordinary legislative procedure, 
shall establish the necessary measures , which may take the form of a European space 
programme, excluding any harmonisation of the laws and regulations of the Member 
States.  
The initiative aims to establish a civil system under civil control. The use cases will be civil and some 
will have  secur ity implications  59.  
3.2. Subsidiarity  
According to Article 4 TFEU, Article 189 is a shared competence. EU actions falling outside exclusive 
competence have to be assessed in the light of the subsidiarity principle set out in Article 5(3) TEU. 
Hence, it must be analysed whether the objectives of the proposal could not be achieved by the Member 
States in the framework of their national legal systems or whether, by reason of its scale and effects, 
they are better achieved at EU level.  
3.2.1.  The objecti ves of the propo sed initiative cannot be sufficiently achieved by the 
Member States  
As described under Chapter 2.2., the dimension of the evolving needs has a global element and will 
therefore have to be addressed at EU level. Due to the European and even global scale of  the problems, 
there is no possibility to address the issue at the regional or local level.  
A new initiative would build upon EU GOVSATCOM existing pooling and sharing arrangement , but 
no EU Member State alone has the capacity to fulfil the totality of evo lving user needs globally and 
the related costs. Moreover, the provision of governmental communication is sensitive and requires a 
level of resilience and trust among the stakeholders which is difficult to achieve by any EU Member 
State acting alone.  
An EU  solution provides added value because action and coordination at EU level would avoid 
duplication of efforts across the Union and Member States, and would increase synergies between 
                                                           
59 The initiative does not aim at acquirin g Milsatcom capabilities. Furthermore, t he space enabled services  expenditure for military operations will not 
be part of thi s initiative, h ence Article 41( 2) TEU is not appl icable . 
 
 EN          20     EN  civil, space and defence. It would lead to a better exploitation of existing assets, to greater security and 
resilience, notably through quantum cryptography, to better coverage, and to provision of a greater 
array of services. Other EU and M ember State thematic policies would benefit, too.  
3.2.2.  The objectives of the proposed a ction, by reason of its scale and effects, can be 
better achieved at EU level  
On the basis of the findings in previous sections, there are clear benefits from  EU-level action in terms  
of economies of scale, whereby a coordinated action would remove duplic ation of efforts across the 
Member States. The individual user needs across Member States are generally heterogeneous and often 
unpredictable in terms of scope, capacity, timing and location. Common for all use cases is the need 
for flexibility due to the often unpredictable need for satcom capacity. Acquiring such flexibility of 
access to capacity requires large investments, both for the provision of national capacity and for the 
provision of commercial solutions, where tailor made contractual solutions en suring assured access to 
capacity currently serves the largest global customers only.   
The establishment of an EU -level governance that can leverage secure and edge satcom services for 
all national and EU security actors would contribute to a more effective and autonomous EU response 
to risks and threats, ranging from cyber -attacks and hybrid threats, and natural disasters to evolving 
secure governmental satcom use cases and increasing global needs. Therefore, by reason of 
effectiveness and efficien cy, the establishment of such system can only be achieved at the EU level.  
The EU satcom industry would benefit from the long -term commitment and EU -level security 
accreditation. With the EU as a long -term anchor customer for governmental services the satcom 
industry business case is strengthened and de -risked for them to have better access to finance and 
ultimately be more competitive.  
Last, but certainly not least, European citizens would benefit directly and indirectly from the enhanced 
operational effectiveness of the various security actors.  
  
 
 EN          21     EN   
4. OBJECTIVES : WHAT IS TO BE ACHIEVE D? 
  
Figure 9: Overview of problems and objectives articulation  
 
4.1. General objective  
The general objective is  to increase  provision of resilient , global, guaranteed and flexible  satcom 
solutions built on an EU technological  and industrial base . 
 
4.2. Specific objectives  
To meet the above general objective, the following specific objectives should be achieved : 
 Ensure the provision of secure satcom for evolving public needs ; 
 Increase the resilience of M ember States and EU operations by guaranteed access  to satcom ; 
 Ensure that governmental communication  needs are not critically dependent on non -EU 
infrastructure  
 
 
4.3. Consistency with other policies and objectives  
This initiative contributes in a cross -cutting manner to a range of headline political ambitions of the 
Union . By providing secure digital connectivity to public actors in situations where land –based 
connections are absent (remote areas, seas),  partially or fully  destroyed (disaster areas), or cannot be 
trusted (conflict areas), this initiative is closely linked to : 
 The EU space policy and in particular the EU Space Programme, in which the EU 
GOVSATCOM component can be regarded as precursor for this initiative. At space 
infrastructure level, this initiative may also create operational synergies with existing Space 
Programme components such as Galileo or Copernicus.  

 
 EN          22     EN   Digital policies , such as the  2030 Digital Compass: the European way for the Digital 
Decade60, which highlights the need for a mix of technologies to provide connectivity, 
including space connectivity, and The EU's Cybersecurity Strategy for the Digital Decade61, 
highlighting the increased security risks associated with connected networks, and the need to 
mitigate such risks at EU level by technological sovereignty in critical technologies and 
systems.  
 The EU Security Union Strategy62, highlighting the need for an integrated EU resp onse, 
helping EU security actors with the tools and information they need. Secure satellite 
communication is a recogni sed essential tool for the wide array of security actors, including 
border management, law enforcement, crisis management (e.g. terrorist attacks), civil 
protection, fire fighters, fisheries control, and maritime security.  
 EU policies relating to global leadership . Those  have seen a strong evolution in the last years, 
in sync with the rapidly changing geopolitical landscape , US leadership and global strategic 
positioning, and rapidly evolving threats to complex hybrid patterns, in which even migration 
can be weaponized. The Global Strategy for the European Union’s Foreign and Security 
Policy  started the process in 2016, with  and important policy on countering hybrid threats 
in 201863, referring to satellite communications as key assets for a range of security aspects. 
The current reflections with Member States revolve around the Strategic Compass for 
security and defence , whic h is based on a common risk and threat analysis. The text under 
discussion highlights that the threats  we face are intensifying and that the capacity of 
individual Member States to cope with such threats is insufficient and declining. At the same 
time wide r geopolitical trends (e.g. US priorities in Asia Pacific) call for the EU to undertake 
a greater share of responsibility for its own security and that of the world.   
 Research,  development and innovation  policies , including Horizon Europe, and InvestEU, 
are all crucial to ensure that the EU has the technological and industrial base necessary to avoid 
strategic dependencies which limit the EU and M ember State’ freedom of action, as 
highlighted in the 2021 update of the New Industrial Strategy64. They w ould support the 
initiative by contributing to the development of  innovative solutions to the service demand.   
 Transport policies , such as  the Sustainable and Smart Mobility Strategy65 where satellite 
services are identified as an enabler for Cooperative, Connected and Automated M obility . 
 EU policies relating to connecting strategic areas , such as the Joint Communication on  A 
peaceful, sustainable and prosperous Arctic66, where the space -based secure connectivity 
initiative is mentioned as a way to provide essential connectivity services in a region with 
limited terrestrial connectivity infrastructure and in Towards a comprehensive Strategy with 
                                                           
60 COM(2021) 118 final  
61 JOIN(2020) 18 final   
62 COM(2020) 605 final  
63 JOIN(2016) 18 final  
64 COM(2021) 350 final  
65 COM (2020) 789 Final  
66 JOIN(2 021) 27 final  
 
 EN          23     EN  Africa67, where the EU declar ed its intention to establish a partnership to boost the continent’s 
digital transformation.   
 Global gateway68, the EU plan for major investments in infrastructure development around 
the world. Space based communication systems are global infrastructures by definition, and 
thereby, as indicated in the joint communication, offer opportunities for cooperation with 
partner countries  and regions , such as Africa .     
5. WHAT ARE THE AVAILABL E POLICY OPTIONS ? 
5.1. Definition of options  
The satcom market differs signifi cantly from other space segments where the EU has already 
established components of its Space Programme , such as Earth Observation under Copernicus and 
Navigation Services under Galileo . Each of these specificities impacts the way options have to be 
considered to address the growing mismatch between public  needs for secure satcom and available EU 
and Member State satcom solutions.  
European satcom was the first space commercial market to  emerge in the 1970’s. It constitutes a 
functioning market generating EUR 102  billion revenues in 2019. Services are mature and follow 
defined commercial, governmental and military standards. There is effective competition among 
established and new players , including several European companies . 
The intervention logic should therefore follow a service -based approach.  The options to consider 
to close the gap in the provision of required services do not necessarily have to go through the 
establishment of a brand -new EU-owned infrastructure, as it was the case for Galileo , and, to a lesser 
extent, for Copernicus. This is in particular reflected in the way the EU GOVSATCOM under its 
current Phase 1   has sought the optimisation  of existing European capacity.  
The first question when considering the options is therefore :  
i. to assess whether the public or  private sector can provide these secure accredited services , 
with the EU and Member States purchasing such services : 
a. from the marketplace in the EU ( Baseline ) or  
b. from foreign market providers  (Option 3).  
ii. or to provide the required services, the EU will need to act to ensure the provision of these 
services by either   
a. fully funding and procuring  its own  system  (Option 1  – Fully Public ) or  
b. establishing a public - private partnership (in the form of a concession)  (Option 2: 
Public -private -partnership: EU Concession ). 
                                                           
67 Join (2020) 4 Final  
68 JOIN(2021) 30 final  
 
 EN          24     EN  5.2. Option 0: Baseline  
Under the baseline scenario, no EU action would take place beyond what is currently being 
implemented through EU GOVSATCOM.  
EU GOVSATCOM is already a component of the EU Space Programme69. The objective of this 
component  is to pool the existing national satellite communication capacities and private capacities 
across the EU and to share them on the specific use -case basis amongst the EU Member States and 
specific EU entities, such as the EU Agencies, EEAS, or ESA.  
The ba seline is taken to mean the continuation of the  EU GOVSATCOM Phase 1, i.e. limited to current 
pooling and sharing of Member State and private satcom systems. In such a scenario individual 
Member States, or EU companies70 may decide to develop new satcom sat ellites, the partial capacity 
of which is sold to the EU GOVSATCOM pool. Transition to EU GOVSATCOM phase 2 in the 
initially planned timeframe  would still require a legislative act,  additional budget  and available 
frequency filings in the 2026 -2030 timeframe  (see chapter 2.4). 
Services : The services are only governmental and provided through service contracts with EU and 
Member States. A continuation of EU GOVSATCOM pooling and sharing alone, would provide only 
existing services portfolio , without offering the  low latency services and global secure satcom71.  
Ownership: Assets  providing capacity  in this option are  owned by  Member States a nd private 
operators, whereas the EU owns  the GOVSATCOM hub  which is the coordination platform that 
connects users and providers of satcom capacities and services.  
Governance : The Commission is the Programme manager of  EU GOVSATCOM  and has entrusted 
European Space Programme Agency (EUSPA ) for the procurement and the operation of the 
GOVSATCOM hub.  
Security: EU GOVSATCOM is subject to the security provisions  of the Space Regulation including 
the Council Decision (CFSP) 2021/698 . Quantum -based and enhanced space systems and services are 
currently not a component of the EU Space Programme. In the baseline scenario, activities regarding 
a European Quantum communications infrastructure would continue under the EuroQCI initiative, 
independently from the EU GOVSATCOM component.    
                                                           
69  Regulation (EU) 2021/696 of the European  Parliament and of the Council of 28 April 2021 establishing the Union Space 
Programme and the European Union Agency for the Space Programme and repealing Regulations (EU) No 912/2010, (EU) No 
1285/2013 and (EU) No 377/2014 and Decision No 541/2014/EU, OJ L 170, 12.5.2021, p. 69, Articles 62 -69.  
70 Under the EU Space Programme Regulation only companies that have been security accredited by the Security Accreditation Board  
(SAB) set up under the Regulation can provide GOVSATCOM services. Accreditation of ent ities established in a third country would 
require a security of information agreement based on Article 218 TFEU with the third country where these companies are establ ished 
(cf. Article 55 of Commission Decision (EU/EURATOM) 2015/44). Even if this require ment was fulfilled, it is highly unlikely that a 
security accreditation could be provided in the light of Article 24 of the Space Programme Regulation. NB: so far the SAB has  never 
issued a security accreditation to an entity established in a third country . 
71 See Chapter 2.2.3.  
 
 EN          25     EN  5.3. Option 1: Fully Public  
This scenario  foresees the development of a dedicated  infrastructure  allowing to provide low 
latency services and global coverage , complementing the existing GEO capacity . In addition , assets 
owned and operated by Member States or EU private entities would be integrated through pooling and 
sharing arrangements building upon the ongoing arrangements in the frame of EU GOVSATCOM. In 
this respect, the dimensioning of the low latency capac ity needs should be carefully assessed in a joint 
process with governmental user communities to ensure that there is no overcapacity.  
Services: The services are exclusively  governmental. Their provision  to EU and Member State users 
and the operations would  be under the overall responsibility of the Commission . However, d epending 
on the security requirements, operations, maintenance and service provision could be contracted to an 
industrial operator, similar to Galileo Services Operations . 
Ownership: This infrastructure would be procured by the Union that  would become the owner of all 
tangible and intangible assets created or developed under the initiative. The p ublic sector  would ensure 
appropriate action towards risks arising from the development, deployment, operation and use of the 
system and services, or in the event of a threat to such system and services. The Union  would assume  
the risks in connection with the implementation, including costs, deployment, delay, and operational 
risks.  
Governance : similar to the one set out in the Space Regulation  for Galileo with Comm ission as a 
Programme Manager, ESA  entrusted with development and deployment tasks and EUSPA  entrusted 
with exploitation  tasks.   
Security: similar to the security governance foreseen by the Space Regulation including the Council 
Decision (CFSP) 2021/698 . The Quantum Key Distribution (QKD) capability developed under  
EuroQCI w ould be fully integrated to the system.  
 
5.4. Option 2: Public -private -partnership: EU Concession  
Similar to Option 1, t his scenario foresees the development of a dedicated infrastructure allowing to 
provide low latency secured servi ces and global coverage , complementing the existing GEO capacity . 
The EU GOVSATCOM pooling and sharing of existing capability would be fully integrated into the 
system.  In this respect, the dimensioning of the low latency capacity needs should be carefully assessed 
in a joint process with governmental user communities to ensure  that there is no overcapacity.  
Under this scenario, the Union would partner with the private sector .  In accordance with the 
provisions of A rticle 2(14) of the Financial Regulation72, a public private partnership is defined as  a 
concession contract between one or more economic operators and one or more contracting authorities 
(i.e. the EU institutions, bodies and agencies). A concession contract entrusts the execution of works 
                                                           
72 Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council of 18 July 2018 on the financial 
rules applicable to the general budget of the Union, OJ L 193, 30.7.2018, p. 1.  
 
 EN          26     EN  or the provision and management of services to an e conomic operator (the concessionaire) and involves 
a transfer to the concessionaire of the operating risk related to these works or service.  
Services: The services would be governmental. However, the  concessionaire  would have the right to 
develop and own additional infrastructure elements allowing it to  provide commercial  services . In this 
case, an adequate open access mechanism should be foreseen to allow other EU telecom operators to 
use a share of the commercial capacity.  
With regard to the cost and risk sharing mechanisms:  
i. The concessionaire would be tasked with the operations, maintenance and necessary upgrades 
of the system  (except for security assets directly operated by the EU).  In turn, the EU could 
commit to appropriate long -term service paymen ts to cover provision of services to  EU 
institutions and Member States . 
ii. The concessionaire would bear all costs related to the provision of commercial services as well 
as any additional infrastructure cost.   
Ownership:  The ownership of the infrastructure w ill be based  on the  capital expenditure  sharing 
model between public and private sector agreed under the concession contract. In all cases, t o ensure 
the security and availability of the governmental services, the Union should  own the part of the system 
infrastructure related to security (such as the quantum encryption part of the system,  or the Security 
Monitoring Centre ) and ensure a n non -exclusive and unrestricted acce ss and use of the other parts of 
infrastruct ure which are necessar y for the provisi on of the Governmental Services . The private sector 
would exclusively own the additional elements of the infrastructure related to the provision of the 
commercial services.  
Governance : The Commission will be the Programme Manager for the establishment and the 
supervision of the concession. EUSPA  will be entrusted with the provision of the governmental 
services. ESA will be entrusted with the supervision of the development  and v alidation  activities.  
Security: similar to the security governance foreseen by the Space Regulation including the Council 
Decision (CFSP) 2021/698 . The Quantum Key Distribution (QKD) capability developed under  
EuroQCI w ould be fully integrated to the system.  
 
5.5. Option 3: Service procurement from a non -EU private constellation  
Several non -EU based commercial constellations are currently being deployed , but none in the EU . 
Under this scenario, the Union would need to conclude an agreement where it would take an equ ity 
stake in one of the entities controlling these infrastructures, in order to ensure guarantee of access to 
services  on a par with other system users . This stake could materialise, through a shareholder 
agreement, in detaining a specific class of shares allowing to ensure a certain level of control over the 
internal decision -making process of the company in specific areas, (such as the service portfoli o to be 
offered to EU governmental users). The instrument to be used by the Union to buy and detain corporate 
 
 EN          27     EN  shares remains to be defined, as this would be the first time the EU would acquire a significant amount 
of shares of a company established in a th ird country.  
Services: The governmental services would be provided on the basis  of a service contract.  The system 
would still primarily provide commercial services to other users.  
Ownership: The infrastructure would remain owned by the private non -EU entity. The system 
implementation, its operations, maintenance , governance  and the provision of services would remain 
entirely in the hands of the third -country commercial entity. The entity would continue to operate under 
the laws and the s upervision of its country of establishment, outside of the Union.  The Union would 
just be one shareholder among others.  
Security: The entity would be subject to the security regime in force in its  country of establishment . 
To ensure the security and avail ability of the governmental services, the Union would have to request 
that some adjustments are brought to the system architecture (such as geographical footprint of the 
Ground System, software development and validation approach, cybersecurity approach). These 
adjustments would need to be sufficient to allow a security accreditation in line with the provisions of 
the Space Regulation73. EuroQCI or any EU native encryption features would not be integrated into 
the system.  
5.6. Other Options discarded  
Further options have been carefully analysed, however these were discarded at an early stage:  
Research partnerships : Concerning the implementation under one of the research partnership 
instruments foreseen in the TFEU (EU participation in research program mes jointly undertaken by 
several EU countries under Article 185 or joint undertakings under Article 187 TFEU) and the Horizon 
Europe Regulation (co -programmed partnerships, co -funded partnerships)74, these partnerships are 
foreseen and tailored for long -term research and innovation activities and are not suitable for the 
implementation of operational space services systems75. Furthermore, such partnerships do not allow 
a competitive tendering element with a view to obtain the best value for money.  
 
                                                           
73 Regulation (EU) 2021/696 of the European Parliament and of the Council of 28 April 2021 establishing the Union 
Space Programme and the European Union Ag ency for the Space Programme and repealing Regulations (EU) No 
912/2010, (EU) No 1285/2013 and (EU) No 377/2014 and Decision No 541/2014/EU  
74 Regulation (EU) 2021/695 of the European Parliament and of the Council of 28 April 2021 establishing Horizon 
Europ e – the Framework Programme for Research and Innovation, laying down its rules for participation and 
dissemination, and repealing Regulations (EU) No 1290/2013 and (EU) No 1291/2013, OJ L 170, 12.5.2021, p. 1 –68 
75 Art. 2 (3) Horizon Europe Regulation: “Eur opean Partnership' means an initiative, prepared with the early involvement 
of Member States and associated countries, where the Union together with private and/or public partners (such as 
industry, universities, research organisations, bodies with a publi c service mission at local, regional, national or 
international level or civil society organisations including foundations and NGOs) commit to jointly supporting the 
development and implementation of a programme of R&I activities, including those related t o market, regulatory or 
policy uptake.”  
DRAFT - PRELIMINARY  
 
28 
EN                                                                        EN 5.7. Summary  
The following table provides an overview of the policy options discussed in this chapter:  
 Ownership  Operations  Governance  Services   
Security  
 
  Public Sector  Commercial  
 Market  
Option 0:  
Baseline   
EU 
  
EU Commission , with tasks 
entrusted to  EUSPA  Service contract with EU and 
Member States  
 N/A Subject to Space Regulation  
 
No integration of QKD into the system.   
Option 1:  
Fully public  EU  If the security 
level allows, 
some assets can  
be contracted to 
industrial 
operator  Commission , with tasks 
entrusted to EUSPA and 
ESA  Services to public 
stakeholders managed by EU.   
 
Industrial Operators could be 
tasked with the  operation of 
the system, through a service 
contract  None  Similar to the security governance 
foreseen by the Space Regulation 
including the Council Decision (CFSP) 
2021/698.  
 
The Quantum Key Distribution (QKD)  
capability developed under EuroQCI 
would be fully integrated to the system.  
 
 Option 2:  
Public -
private -
partnership: 
EU 
Concession  Public -owned 
security assets  
Private owning 
operational and 
commercial 
assets  Private  (except 
security assets, 
directly 
operated by EU)  Commission , with tasks 
entrusted  to EUSPA and 
ESA  Commitment to long -term 
service payments to cover the 
demand of Member States  and 
EU institutions regarding 
public secure satellite services  Concessionaire free to market 
commercial services, provided 
he entirely finances and 
deploys the additional 
infrastructure required to 
deliver such services.    
Option 3:  
Service 
procurement 
from a non -
EU 
constellation  Private (with 
minority  EU 
stake)  Private non -EU  Private non -EU Service contract with EU and 
Member States  
 Private  Subject to security regime of 3rd country  
 
No integration of QKD into the system.  
Table  2: Summary of Options  
 
EN             29     EN  
 6. WHAT IS THE IMPACT OF THE P OLICY OPTIONS ?    
6.1. Economic impact  
The economic impact has been analysed on three main dimensions. One of the major impact of the 
initiative is the cost of the satcom services, and in some cases the cost of the infrastructure investments 
(CAPEX) and operational costs (OPEX) needed to enable these services. A second group of economic 
impact relates to the broader effects of public investments, such as changes in employment or Gross 
Value Added (GVA, a measure of economic output). Those have been analysed by econometric input -
output modelling. The third group of economic impact concerns th e enabling of commercial 
downstream activities in the options where a private operator would build upon the governmental 
infrastructure to develop a commercial offer.  
6.1.1.  Cost  
The estimated cost of the additional  satcom  capacity , designed to serve governmenta l demand is as 
follows:  
 The cost associated to the deployment of the infrastructure needed to provide governmental 
services is estimated at around EUR 6 billion.  
 The cost to operate and maintain the constellation  
 The investment share and risk exposure of the public sector would depend on the policy option 
selected for its implementation.  
Figures  are built upon cost modelling exercises performed in the context of the secure connectivity 
study.  The cost  of the initiative will differ based on which option is chosen.  
 CAPEX 
for the 
Union  in 
EUR   Annual 
OPEX for 
the Union  in  
EUR  Annual Service 
costs paid by the 
Union  in  EUR  Comments  
Option 0: 
Baseline  180 
million  Not 
applicable  40 million from 
2025 to 2027  Services would be procured depending on budgetary 
availability (currently 40m in current MFF)  
 
Option 1:  
Fully public  6 billion 250 million  Not applicable   
Option 2:  
PPP / Concession  4 billion 170 million  Not applicable  Current assumption based on power/bandwidth allocation: 
two-third of costs for public sector (EU+MS ) 
Option 3:  
Stake in non -EU 
constellation  tbd76 Not 
applicable  400 million  Provided that a private operator manages to deploy the 
infrastructure allowing to provide the new services, 
bandwidth would be sold on a market price basis.  
Table  3: Cost impact per option  
6.1.2.  Job creation and gross value added (GVA)  
Job creation and gross value added (GVA) is directly affected by the level of investment into the EU 
space economy.  From an infrastructure deployment perspective (upstream sector), multipliers defined 
                                                           
76 Subject to negotiation. As a benchmark, the UK government purchased a GBP 400m stake in Oneweb equity of 19.3%  with 
additional special rights (‘Golden share’)  
 
EN             30     EN  
 in the frame of previous Space Regulation impact assessment studies  can be transposed seamlessly to 
this infrastructure. However, when it comes to the downstream sector, it should be better to use 
telecommunication/ broadband multipliers. In that case, the econometric used is the one developed by 
ITU77.  
Upstream sector: Investment into the space upstream sector creates transactional effects  as the 
investment in the  space economy increase s the value added of suppliers in this sector , and the wider 
economy due to expanding business and salaries which raise consumption . Multipliers of transactional 
effects in European space programmes are estimated to be 1.4 -2.0 (i.e. EUR 1 invested in the space 
sector leads to a GDP increase of EUR 1.4 -2.0)78. Currently, the European space industry employs 
over 231  000 professionals79, most of them highly skilled. The fostered growth would cause an 
additional demand for jobs  in this indu stry.  
The economic impact on the baseline scenario (option 0) is equivalent to the current EU 
GOVSATCOM programme, which is expected to increase the cumulative Gross Value Added (GVA)  
until 2040 by EUR 2.7 -5.0 billion (mainly in Europe) while requiring spending for the infrastructure  
and services in a magnitude of EUR 2.2 -4.1 billion80. As Options 1 and 2 would require the 
deployment of a new infrastructure , its impact on GVA would reac h EUR 17-24 billion.  Impact of 
Option 1  would be lower than in Option 2, as the infrastructure that the public sector could deploy 
would be strictly limited to the provision of governmental services, while in Option 2, commercial 
investments made by the private sector, including in and with the European New Space ecosystem, 
could enable further GVA increase.  Option 3 would not primarily lead to increased invest ment  directly 
in the EU space sector , except for adjustments on the ground segment footprint tha t could be requested 
by the EU81.  
Downstream sector.  Investments in Space upstream infrastructure is estimated to generate a six -fold 
impact in downstream sectors82.The spill over effects are created by downstream sectors using  the 
services, technologies and data provided by the space sector to enhan ce their business. These are 
estimated to have an impact at 1.8-3.2 (i.e. EUR 1 invested in the space sector le ads to a GDP increase 
of EUR 1.8 -3.2).  As Options 1 and 2 would requir e the deployment of a new infrastructure , its impact 
on GVA would reach EUR 10 -19 billion.  
                                                           
77  ITU (2020):  The economic contribution of broadband, digitization and ICT regulation: Econometric modelling for 
the ITU Europe region  It is worth noting that the model differentiates between low, medium and high income 
countries and therefore has a relatively conservative estimate of benefits for the Europe region.  
78  PwC (2019): Main trends and challenges in the space sector  and Eurostat (2019): EU inter -country supply, use and 
input -output tables — Full international and global accounts for research in input -outpu t analysis (FIGARO)   
79   Council of the EU: EU in space.  
80   EC (2018): Study in support of the Impact Assessment of an EU GOVSATCOM initiative, Annex 8   
81   It is however worth noticing that EU space industry is significantly contributing to the deployment of several major non -EU 
constellations: Telesat Lightspeed, Oneweb, etc.  
82   Council of the EU: EU in space.   
 
EN             31     EN  
  
Figure 10: Output multiplier calculation. Source: Roland Berger  
The growth of the downstream sectors, triggered by secure satcom , would create new job 
opportunities:  employment multipliers of European space programmes are estimated to be 1.2 -2.4 
(i.e. for each new job in the space sector 0.2 -1.4 additional jobs are created in the wider economy 
outside the space sector83). For Option  0, the job creation would be limited to those created in relation 
to EU GOVSATCOM, whereas Option 1 and 2 would have a higher impact on jobs due to growth in 
space and downstream sectors.  
The possibility offered  in Option 2 and 3 for the  private sector to make additional investment to 
develop commercial services  can create additional economic benefits for the downstream sector, 
as it can address significant  commercial market opportunities . In addition to fixed and mobile 
offerings, satcom  can contribute to enabl ing ‘smart ’ systems and applications, particularly smart 
energy systems (smart electricity grids, smart home devices for heating, air conditioning, and lighting), 
but also smart applications in agriculture (e.g. to connect sensors f or humidity and temperature to 
manage irrigation), manufacturing, logistics and other sectors84.  
Satcom communication c ould foster digital technologies in the downstream sectors which could reduce 
the number of jobs due to process automation or outsourcing  of jobs to non -EU countries. However, it 
can be expected that these effects would be compensated by the effect on innovations in applications 
and services which w ould create new jobs85. These new services, technologies and data w ould also 
                                                           
83  PwC (2019): Main trends and challenges in the space sector  
84  Apart from the overall economy the areas prof iting most from space investments are environmental management, 
transport and urban planning, R&D and science, climate monitoring and meteorology, telecommunications, defence 
and security, energy, agriculture, high -tech industries, and manufacturing, minin g and construction. OECD (2019): 
The Space Economy in figures. https://read.oecd -ilibrary.org/science -and-technology/the -space -econom y-in-
figures_c5996201 -en#page45  
85  A study by ITU considering the different effects of additional access to fixed and mobile broadband networks came 
to this result. ITU (2020): The economic contribution of broadband, digitization and ICT regulation. Econometric 
modelling for the ITU Europe region. https://www.itu.int/dms_pub/itu -d/opb/pref/D -PREF -EF.BDT_EUR -2020 -
PDF-E.pdf  

 
EN             32     EN  
 create spill over  effects for the downstream sector to enhance their business opportunities.  Option 2 
and 3 may therefore provide additional positive impact on the job creation.   
The new commercial services may support bridging the digital divide by providing ubiquitous 
broadband coverage to the EU . This can  push ICT adoption in rural areas , which would trigger  
investments and lead to additional growth lowering the economic gap to non -rural areas86. A study 
undertaken by the ITU has shown that a 10% increase in mobile and fixed broadband penetration in 
Europe would yield an increase of 2.1% and 0.46%, respectively, in GDP per capita87. 
Further, a dditional government revenues that stem from taxes on transactions, salaries and 
consu mption, the share of the investment to be recovered from the original investment is estimated to 
be more than 35%88. It is not however, taken into account as such, in the summary below.  
Summary  of the impacts compared to the different options:  
 Upstream  Downstream  
Option 0   Economic growth  limited  to the economic impact 
of EU GOVSATCOM  
 Risk of lagging behind the competition from  non-
EU companies   
  No EU triggering of economic growth stemming from 
SatCom  commercial market services   
 
Option 1   Additional investment required to build the new 
infrastructure would provide transactional effects 
of 1.4 -2.0. 
  Spill -over effect in the downstream market estimated to 
have an impact at 1.8 -3.2 
 Investment in the space upstream infrastructure is 
estimated to generate a six-fold impact in the downstream 
sectors  
 Job growth in estimated to be 1.2 -2.4 
 Additional government revenues are estimated to be more 
than 35% of the original investment  
 No EU triggering of economic growth stemming from 
SatCom  commercial market servic es  
 
Option 2   Additional investment required to build the new 
infrastructure would provide transactional effects 
of 1.4 -2.0. 
 Competition during concession -award process 
and in operations would lead to well -suited 
market solutions  
  Investment in the space upstream infrastructure is 
estimated to generate a six -fold impact in the downstream 
sectors  
 Spill -over effect in the downstream market estimated to 
have an impact at 1.8 -3.2 
 Job growth in estimated to be 1.2 -2.4 
 Additional government revenues are es timated to be more 
than 35% of the original investment  
 The private concessionaire would be allowed to 
commercially exploit the system which would lead to 
economic growth and additional jobs in space and 
downstream sectors  (including New Space). This includes 
the economic benefits of bridging the digital divide.  
 
Option 3   The equity investment will have marginal impact 
on the EU space economy   Commercial satcom solutions would lead to econo mic 
growth and additional jobs in the downstream sector. This 
                                                           
86  The GDP per capita in rural regions is only at 75% of the EU average and in r emote rural regions it is even lower, at 
70%. EC (2021): A long -term Vision for the EU's Rural Areas - Towards stronger, connected, resilient and 
prosperous rural areas by 2040.  
https://ec.europa.eu/info/sites/default/files/strategy/strategy_documents/documents/ltvra -c2021 -345_en.pdf  
87  ITU (202 0):  The economic contribution of broadband, digitization and ICT regulation: Econometric modelling for 
the ITU Europe region  
88  PwC (2 019): Main trends and challenges in the space sector   
 
EN             33     EN  
  Risk of lagging behind the competition from  non-
EU companies   includes the economic benefits of bridging the digital 
divide  
 
Table 4: overview of economic impacts  
 
6.2. Social impact  
6.2.1.  Civil protection  
The initiative enhances the resilience  of EU infrastructure and public services  hence the social 
imprint of their operational performance . A very high reliability and availability ratios of more than 
99.9% are further advantages of satcom  when it comes to civil protection89. The initiative would 
provide a ubiquitous and resilient communication system to ensure smooth functioning of critical 
infrastructure (dams, power stations, local 5G cells  etc.) and uninterrupted coordination of citizens and 
public authorities in case of emergencies  and disasters. It provides a backup infrastructure for terrestrial 
networks as well as a reliable infrastructure for areas that are currently disconnected but may require 
communication in case of emergencies and disasters like earthquakes, floods, fires, and attacks by 
terrorists or criminals.  
The added value for citizens as well as for people responsible for critical infrastructure sites to have 
the chance to communicate in such a situation is extremely high. A delay in delivering the 
communication service or a limitation of such service may re sult in a greater number of people injured 
and lives lost as well as in more damages in the critical infrastructure with all its subsequent 
consequences. A resilient communication network would mitigate these risks and enable rescue and 
evacuation teams to  react quickly. The use of Quantum Key Distribution (QKD)  would improve 
Information Assurance  by strongly reinforcing encryption robustness . The implementation of such a 
system would increase trust and resilience of telecommunications within Europe. In add ition, satellite 
communication would enhance early -warning systems to further save lives by monitoring the 
environment and sending the most recent data to public authorities to immediately respond to 
environmental threats like floods, earthquakes, tsunamis , or radioactive releases90. 
Reliability and guaranteed access of the service  is needed i n order to ensure the capacity during 
an emergency . For the baseline scenario (Option 0) this is ensured to a certain extent, limited by use -
case gaps and the life -time of the current pooling and sharing satellite fleet. Option 1 and 2  would 
provide full capacity to Member State s and EU institutions , but th e access to ensure a high security, 
availability and reliability would be easier under Option 1 than 2. However, it would be the most 
difficult to ensure this level of assured access under Option 3 , as other foreign governments may 
compete over the same ac cess in Option 3.   
                                                           
89  For a comparison of terrestrial and satellite networks see Orange (2015): satellite vs. terrestrial – which network is 
right for you. https://www.orange -business.com/sites/default/files/media/library/0215_satellite_vs_terrestrial_wpr -
sat-0094.pdf  
90  ESOA (2021): Satellite Communications for Early Warning, Environmental Monitoring & Climate Change. 
https://esoa.net/wp -content/uploads/2021 -01-Satellite -Communications -for-Early -Warning -Environmental -
Monitoring -Climate -Change.pdf  
 
EN             34     EN  
  
6.2.2.  Benefits of potential commercial use cases  
The involvement of the industry in Option 2 and 3 may produce spin -off effects for the social and 
territorial cohesion of the EU, if they chose to exploit the system for commercial use cases91, such 
as providing satcom broadband to remote areas. This would increase the quality of life in remote 
regions by providing broadband access to the internet and thus enabling internet -based services like 
online education, eHealth and eGovernment. In 2019, 8 6% of all EU households had access to a 
broadband connection of at least 30 Mbps (Next Generation Access, NGA) while in rural areas only 
59% of households had this type of connection.92 For local companies in remote areas the initiative 
would open business opportunities to connect with suppliers and customers as well as to develop digital 
business models.  
 
6.3. Environmental impact  
6.3.1.  Environmental i mpacts of building infrastructure  
Launching a satellite communication system would inevitabl y have an impact on the environment, 
particularly due to the environmental footprint related to the manufacturing and launching of the 
system infrastructure. In this regard, Options 1  and 2 are expected to have the similar 
environmental impact . Compared to other industry sectors, the manufacturing of spacecraft does not  
emit significant greenhouse gases emissions93. The initiative has similar positive contribution towards 
environmental objectives as the Galileo and Copernicus components of the Space Regulatio n94. A 
dedicated study on the environmental benefits stemming from the use of the components is 
approximately 2 orders of magnitude higher than the environmental footprint generated by the 
construction, deployment (including the launches and the production of launchers) and use over the 
complete life time (22 years) of these systems. See figure 11 of the benefits to impact comparison .   
                                                           
91 Example of commercial broadband use -cases include: mobile and fixed broadband satellite access, satellite trunking 
for B2B services, Satellite ac cess for transportation, reinforced networks by satellite and satellite broadband and cloud -
based services. Source: Study DEFIS/2020/ OP/0008 : GOVSATCOM and EuroQCI: Building Blocks Towards a Secure 
Space Connectivity System  
 
93 Eurostat Manual of Supply, Use and Input -Output Tables (2008)  
94 Note that even though of the n umber of satellites are bigger in t his activity than i n Galileo or Copernicus, the small size 
and mass of the satellites coupled with  the possibility to launch them in g roups  of large numbers (e .g. from 12 to 36 
satellites in one launch) results in relatively comparable footprint evaluation . 
 
EN             35     EN  
  
Figure 11: PWC (2020) Analysis of the Environmental Impact of the EU Space Programme  
Option 0 wo uld not have a further environmental impact, as it relies only on existing satcom 
capacities. Option 3 would have a lower impact than Options 1 and 2 , for those third country owned 
LEO constellations that have already launched an initial set of satellites allowing them to provide 
initial services. However, Option 3 would have a higher impact than Option 0, as these third country 
owned LEO constellation s have not yet achieved full operational capability and require further launch 
of satellites.  
Satellites  in orbit create a risk for long -term environmental harm, due  to its potential of creating 
additional space debris, either at their end -of-life or due to a technical failure. To mitigate the impact 
on the space environment, Options 1 and 2  would  comply with the international standards on the 
protection of space environment  (e.g. the Committee on the Peaceful Uses of Outer Space 
(COPUOS ) and Inter-Agency Space Debris Coordination Committee ( IADC ) Space Debris Mitigation 
Guidelines), as well as the existing national legislation (e.g. the French LOI n° 2008 -518 relative aux 
opérations spatiales95). Further, an EU  built system would  also comply with existing EU 
environmental regulations, such as REACH regulation96 and the EU Directive on Hazardous 
Waste97. Reducing th e debris  risk with voluntary adherence to international debris mitigating standards 
is challenging in the case of owning a stake in foreign constellation (Option 3).  
6.3.2.  Environmental benefits  
At the same time, the initiative is also expected to result in a number of positive environmental 
impacts . The infrastructure will provide communication through space, hereby avoiding the 
deployment of ground networks, submarine cables, high power cables or fibres (buried in the ground 
or above the ground). No significant harm will therefore be done to the sustainable use and protection 
of water and marine resources. Satcom services for maritime surveillance supports pollution detection 
                                                           
95 LOI n° 2008 -518 du 3 juin 2008 relative aux opérations spatiales  
96 Regulation (E C) No 1907/2006 Of The European Parliament And Of The Council of 18 December 2006 concerning 
the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals 
Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission 
Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 
93/67/EEC, 93/105/EC and 2000/21/EC  
97 Council Directive 91/689/EEC of 12 December 1991 on hazardous waste  

 
EN             36     EN  
 and response as well as environmental monitoring.  In addition, minimising  environmental risks to a 
large extent relies on data monitoring . Monitoring data like water levels, land cover change, ice sheet 
elevation, and ice sea thickness will become even more important and require larger quantities of data 
being transmitted. The initiative could help to relay data from Earth Observation satellites (such as 
Copernicus) to ensure high -speed delivery of time -critical data to be better prepared, inform citizens, 
and take action. The services provided by a space -based secure connectivity infrastructure are also 
expected to provide the communication channels for autonomous vehicles, thus resultin g in more 
energy efficient road transport.   
Where the private industry choose to exploit the system for commercial services (potentially Option 2 
and 3), low -latency broadband can be beneficial for the environment . For example , smart systems 
creates energy efficiency by enabling households  to have better understand and control their energy 
management, precision farming can increase input use efficiency and reduce emissions,  and IoT 
applications can be used to track wildlife ext ension .  
An overview of the  analysis of the initiative’s compliance with the “do no harm principle ” can be 
found in annex 5.   
7. HOW DO THE OPTIONS CO MPARE ? 
7.1. Effectiveness  
The effectiveness  of the options is examined against the policy objectives identified in Section  4. The 
criteria presented below are used to help assess the effectiveness.  
 
 
 
 
 
 
 
 
 
 Specific objectives  Assessment criteria  
Specific Objective I   
 
Ensure the provision of secure satcom  for 
evolving public  needs   
- Ability to scale the  capacity to meet future 
needs in a flexible manner  
Specific Objective II   
 
Increase resilience of Member States and EU 
missions and operations by guaranteed access to 
satcom   
- Extent of information assurance  & guarantee 
of access through the GOVSATCOM hub  and 
security accreditation board  
- QKD payload  
Specific Objective III  
 
Ensure that governmental communication needs 
are not critically dependent on non -EU operations  
  
- Appropriate level of non -dependence on third 
countries , e.g.:  
o Location of system management and 
operations  in the EU  
o Software produced and validated in 
the EU  
o Testing of technology in the EU  
- Long -term competitiveness of the EU satcom 
industry  
 
EN             37     EN  
  
 Baseline  Option 1  Option 2 Option 3 
Specific Objective I   
Ensure the 
provision of secure 
satcom for evolving 
governmental needs   (=) 
  EU current pooling and sharing capacity 
under GOVSATCOM dependent upon further 
commitment from MS and national 
governments  
 Future gaps not ensured  in current pooling 
and sharing system, and would become 
increasingly difficult to cover in time due to 
the frequency scarcity  (+++)  
  EU ownership allows the ability to scale up 
according to each MS’ identified needs  
 
 
 (-) 
 The service provided  would be commercial -off-the shelf, 
and would not meet several governmental requirements 
(e.g. signal robustness, use of governmental frequencies)   
 
Specific Objective II   
Increase resilience 
of Member States 
and EU missions 
and operations by 
guaranteed access to 
satcom  (=)  
 
 EU GOVSATCOM hub and security 
accreditation applies  
 However, no possibility to implement low 
latency services, global coverage and QKD 
payloads  (+++)  
 
  Increased number of satellites compared to 
existing assets, leading to greater resilience  of the 
system and to a reduction of service disruption 
risk 
  EU GOVSATCOM hub integrated and  security 
accreditation applies   
 Ability to implement low latency services and to 
include QKD  payloads   
 
 (-) 
 
 
 Services would be supervised by non -EU authority, in non -
EU jurisdiction, thus decreasing overall resilience and EU 
operational autonomy  
 Security accreditation  for non -EU solution would be  very 
challenging , and the services may not offer the same level 
of security requirements as an infrastructure primarily 
designed for governmental use (Design robustness and 
encryption remain commercial…)  
Specific Objective III  
 
Ensure that 
governmental 
communication 
needs are not 
critically dependent (=) 
 Limited to the current pooling and sharing 
under EU GOVSATCOM component  low 
latency user needs cannot be satisfied  
 Risk of EU satcom industry losing industrial 
competitiveness in the field of low latency  
 (+++)  
  The EU can define and control all aspects of the  
initiative:  
  Full operational autonomy  (--) 
 Entirety of operation, and thus the very service provision, 
would be performed outside of EU. The decision or not to 
disrupt services would be entirely in non -EU decision 
making processes (at both service provider level and third 
state supervision authorit y).  
 
EN             38     EN  
 Table  5: Effectiveness assessment  
 
7.2. Efficiency  
The combined measures under the retained Options have economic, social and environmental impacts. The major costs of Options 1 and 2 relate 
to building the infrastructure.  
Baseline costs as well as economic, social and environmental benefits are not recap ped in this table, as services are not fully comparable. 
However, impacts are measured against baseline  on non -EU 
operations  
  Appropriate /affordable  level of industrial 
dependence (to be discussed with industry 
during the procurement phase)  
 R&D investment will contribute to the EU 
industrial competitiveness  
  This option would even be worse than baseline, because 
over time users would increase their dependence by 
building systems, tools, processes that rely on these non -
EU services. A subsequent disruption would create even 
disturbance.    
 Risk of EU satco m industry losing industrial 
competitiveness in the field of low latency  
 
 Option 1  – Full Public  Option 2  – PPP/Concession  Option 3 – Stake in non -EU constellation  
Costs     
Infrastructure  6 billion 4 billion Depending on the Equity stake to be taken  
Service costs  Not applicable  Not applicable  400 million , bandwidth valued on market 
price basis.  
OPEX for the Union  250 million  170 million  Not applicable  
Benefits     
Economy (GVA)  (++) (+++)  (+) 
 
EN             39     EN  
  Additional investment required to build the new 
infrastructure would provide transactional effects of 
1.4-2.0. 
  Spill -over effect in the downstream market estimated 
to have an impact at 1.8 -3.2 
 Investment in the space upstream infrastructure is 
estimated to generate a six -fold impact in the 
downstream sectors  
 Job growth in estimated to be 1.2 -2.4 
 Additional government revenues are estimated to be 
more than 35% of the original investment  
 No EU triggering of economic growth stemming 
from SatCom  commercial market services   
  Additional investment required to build the new 
infrastructure would provide transactional effects of 
1.4-2.0.  
 Competition during concession -award process and in 
operations would lead to well -suited market solutions  
  Investment in the space upstream infr astructure is 
estimated to generate a six -fold impact in the 
downstream sectors  
 Spill -over effect in the downstream market estimated 
to have an impact at 1.8 -3.2 
 Job growth in estimated to be 1.2 -2.4 
 Additional government revenues are estimated to be 
more than 35% of the original investment  
 The private concessionaire would be allowed to 
commercially exploit the system which would lead to 
economic growth and additional jobs in space and 
downstream sect ors (including New Space). This 
includes the economic benefits of bridging the digital 
divide.    The equity investment would have marginal 
impact on EU economy  
  Risk of lagging behind the competition 
from  non-EU companies   
 Commercial satcom solutions would lead to 
economic growth and additional jobs in the 
downstream sector. This includes the economic 
benefits of bridging the digital divide  
 
 
 
Social impacts (civil 
security and potential 
spill-over effects)  (++)  
 Full coverage of governmental satellite 
communication needs  
 Availability and reliability of satellite 
communication services for citizens in case of 
emergencies and disasters  
  (+++)  
  The EU has the opportunity to set requirements in 
the concession to secure a high service level 
regard ing availability and capacity of the network  
in case of emergencies and disasters  
 Commercial services can provide positive benefits 
for EU citizens and business (e.g. digital divide)  
 Full coverage of governmental satellite 
communication needs  (+) 
 Provides capacity for governmental user needs, 
but lower assured access to capacity than the 
other options  because of co -ownership 
(potentially with other non EU governments) .  
 Commercial services can provide positive 
benefits for EU citizens and business  (e.g. 
digital divide).  
Environmental 
benefits  (-) 
  Negative environmental impact of developing and 
launching additional satellites  
 Build upon existing infrastructure from 
GOVSATCOM  
 Ownership requires the EU to approve the design, 
hereby enabling a strict adherence to 
environmental standards  and regulation  
 Governmental services supporting environmental 
monitoring  (-) 
 Negative environmental impact of developing and 
launching additional satellites  
  Build upon existing infrastructure from 
GOVSATCOM  
 Through the concession agreement the EU can set 
requirements of adherence to environmental 
standards and regulations  
 Govern mental services supporting environmental 
monitoring  
  The private concessionaire can exploit the 
commercial services enabling environmental 
friendly applications   
 (=) 
 Low environmental impact from using existing 
capacity , however the non -EU constellations 
have not yet achieved full operational 
capability and require the launch of further 
satellites.  
 Reducing risk with voluntary adherence to 
international environmental standards 
challenging in a foreign constellation  
 Services c ould be used for environmental 
monitoring  
 
 
EN             40     EN  
  
Table  6: Efficiency  Negative environmental impact of developing and 
launching additional satellites   
 
EN             41     EN  
  
7.3. Coherence  
As regard s coheren ce with key EU policy objectives , the main objective of the initiative is to 
provide Me mber State s and EU Institutions  with a tool to respond to their public satcom needs .  
Option 1 and 2  would integrate the EU GOVSATCOM component of the Space Regulation  
in their infrastructure , and hereby create coherence with EU space policy . In addition, as 
Option 1 and 2 would be EU operated and provide the highest level of security, they would 
strengthen the ability to provide an integrated EU response to security threats as called for in 
the EU Security Union Strateg y and in the global strategy for the European Union’s Foreign 
and Security P olicy .  
The development of new infrastructure could benefit from EU research, development and 
innovation policies , hereby contributing to the avoidance of strategic dependence in line with 
the New Industrial Strategy .  
The services enabled by a new infrastructure , would support transport policies  for 
autonomous mobility, and would connect strategic areas  such as Arctic and Africa , in line 
with policy targ ets in these regions and the global gateway . As Option 2 may further enable 
commercial services to these regions, it ranks higher than Option 1.  
 
Option 2  and 3 may contribute to EU’s digital policies , should  the private sector exploit the 
commercial opportunities.  
 
7.4. Feasibility    
Option 0 (Baseline). As the baseline option is already being implemented, it has the highest 
feasibility ranking. During bilateral meetings , Member States have expressed support for the 
current GOVSATCOM pooling and sharing. However several Member State s acknowledged 
the urgency of action now, in order to obtain frequency and orbital slots for future evolving 
needs, and are therefore positive towards the early next initiation of further capacity . Industry Policies (see section  4.3)   Option 0 – 
Baseline  Option 1 – Full 
Public  Option 2 – 
PPP/Concession  Option 3 – Stake 
in non -EU 
constellation  
EU space policy  = + + - 
Digital policies  = = ++ + 
EU Security Union Strategy  = ++ ++ -- 
Research, development and 
innovation policies  = ++ ++ - 
Transport policies  = + + = 
Union policies relating to global 
leadership  = + ++ - 
EU policies relating to connecting 
strategic areas  = + ++ - 
Global gateway  
 
EN             42     EN  
 stakeholders have stated that there are no plans for EU private companies of creating a satcom 
constellation that will meet the evolving governmental low -latency and global need s98.   
Option 1 (Fully pub lic) is assessed to have a  medium feasibility  ranking . The EU has large 
experience  of implementing such initiative  from its flagship programme EGNSS and 
Copernicus and can take full recourse to respective lessons learned and established practices. 
Namely, Commission , EUSPA , and ESA have considerable experience with large scale 
procureme nts of space assets and ground system elements. Similar experience also exists where 
a private operator should be charged with the system operations, maintenance, and service 
provision tasks.  
Option 2 (PPP Concession) is assessed to have a medium feasibil ity ranking. There is a legal 
certainty and clarity  regarding the  concession process ( Article 2 (14) and Article 164 of the EU 
Financial Regulation ). However, a concession requires a very sound preparation  and t he 
procurement procedure would likely be relatively lengthy and would require dedicated  
resources. The need to negotiate a sound and reliable allocation and delimitation of risks and 
benefits  adds further complexity. The Space Regulation99 acknowledges the PPP approach for 
the acquisition of satcom infrastructure . Consultation s with stakeholders  reveals that  the 
majority of industrial stakeholders favours the PPP approach.  
Option 3 (Stake in non -EU constellation ) is assessed to have t he lowest feasibility ranking . 
This low score is given, because it would be difficult politically to garner the support for a 
stake. Legally speaking it is also difficult, bec ause it would require the EU  to acquire a 
significant amount of shares of a company establi shed in a third country, which has not yet 
been done. The instrument for such acquisition could thus have to be defined. Non-EU LEO 
constellation operators have expressed support for this option, because of the benefits related 
to cost -efficiency and quick access to services.   
7.5. Comparison summary  
The table below  summarises the assessment of impacts:  
                                                           
98 Detailed views of the different stakeholder groups can be found in Annex 2.  
99 Recital 10 4 of the Space Regulation   Baseline  Option 1  Option 2  Option 3  
Effectiveness   (=) (+++) (+++) (-) 
I – Ensure provision of secure satcom  (=) (+++) (+++) (-) 
II – Increase MS resilience  (=)  (+++) (+++) (-) 
III – No critical dependency  (=)  (+++)   (+++)   (--) 
Efficiency  (=) (+) (++) (+) 
Cost (=)  (--) (-) (=)  
Economic benefits (GVA)  (=) (++) (+++)  (+) 
Social impact  (=) (++)  (+++)  (+) 
Environmental benefits  (=) (-) (-) (=) 
Coherence  (=) (+) (++) (-) 
Feasibility   (=) (+) (+) (-) 
 
EN             43     EN  
 Table 7: summary of impacts  
 
8.  PREFERRED OPTION   
8.1. Concession  as the Preferred Option  
Option 2, the concession , is assessed to be the preferred option. Together with Option 1 it ranks 
the highest with regard to effectiveness .  
Regarding efficiency, it  ranks  higher than Option 1 as it allows the EU  to split the risks and 
costs with industry  hereby limiting the economic burden of the EU . Industry involvement in 
turn provides spin -off opportunities, enabling it to commercially exploit the satcom system for 
other services, such as broadband. These spin -off effects may have additional economic and 
social impacts, and provides the potential for the initiative to meet broader EU policies related 
to the digital agenda. Option 2 is also  strongly  favoured by Member State and industry 
stakeholders. The drawbac k of Option 2 is the complexity related to the preparations and 
negotiation of the concession agreement.  
However, several  examples of successful PPPs already exist at national level, for example 
HISDESAT in Spain, or LuxGovSat in Luxemburg. ESA is using a similar approach to 
leverage innovation in projects, for example in the approach taken on the European Data Relay 
System. In satellite communications this is tried and tested concept that has been used variably 
for limited investments, such as hosted payload on a satellite, and to larger investments of full 
satellites.  
 

 
EN             44     EN  
 Figure 12: PPP approach100 
Option 2 has the advantages that it:  
 
 Improves the provision of governmental services ( low latency, resilience, security, 
guaranteed access, autonomous use)  
 
 Enables the provision of additional commercial s ervices  (economic growth, social benefits)  
 
 Optimi ses costs:  
- development and deployment with economies of scale  
- operation s with mutualisation of capacity  
 
 Stimulates R&D and leverages innovative technologies , in particular with the New Space 
involvement  (sharing the technology risk between  public  and private ) 
 
 
8.2. Implementation of the Concession  
The initiative would  be implemented  under direct management  in accordance with the 
Financial Regulation or under indirect management with bodies referred to in point (c) of the 
first subparagraph of Article 62(1) of the Financial Regulation.   
The funding  would  be covered by a financial contribution by the Union, the Member States 
(possibly through ESA ) as well as  private sector investment .  
The EU would retain ownership of all tangible and intangible assets forming part of the 
Governmental Infrastructure. To that effect, the Commission would ensure that contracts, 
agreements and other arrangements concerning activities which may result in the creation or 
development of such assets contain provisions ensuring the Union’s ownership of those assets. 
The private would own operational and commercia l aspects of the initiative, and could exploit 
the system for commercial services through additional infrastructure that it would bear the cost 
for.   
In line with requests from Member States that New Space involvement is ensured in the 
initiative, t he procurement could  elaborate criteria for the award of the concession ensuring 
the participation of start -ups and SMEs  along the whole value chain of the concession , 
hereby incentivising  the development of innovative and disruptive technologies . The 
procurement should  also ensur e effective and transparent competition, reinforce the autonomy 
of the EU in technological terms , and ensure  compliance with requirements related to 
security, service continuity and reliability.   
                                                           
100 A classified note provides more information regarding the proposed set -up 
 
EN             45     EN  
 The governance  would  be based on the following  principles:  
 clear distribution of tasks and responsibilities between the entities involved in its 
implementation ; 
 strong control of cost, schedule and performance ; 
 service continuity, including protection  of the infrastructure  from r elevant threats;  
 systematic and structured consideration of the users needs and their evolution;  
 risk mitigation, in particular through appropriate risk sharing mechanism between public 
and private partners.  
The Commission would have overall responsibility  for the implementation of the 
Programme , including in the field of security, without prejudice to Member States’ 
prerogatives in the area of national security.  
ESA  and EUSPA would be entrusted by the Commission  to contribute to the sound 
implementation in terms  of 0development and validation activities, and exploitation activities 
respectively. In addition, EUSPA would carry out  the security accreditation101 of the 
Governmental Infrastructure and Governmental Services in accordance with Chapter II of Title 
V of the Space Regulation.  
To minimise  design and service provision risks , the principle of unity of command should be 
applied. In particular, the concess ionaire should be the only architect and operator of the 
system.  
Finally, t o ensure the control by the Union  over the infrastructure shared with the private 
partner , a number of  contractual provisions  should  be considered  in the concession  
agreement such as : buy-back option  in case of default ; veto right in case of acquisition by a 
third country company;  vetting  of key personnel;  etc. 
 
9. HOW WILL ACTUAL IMPAC TS BE MONITORED AND EVALUATED ?  
The i nitiative will be successful if:  
1. Member States governments and EU institutions can access initial set of 
governmental services in 2025, with full capacity in 2027.  
2. The system performance in term of coverage (Over 99.5% availability), service 
availability (Over 99.9%) , bandwidth, and resilience to threa ts/potential attacks 
(identified in a classified threat analysis) is meeting the services requirements set by 
the Commission.  
3. The system obtains in 2027 a security accreditation allowing the services to transmit 
EU Classified Information (EUCI) up to a cer tain level (classified) and the equivalent 
                                                           
101 Through its Security Accreditation Board  
 
EN             46     EN  
 level of national classification in all EU Member States,  following the principles set 
in Council Decision  (2013/48 8/EU ) on the security rules  for protecting EUCI.  
The monitoring of the initiative should cover the following aspects : 
- Implementation:  Infrastructure deployment according to the concession  
contractual arrangements.  
- Application:  Performance of the services provided under the initiative and 
evolution of needs of the users of the initiative. Concretely measured 
through the indicators below  in Table 8 . 
 
 
Specific Objective  Indicators  Source  Frequ ency of 
measure ment  
Ensure the provision of 
secure satcom for 
evolving governmental 
needs  
  Global coverage (30° over 
horizon)  
 Service availability  
 Average latency  
 throughput  
 number of users   Concessionaire (with EUSPA 
validation)  
  Daily  
 User’s satisfaction   Member St ates 
 End-user EU Institutions and 
Agencies   Quarterly  
 
Increase the resilience of 
Member States and EU 
missions and operations 
by guaranteed access to 
satcom   Number of users  
 Volume of data used (i.e. 
system is used and 
capacity is sized properly)  
 Resilience  to adverse 
events and threats  
 Availability of various 
ranges of end -user 
terminals  
  Concessionnaire  
 EUSPA   Quarterly  
 
 Report on use -cases in 
non-classified areas – 
level of ‘cross -
fertilisation’ between 
users   Member St ates 
 End-user EU Institutions and 
Agencies   Yearly  
Ensure that 
governmental 
communication needs are 
not critically dependent 
on non -EU infrastructure  
  Assessment on critical 
components and maturity 
of EU supply chain  
  Commission with support of 
ESA and EUSPA  
  Every second  
year 
Table  8: Monitoring framework  
Current targets for all these indicators  have been defined during the secure connectivity study 
and are at this stage considered sensitive non classified.  
 
EN             47     EN  
 The initiative would follow the evaluation approach set out for the space programme 
components as set in Regulation. The timeline for evaluation is therefore every fourth year . 
The evaluation would for example use surveys to measure capacity gaps and  user satisfaction, 
and reports  of service availability in order to measure the effectiveness, efficiency and EU 
added value in line with the Better Regulation.  
In addition, regular meetings  with Member  States  would take place  four times a year  under 
the Govsatcom configuration of the Space Programme Committee . During these meetings, the 
Commission would report on the progress of the initiative, enabling Member States to react 
and come with feedback. Furthermore, a n end-user forum, similar to the one of Copernicus, 
would be established.  
  
 
EN             48     EN  
 ANNEX 1: PROCEDURAL INFORMATIO N AND FOLLOW -UP OF 
COMMENTS FROM THE REGULATORY SCRUTINY BOARD  
  
1. LEAD DG,  DECIDE PLANNING /CWP  REFERENCES    
 
DG DEFIS is the lead Directorate General , in close coordination with DG CNECT,  for this 
initiative on EU space -based secure connectivity.  
The initiative was validated in Decide Planning under reference PLAN/2021/10522.  
The Inception Impact Assessment was published on Commissi on website on 31 August 
2021102. 
2. ORGANISATION AND TIMI NG  
 
The work on the Impact Assessment on the EU space -based secure connectivity initiative  was 
coordinated with other services through an Inter -Service Steering Group (ISSG).  The ISSG 
was established on 30 April 2021. Representatives of the Secretariat General (SG), Legal 
Service (LS), Directorate -General for Mobility and Transport (MOVE), Directorate -General 
for Competition (COMP), Directorate -General for Communications Networks, Conte nt and 
Technology (CNECT), Directorate -General for Maritime Affairs and Fisheries (MARE), 
Directorate -General for Neighbourhood and Enlargement Negotiations (NEAR), Directorate -
General for International Partnerships (INTPA), Directorate -General for Migrati on and Home 
Affairs (HOME), Directorate -General for Internal Market, Industry, Entrepreneurship and 
SMEs (GROW), Directorate -General for Health and Food Safety (SANTE), Directorate -
General for Research and Innovation (RTD), Directorate -General for Agricult ure and Rural 
Development (AGRI), Directorate -General for European Civil Protection and Humanitarian 
Aid Operations (ECHO), Directorate -General for Regional and Urban Policy (REGIO), Joint 
Research Centre (JRC), Directorate -General for Budget (BUDG), Europ ean Defence Agency 
(EDA), European Border and Coast Guard Agency (FRONTEX), European Union Agency for 
Space Programme (EUSPA), and the European External Action Service (EEAS) ) were 
appointed to the ISSG.  
The ISSG met four times, first on 27 May 2021, and  the final meeting before the first 
submission of the draft Impact Assessment to the RSB took place on 7 October 2021. Another 
ISSG meeting was held on 10 December 2021  before the second submission  to the Regulatory 
Scrutiny Board . 
  
3. CONSULTATION OF THE REGULATORY SCRUTINY BOARD    
 
The Draft Impact assessment Report was submitted to the Regulatory Scrutiny Board on 11 
October 2021. It received a negative opinion on 12 November 2021, and was resubmitted on  
                                                           
102  Better Regulation: EU space -based secure connectivity initiative – public consultation  
 
EN             49     EN  
 20 December 2021 . While noting the improvements responding to its initial comments, the 
Board nevertheless maintained its negative opinion on 12 January 2022, referring to 
shortcomings  in the following areas:  
(1) analytical coherence between the problem definition, objectives, options, criteria for the 
comp arison of options and the definition of future monitoring indicators;   
(2) on the lack of explanations on the choice of policy options as assuming a predetermined 
technical solution  and consequently artificially limits the scope, design and content of 
the op tions to the implementation of this predetermined outcome;  
(3) absence of a timescale and identification of funding sources  
(4) clarity on methodological assumptions and validity of secondary data cited  
(5) lack of explanations on the compatibility of the initiative with the objectives of the 
Climate Law.  
 
4. REGULATORY SCRUTINY BOARD  FINDINGS AND FOLLOW -UP 
 
The follow -up to the above listed five main shortcomings that the Regulatory Scrutiny Board 
has identified is outlined below for each of them.  
1) There is still no analytical coherence between the problem definition, objectives, options, 
criteria for the comparison of options and the definition of future monitoring indicators.  
a) Problem definition  
i) The core problem  
Both governmental user needs and the satcom solutions are changing rapidly. Under the 
increasing threat levels and increasing importance of real time needs, in particular for Machine 
to Machine (M2M) and Internet of Things (IoT), user needs are moving towa rds higher 
security solutions, low latency103 and global cove rage.   
However, the current EU s atcom assets cannot meet these new needs.  The problem is not 
about a quantitative gap  between supply and demand ( which could be covered by existing 
GEO capacity) but rather a qualitative one , as t here is not today any EU low latency solution 
(LEO and MEO ) that coul d meet the evolving  user needs.   
As explained in section 2.4, EU public and private stakeholders have indicated their intention 
not to purs ue the development of their own LEO capabilities. The non -geostationary nature of 
the system leads to launch a significant amount of satellites to provide permanent coverage, 
                                                           
103  Latency: a mount of delay, measured in milliseconds (ms), that occurs in a round -trip data transmission to a satellite.   
 
EN             50     EN  
 which requires an amount of CAPEX that could not  reasonably be covered by a singl e Member 
State104.  
In addition , this problem cannot be adequately addressed through a non -EU solution  since  
Member States and EU Institutions require, for governmental needs , a guaranteed access  in 
an unrestricted manner  to secure connectivity services without soliciting the assent of a 
third party.   
The use of non -EU, commercial off -the-shelf satcom capabilities for low -criticality 
governmental applications should remain open to third -country operators, as it is the case 
today.  
ii) Problem drivers  
As regards the problem drivers, the following clarifications need to be taken into account:  
- as regards the threat level increase and its changing nature  
As clearly documented in a range of EU policy documents (see section 4.3 of the Impact 
Assessment), the th reat level against EU Member States and institutions is increasing, and 
changing in nature, leading to increased risks to citizens, governments, EU institutions and 
their interests.  
This relates to hybrid threats, cyber threats, increase of natural disaste r, as well as quantum 
computers.  
With regard to quantum key distribution , the initiative will include quantum technology with 
a view to avoid ing a situation where quantum computers would be able to decrypt the 
information transmitted through its infrastructure.  Quantum Key Distribution (QKD) is one 
way to develop post -quantum cryptography. The current technologies for terrestrial QKD have 
a distan ce limit due to signal light attenuation ( Current  record , set early 2022 by a team from 
the University of Science and Technology of China , reaches  only 833 km105), but its range of 
communication can be extended by employing satellites equipped with high -quality optical 
links. In 2017, a quantum key distribution was performed between Beijing and Vienna (4 600 
km) using Chinese QKD satellite Micius .  Further activit ies need to be conducted between 
2022 and 2027 to ensure that such a system can be accredited to convey EU classified 
information (EUCI).I t is important to remind  that the Secure Connectivity initiative does not 
create the EuroQCI infrastructure or its spa ce based segment (adopted in June 2019), but that 
the two initiatives are integrated to maximise the synergies.   
                                                           
104 The cost to deploy such a system exceeds EUR 5bn, where the highest spenders  in the EU (France, Germany, Italy) spend on ave rage 
EUR 0.5bn per year on Satcom systems.  
105 Wang, S., Yin, ZQ., He, DY.  et al.  Twin -field quantum key distribution over 830 -km fibre.  Nat. Photon.  16, 154–161 (2022).   
 
EN             51     EN  
 The use of private satellites is not considered compatible with the high security 
requirements of QKD, because the satellite itself should be t rusted as it generates (or has 
access to) the cryptographic keys.  
- as regards the evolving nature of secure governmental satcom needs  
Traditionally, satcom has been used for voice communication and data transfer in remote areas 
(e.g. at sea), but the nature of use cases is rapidly evolving, driven by both technological 
developments and geopolitical shifts:  
 Machine to Machine (M2M) and I nternet of Things (IoT)  
 Move towards autonomous transportation and Remote Piloted Aircraft Systems 
(RPAS)  
 Increased global coverage needs.  
The cumulative combination of technological developments with the identified use -cases 
testify to a significant evolution of EU secure satcom needs. Table 1  page  13 provides a 
visual synthesis of the above linkages. It demonstrates that all identified use -cases are affected 
for instance by Machine -to-Machine communication (e.g. border surveillance increas ingly 
relies on sensors spread on land and maritime borders that require connectivity), or RPAS 
(Remote Piloted Aircraft  Systems, e.g. Civil protection operations increasingly rely on such 
unmanned aircraft).  
 
 
- as regards the fact that the current EU satcom assets do not allow to meet these evolving 
needs  
The problem is not about a quantitative gap  between supply and demand (GEO capacity) but 
rather a qualitative one  between new low latency needs (LEO/MEO capacity) and the existing 
EU fleet.  

 
EN             52     EN  
 Initially,  satcom has been relying on geosynchronous (GEO) spacecraft. Technical progress  
has allowed the emergence of non -geosynchronous -orbit (NGSO) communications 
constellations, comprising low -Earth -orbit (LEO) and medium -Earth -orbit (MEO) satellites to 
emerge.  There is not today any EU LEO and MEO operational or project capabilities that 
could meet the evolving governmental user needs.  
Figure 4  page 14 explains these various concepts:  
 
 
b) Evolution of the problem  
- in terms of demand and supply  
On the demand side  the figure herewith provides an overview of the  evolution of EU 
governmental satcom volume  demand :  
 
 
This figure  shows a stark increase  in demand  between the period 2025 -2030 and 2030 -2040 
of more than 100%.  It is to be noted that the technical and security requirements differ for each 
use cases . 
 

 
EN             53     EN  
 Furthermore, a detailed table  on demand per use case has been added as Annex 4 in this 
document.  
On the supply side : 
• the provision of satcom services is a complex interplay between national decisions for 
governmental systems, and decisions of private companies regarding new investments in 
satcom commercial systems;  
• since the Govsatcom market segment is relatively small (compared to the needs of the 
private sector), and none of the EU Member States has sufficient market power to leverage 
fully private solutions, it is unlikely that future EU and Member States Govsatcom needs 
will be spontaneously met by EU private actors;  
• cost modelling analyses performed by ASD Eurospace106 highlight that the magnitude of 
the investment would require a commitment of the public sector to alleviate the risk. 
Industrial stakeholders have also confirmed this assessment of the market107; and final ly 
although some EU Member States have national satcom systems, none of the EU Member 
States is planning to develop a global low latency system in the coming decade.  
As a conclusion on this mismatch between supply and demand, the only way for EU Member 
States and Institutions to meet these emerging needs, should no action be taken at EU level, 
would be to rely on non -EU infrastructure, such as the future US Transport layer, the British 
Oneweb 2, or the Russian Sphera.  
 
- in terms of urgency of the initiative  
The urgency of the initiative is linke d to the following interrelated developments:  
 
• technological progress (as evidenced in section 2.2. of the Impact Assessment) that 
has led to the emergence of low latency solutions  as from 2018/19;  
 
• the emergence of various public -supported or subsidised non -EU mega -constellations  
in the US, China and Russia spurred by this technological progress.  
 
                                                           
106 Trade association of the European Space Industry . Annex 3 – Stakeholders consultation further expands the rationale. 
ASD document available here.  
107 It is worth highlighting that the lack of a ‘technology push’ offer from Industry does not constitute a market failure, but 
rather a logical outcome for such a product that (i) requires several hundred -millions upfront non-recurring cost and (ii) that 
would not be marketable for B2C commercial applications.  
 
EN             54     EN  
  
Number of launched communication satellites, 2010 -2019 (Source: Space Foundation)  
• risk of shortage of available filing and orbital slots due to exponential increase of 
these mega -constellations. As each orbit can hardly support more than one or two 
constellations, the first -comers are better served in terms of positions, bandwidth and 
priority on frequency  use; the others might be prevented reasonable and sustainable 
service operation. Without timely action, the currently available EU filings will become 
obsolete. There is therefore a need to proceed urgently, in order to profit from these 
existing filings.  Figure 8  page 18 illustrates the analysis conducted  on the ITU filing 
database;  
 
 
Figure 8: non GSO filings as of 15 Dec 2021 (source: ITU)  
• in addition the EU available frequency filings  that would allow to establish a LEO 
infrastructure is facing strong attrition  over time . On top, EU Member States  have a 
very limited number of filings compared to other players  as illustrated in the figure 
below 108; and  
                                                           
108 It is to be noted that while taken individually, the number of European filings is limited, it is a significant 
asset would this portfolio of filings be managed at an integrated EU level ,  

 
EN             55     EN  
  
Figure : LEO/MEO filings 2007 -2021(source: ITU)  
 
- the lead time  for the design, development and deployment of a space -based system 
takes several years and needs to be anticipated well in advance. Not all space -based 
services necessary to satisfy our needs can be developed at a moment’s notice.  
 
c) Objectives   
The addi tions and clarifications made above to the problem definition and problem drivers, 
improve the analytical coherence with regard to the objectives as set out in section 4.1 and 4.2 
of the Impact Assessment.  
The improvement is related to:  
 the evolving public needs  notably in terms of quality (low latency);  
 the need for guaranteed access to satcom whilst avoiding any critical dependence on 
non-EU infrastructure that could be detrimental to the integrity, resilience and 
sustainability of the Union’s opera tions.  
 
d) Options  
Further details as regards the choice of the options are provided hereunder point (2). 
e) Criteria for the comparison of options  and monitoring indicators  
Options are compared vis -à-vis: 
o For effectiveness: against policy objectives set  out in  section 3 of the Impact 
Assess ment.  
o For efficiency against the preceding analyses carried out in section 6 of the 
Impact Assessment in terms of economic, social and environmental impacts.  

 
EN             56     EN  
 Table in section 7.1 page 36 below has been reviewed clarifying  the various assessment criteria:  
 
In order to ensure a perfect  correlation between the criteria used for comparison (cf. 
section 7.1 of the Impact Asses sment)  and the monitoring indicators (cf. section 9 of the 
Impact Assessment)  comparison criteria have been systematically flown down into 
monitoring indicators. The followi ng table illustrates this point:  
 
 
 
   
Section 7  
Section 9 
 
EN             57     EN  
 (2) The report continues to assume a predetermined technical solution – without specifying 
it – and consequently artificially limits the scope, design and content of the options to the 
implementation of this predetermined outcome.  
The intervention logic has been signific antly clarified between the first and second submi ssions 
of the impact assessment  to better explain the choice of options.  
The policy options, as considered in the current analysis, address the objective of supplying 
satcom  services. The initiative leverages the work done by Member States, the Commission, 
the EEAS, the European Defence Agency (EDA), and the European Space Agency (ESA)  in 
the elaboration of the High Level Civil Military User Needs for Governmental Satellite 
Communicatio ns document109 (HLUN) . In this respect, satcom is not a predetermined 
technical solution, but the starting point of the problem  definition.  The impact assessment 
does not in particular challenge the conclusions  of the HLUN  by trying to find alternative 
technical ways to meet the fundamental requirements expressed by these end -user 
communities. Its ambition, as it was the case for the Govsatcom impact assessment, is narrower 
and focuses on meeting these needs.  
The approach does not assume a technical solution, and does not specify it:  while the use -case 
needs expressed by governmental end -user communities are converging into a stable set of 
requirements, technical solutions meeting each use -case needs are still  very open.   
Defining options through a limited set of technical scenarios would, paradoxically : 
i. Prejudge that all options necessarily go through the acquisition by the public sector of 
an infrastructure, where maybe buying a series of services from the p rivate sector could 
suffice ; 
ii. Dismiss ex-ante the existence of potential technical innovations that could be brought 
by the private sector, and in particular the startups ecosystem that has emerged in the 
field of low -latency services.  
iii. Dismiss ex -ante the p otential for synergies between governmental services and 
commercial satcom . 
This service -based approach is all the more warranted as satellite communications is an 
established market . Therefore, it is important to identify realistic options where the  public 
investment could be opti mized by profiting from such a well-established  market . 
The situation is different from other EU space initiatives  like Galileo, where in 2012 ther e 
was no functioning market for navigation and positioning services , no exist ing operators for 
such services and no expertise either in the public or the private sector within the EU. This is 
                                                           
109 EEAS(2017) 359 , High Level Civil Military User Needs for Govern mental Satellite Communications  
(HLUN)  
 
EN             58     EN  
 the reason why the EU by deciding to fully fund the programme  analysed the different 
architectural options.  
For the present initiative, such technical implementation questions would in any case have no 
impact on the scope and content of the options  as detailed in the Impact Assessment since 
with regard to the services the question of number of satellites is not relevant , as long as the 
solution  is capable of providing the required services.  
 a) Scope and design  
As explained above, t he satcom market differs significantly from other space segments where 
the EU has already established components of its Space Programme, such as Earth Observation 
under Copernicus and Navigation Services under Galileo.  
To acquire a low latency service, the possible  options  for the EU  are: 
- either to buy off -the-shelf -services;  
- build a EU -owned system; or  
- define, together with Member States and agencies requireme nts tailored for each use case and 
ask the private sector to offer technical solutions .  
This is further illustrated in the following figure:  
 
 
In the options where the Commission  would  buy a service  (and thus where the private sector 
has to reflect upon the best architectural approach to meet public sector demand), the 
assessment of any architectural trade -off is irrelevant.  

 
EN             59     EN  
 The policy options should not be considered as mere ‘implementation modes’ of  a same 
‘predetermined technical solution ’. On the contrary, the technical outcome of each policy 
option would, by construction, be very different , for example, between:  
 Option 1: A fully public -owned constellation, emitting only in governmental frequency 
band, dimensioned to meet , on a standalone basis , peak governmental demand , and thus 
requiring a high number of satellites, mostly unused outside of peak times  
 Option 3: A privately -owned constellation, comprising a limited number of 
governmental payloads,  emitting in various bands, able to divert non -critical 
governmental demand (e.g. humanitarian aid, some civil protection applications that do 
not require high security requirements) through commercial payloads during peak 
times ,  
During the procurement pr ocess  of the concession,  the Commission will express a 
requirement for a service, defined in terms of coverage, latency, throughput, etc.  The applicants 
will propose  services and will present  technical/architectural designs  to demonstrate that they 
are in position to deliver such service . The Commission will evaluate these various 
architectural proposals  only against their ability to meet its service requirements . The 
architectural proposal will also allow to identify those assets that are essential, notably from 
a security point of view, to ensure proper provision of the governmental services and that 
should, therefore, be owned by the Union.  
The added value of a concession is that it offers also the opportunity to create a considerable 
amount of benefits through commercial services,  and at the same time, to mutualise 
capabilities with a governmental system that, alone, would be significantly more expensive and 
would not create any direct socio -economic benefits.  
This concession scheme could permi t to build upon  the existing EU satellite communication 
technological and infrastructural base and to provide robust and innovative governmental 
services, while allowing the private partner to complement the governmental infrastructure 
with additional capa bilities to offer commercial services including through its own 
investments.  
Such a scheme would furthermore optimise the costs by sharing development and deployment 
costs on components common to both governmental and commercial infrastructures, as well a s 
operational costs by allowing a high level of capacity mutualisation.  
Finally, it would stimulate innovation  in particular for New Space by enabling the sharing of 
research and development risks between public and private partners.  
b) Content  
As regards  the content of the options, it is noteworthy to clarify the following points:  
- as to the relationship between capacity and costs  
 
EN             60     EN  
 What is the same in options 1 (full public) and 2 (concession scheme) is not the total capacity 
of the system but the Union’s d emand for governmental services. To that end it should be 
clarified that although the  Union demand is the same for option 1 and 2 , the cost for the 
Union is different for each option as set out in Table 3  page 29 herewith.  This is due to the 
fact that in option 1 the Union finances the entire infrastruct ure; whereas in option 2 there is 
optimisation of  the costs by sharing development and deployment costs on components 
common to both governmental and commercial infrastructures, as well as operational costs by 
allowing a high level of capacity mutualisation.   
 
 
It is to be noted that CAPEX cost for a stake in a non -EU constellation is not quantified because 
of the various parameters to take into account : 
i. Identify  a constellation potentially for sale  and determine a target price for Equity (as 
well as special rights that would allow the Union to preserve its essential security 
interest110), notwithstanding the ability of the Union to acquire shares of a private 
company that, moreover,  would be established in a third -country.111 
ii. Quantify the required CAPEX to  
a. Transfer selected  ground control and security assets  within the EU  
b. Buy robust satellites allowing the provision of governmental services  
 
- as regards the management of the uncertain ty of government ’s de mand  
It should be noted that the uncertainty of governmental demand for capacity needs is to be 
managed at two levels:  
- firstly at the level of governmental request for capacity;  
                                                           
110  Such as a so -called ‘golden share’ mechanism that would allow the public sector to veto Board decisions that could be detrimental to the 
Union’s interests . 
111 In a similar situation regarding the potential establishment of an EU -owned private company to m anage the Galileo system during its 
exploitation phase,  an analysis (see SEC(2011) 1446 final  p. 48) concluded that ‘the creation of an EU public enterprise will likely require 
putting in place a specific branch of EU law, a task that would need many years to be accomplished’; 
 

 
EN             61     EN  
 - secondly at the technical level, i.e. the sizing of the system.  
As regards the first point, an Implementing Act  will be foreseen under the proposed legislative 
proposal which will deal with the question of capacity sharing and prioritisation. In other 
words, basic rules will be established under which circumstances Member States can require 
additional capacity beyo nd their estimated average capacity needs. Should Member States 
during a certain period require less capacity than their average capacity needs, this could then 
be given to Member States who require during the same period of time higher capacities than 
their average needs. Should there be overall a higher request for capacity than available, then 
a prioritisation mechanism based on objective criteria (e.g. date of the request, volume request, 
etc.) would ensure a fair allocation of capacity between Member S tates.   
Regarding the commercial services there is no need for an Implementing Act, as these will be 
defined by the private sector  under the concession scheme. T he Commission should retain the 
right to assess such services to ensure that the Union’s essential interests in terms of security 
and market competition  are preserved.  
As regards the second point, at the technical level, the following differentiation can b e made 
between the different options:  
Option 0:  
As this option does not allow for the provision of low latency services. The question of 
uncertainty of governmental demand is thus not relevant.  
Option 1:  
A fully public infrastructure would need to be sized  at the peak capacity needs of Member 
States. It would require a strict sharing and prioritisation mechanism.  
Option 2:  
A concession scheme would allow for flexibility  through capacity mutualisation and ease the 
question of sharing and prioritisation.  
Option 3:  
Depending on the shareholder agreement reached, flexibility through capacity mutualisation 
could be envisaged.  
- as regards third party access which is specific to Option 2:  
An adequate mechanism should be foreseen in the concession contract to al low other EU 
telecom operators to use a share of the commercial capacity; and  
 
EN             62     EN  
 Adequate safeguards should be foreseen to avoid any overcompensation of the contractor, 
distortions of competition, any conflict of interest, undue discrimination and any other h idden 
indirect advantages.  
- as regards allocation of liability which is specific to Option 2:  
Under the concession contract will be foreseen the allocation of liability for loss and damages 
to assets (and related insurance approach) as well as for service provision, with relevant 
possible limitation of liability as necessary to ensure the financial viability of the contract . It is 
intend ed thus to implement a similar approach as the one chosen for the Galileo and EGNOS 
operations’ contract.  
- as regards the procurement process for the concession award which is specific to 
Option 2:  
The procurement process  would be carried out in accordance with Ti tle VII of the Financial 
Regulation, ensuring fair and open competition.  In developing the procurement documents, 
several key principles should be addressed in order for the concession contract to:  
• define a clear distribution of tasks and responsibilit ies between the partners;  
• ensure an appropriate prioritisation of governmental user needs;  
• the approach to access/exploitation of the infrastructure components, in particular 
security -related components  
• allow the provision of commercial services to be defined by the private sector; the 
Commission should retain the right to assess and approve such services to ensure that 
the Union’s essential interests and Programme’s objectives are preserved and adequate 
safeguards are put in place to prevent distortions of competition and avoiding any 
overcompensation of the private partner;  
• define the financing scheme proposed in terms of split between the required public 
sector investment (either in kind or through ava ilability payments), the offered private 
sector investment (either in cash or in kind);  
• define the ownership regime of the assets, implementing a clear distinction between 
assets to be owned by the Union and assets to be owned by the contractor.  
In order t o ensure the New Space involvement  in the initiative, the procurement should 
elaborate criteria for the award of the concession ensuring the participation of start -ups and 
SMEs along the whole value chain of the concession, hereby incentivising the develop ment of 
innovative and disruptive technologies. New Space stakeholders have demonstrated their 
innovative ideas for the initiative, and the following two studies on ‘New Space solutions for 
long-term availability of reliable, secure, cost effective space b ased connectivity building on 
GOVSATCOM’ enabled the Commission to leverage these early ideas. The outcome of these 
studies inputs should be duly considered when drafting the procurement documents.  
 
EN             63     EN  
 The procurement should reinforce the non-critical dependen ce of the EU in technological 
terms, and ensure compliance with requirements related to security, service continuity and 
reliability by inserting them as minimum requirements or award criteri a in the tender 
documentation.  
The Commission should ensure effe ctive and transparent competition by continuing spreading 
awareness of the procurement within the limits of the Financial Regulation.  
- as regards security governance  
The process set out in the Space Regulation  will be followed. In terms of steps, this requires 
that first, a threat and risk analysis is being undertaken, on which basis subsequently general 
and specific security requirements will be developed and finally flown down to the concession 
contract.   
This governance scheme applies to all options, except option 3 where  the Union would have to 
request that some adjustments are brought to the system architecture (such as geographical 
footprint of the Ground System, software development and validation approac h, cybersecurity 
approach). These adjustments would need to be sufficient to allow a security accreditation in 
line with the provisions of the Space Regulation . 
 
(3) The report does not contain any timescale for the initiative nor does it identify where th e 
necessary funding would come from.  
a) Timescale  
The secure connectivity initiative would be implemented according to the following main 
milestones under the assumption that the legislative act will be adopted by end of 2022/ early 
2023 by the co-legislator:  
 2023: Award of the c oncession  contract  
 2023 -2027: Development and deployment of the infrastructure  
 2024-2025: Provision of first low latency services  
 2027: Provision of full portfolio of services  
 
In the course of 2022, the inter -institutional legislative process will be carried out, which should 
lead to the adoption of the Regulation by the end of the year/ beginning 2023, based on a 
Commission’s proposal adopted by February 2022.  
In the meanwhile , preparatory steps that will lead to the award of the concession contract would 
start already in the first half of 2022. This phase is expected to be completed by 2023.  
The technical work for the system implementation will commence at the signature of the  
concession contract. This will entail the development and validation phases for both the space 
 
EN             64     EN  
 and the ground segments, to be carried out in the period 2023 -27. The initial services based on 
the new infrastructure (with low -latency services) can be provid ed by end of 2024/ early 2025, 
and the full portfolio of services (with the integration of the quantum capability) can be 
available in 2027 (see picture below).  
 
 
b) Funding  
Regarding the funding sources , these are as follows:  
- Baseline: 100% EU funding  
- Full public:  100% EU funding  
- PPP:  The cost sharing that will be defined in the context of the negotiation of the 
concession contract. It is envisage d to have recourse to  a blending of various budgetary 
sources stemming from:  
o the public sector (2/3) to cover the investment for the governmental service 
component via EU budget and national funding (either through ESA or national 
budgets, or in kind contributions);  
o the private sector (1/3) investment to leverage the commercial service 
component.  
 
- Stake in N on-EU constellation. The Union would fully finance the acquisition of shares.  
In this baseline option (Option 0) , the funding of the initiative be would be entirely covered 
by a financial contribution by the Union (100% EU funding). In this case, the funding has been 
already allocated to the GOVSATCOM component of the EU Space Programme in the current 
Multi -annual Financial Framework (2021 -27). 
In Option 1 (Fully Public) , the funding will also be provided entirely by the Union. In this 
case, however, t he allocation of funds in the current MFF would not allow sufficient financial 
resources to support entirely the envisaged cost of the infrastructure for the secure connectivity 
system; Member States’ contribution is also unlikely to reach the amount neede d to finance the 
system.  
In the Option 2 (Public -private -partnership: EU Concession) , the funding would be covered 
by a financial contribution by the Union, the Member States (possibly through ESA) as well as 
private sector investment. The precise financia l scheme and the cost sharing between the public 

 
EN             65     EN  
 and the private parties will be defined in the context of the negotiation of the concession 
contract. The EU budget and national funding would finance the governmental service 
provision and contribute to the  development and validation activities, while the private 
sector would be called to finance the commercial service provision.  Therefore, a blending 
of various budgetary contribution s can be envisaged, in accordance with the following 
principle:  
 Public sec tor w ould cover the investment for the governmental service component, for 
around two thirds of the total cost of the system. Part of the funds would  be provided 
via the EU budget , and part would be provided by Member States national funding, 
either throug h ESA or national budgets. In -kind contributions from Member States 
would also be possible.  
 The private sector would invest to leverage the commercial service component, 
contributing to one -third of the total cost of the system.  
In Option 3 (Stake in Non -EU constellation) , the Union would fully finance the acquisition 
of shares. In this case, the Union would need to conclude an agreement where it would take an 
equity stake in one of the entities controlling the non -EU constellation. The instrument to be 
used by the Union to buy and detain corporate shares remains to be defined, and the funding 
sources for this operation are not defined.  
 
(4) The impact analysis is incomplete as it continues to lack clarity on methodological 
assumptions and validity of secondary data cited and broadly employed for the economic 
estimates, benchmarks and multipliers in relation to the present initiative.  
 
The methodological approach followed in essence the one used in the Govsatcom  
component’s  impact assessment:  The econom ic impacts were based on the costs associated 
to the options, the impact on Gross Value Added (GVA) and jobs created . The expenditures  
were injected in an input – output model (World Input Output Database – WIOD  2016 
release112 adjusted with Eurostat 2018 Input Output ), leading to an estimation of direct, 
indirect and induced impacts. The expenditure  considered include the total CAPEX, the 
OPEX and service costs . The use of the findings accumulated on Govsatcom is relevant : the 
same value chain is addresse d. 
In option 3, the GVA of additional commercial services  is calculated separately using a 
distinct model developed for the purpose of assessing the impact of broadband  using the 
                                                           
112 Timmer, M. P., Dietzenbacher, E., Los, B., Stehrer, R. and de Vries, G. J. (2015), "An Illustrated User Guide to 
the World Input –Output Database: the Case of Global Automotive Production" , Review of International 
Economics ., 23: 575 –605 (link to 2016 release ) 
 
EN             66     EN  
 multiplier relying on an econometric model developed by the International Telecommunication 
Union.  
 Our methodological choice is to measure benefits only within the EU. In this context, several 
evidences tend to demonstrate that space downstream activities emerge preferably close to the 
upstream ecosystem. An example stemming fr om the satellite navigation field illustrates this: 
while GPS has been accessible to civilian use since 1983, location -based services have thrived 
in the EU only after the start of the deployment of Galileo. The EU satellite navigation market 
has grown fro m EUR 27bn in 2009 to EUR 675bn in 2019, reaching a market share comparable 
to the US113. 
 
As it can be expected, the overall costs and the impact on GVA and jobs creation are directly 
proportional. The lower the overall expenses for procurement of SatCom services are, the lower 
the economic benefits of the option are.  
It is to be noted that the overall GVA impact  of option 3 would be  an increase between 25 and 
33 billion euro. Compared to the total EU economy of about 13 400  billion euro114) this is an 
extremely small effect  (+0.2%) . The case for public intervention remains primarily  to provide 
the Union and Member States with tools to increase the resilience of governmental operations.  
The positive economic impact is a welcome side effect, but not the main driver of the initiative.  
As regards the environmental data  used, further more detailed explanations as to the relevance 
of the study used, as well as additional calculations can be f ound below (cf. point 5).  
(5) The report does not specify how the increased greenhouse gas emissions generated by 
the initiative would be compatible with the objectives of the Climate Law.  
                                                           
113 GSA Market Report 2010 and Market Report 2019.  
114 Eurostat  2021  

 
EN             67     EN  
 The environmental impact s of the initiative can be measured on the  emissions relating to the 
development and deployment of the infrastructure (point a)) and the positive environmental 
impacts stemming from the use of the services (point b)).  
a) Environmental impacts of building and launching infrastructure  
Launching a satellite communication system would inevitably have an impact on the 
environment, particularly due to the environmental footprint related to the manufacturing and 
launching of the system infrastructure. In this regard, Options 1 and 2 are expe cted to have 
the similar environmental impact . There is for the time being no technologies that would 
allow the space industry to be carbon neutral. However, c ompared to other industry sectors, 
the manufacturing of spacecraft does not  emit significant gree nhouse gases emissions115. Using 
the metrics developed in a 2020 PWC report ‘Analysis of the Environmental Impact of the EU 
Space Programme’, it is estimated that deploying and maintaining a constellation over 20 years 
could generate 5 Mt CO2, i.e  0,25 MT p er year , which would represent 0.0008% of 2020 
emissions . However, the precise estimation would be determined by the size and weight of the 
constellation.   
The number of satellites may be bigger in this initiative (around 200 satellites) than in Galileo 
(30 satellites) or Copernicus (8 satellites), however satcom satellites have a comparably smaller 
size and mass, which means that they can be launched in larg e groups, hereby reducing launch 
emissions.  The envisaged deployment strategy considers  9 launches for full operational 
capability, compared to 12 launches for Galileo and 8 for Copernicus.  
 
PWC (2020) Analysis of the Environmental Impact of the EU Space Programme  
 
                                                           
115 Eurostat Manual of Supply, Use and Input -Output Tables (2008)  

 
EN             68     EN  
 Option 0 would not have a further environmental impact, as it relies only on existing 
satcom capacities. Option 3 would have a lower impact than Options 1 and 2 , for those third 
country owned LEO constellations that have already launched an initial set of satellites 
allowing them to provide initial services. However, Option 3 would have a higher impact than 
Option 0, as these third country owned LEO constellation s have not yet achieved full 
operational capability and require further launch of satellites.  
Satellites  in orbit create a risk for long -term environmental harm, due  to its potential of creating 
additional space debris, either at their end -of-life or due to a technical failure. To mitigate the 
impact on the space environment, Options 1 and 2  would  comply with the international 
standards on the protection of space environment  (e.g. the Committee on the Peaceful Uses 
of Outer Space (COPUOS) and Inter -Agency Space Debris Coordination Committee (IADC) 
Space Debris Mitigation Guidelines), as well as the existing national legislation (e.g. the French 
LOI n° 2008 -518 relative aux opérations spatiales116). Further, an EU built system would  also 
comply with existing EU environmental regulations, such as REACH regulation117 and the 
EU Directive on Hazardous Waste118. Reducing th e debris  risk with voluntary adherence to 
international debris mitigating standards is challenging in the case of owning a stake in foreign 
constellation (Option 3).  
Finally, it should be noted that the size of the envisaged the Secure Connectivity constellation 
is not comparable to US and UK constellations (over 10 000 for Starlink in final configuration, 
650 for Oneweb, vs a maximum of 200 satellites in the heaviest architecture scenario currently 
contemplat ed by industry).  
b) Environmental benefits of the services  
The initiative has similar positive contribution towards environmental objectives as the Galileo 
and Copernicus components of the Space Regulation119. The PWC study showed that the 
environmental bene fits stemming from the use of the components is approximately 2 
orders of magnitude higher than the environmental footprint generated by the 
construction , deployment (including the launches and the production of launchers) and 
use over the complete life ti me (22 years) of these systems.  Out of the 20 positive impacts 
identified by in the study, secure connectivity could contribute to 16 of them: for example, in -
situ sensors monitoring marine environment rely today on radio to transmit data, requiring 
                                                           
116 LOI n° 2008 -518 du 3 juin 2008 relative a ux opérations spatiales  
117 Regulation (EC) No 1907/2006 Of The European Parliament And Of The Council of 18 December 2006 
concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a 
European Chemicals Agency, amending Directive 1999/4 5/EC and repealing Council Regulation (EEC) No 
793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and 
Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC  
118 Council Directive 91/689/EEC of 12 December 1991 on hazardous waste  
119 Note that even though of the number of satellites are bigger in this activity than in Galileo or Copernicus, the 
small size and mass of the satellites coupled with the possibility to launch them in groups of large numbers (e.g. 
from 12 to 36 satellites in one launch) results in relatively comparable footprint evaluation . 
 
EN             69     EN  
 signif icant energy and thus heavy (and toxic) batteries. A low -data rate (“IoT”) solution would 
enable smaller, energy efficient in -situ sensors. See figure 11 of the benefits to impact 
comparison .  
 
 
 
Figure: PWC (2020) Analysis of the Environmental Impact of the EU Space Programme  
In addition, t he infrastructure will provide communication through space, hereby avoiding the 
deployment of ground networks, submarine cables, high power cables or fibres (buried in the 
ground or above the ground). No significant har m will therefore be done to the sustainable use 
and protection of water and marine resources. Satcom services for maritime surveillance 
supports pollution detection and response environmental monitoring.  In addition, minimising  
environmental risks to a lar ge extent relies on data monitoring. Monitoring data like water 
levels, land cover change, ice sheet elevation, and ice sea thickness will become even more 
important and require larger quantities of data being transmitted. The initiative could help to 
relay data from Earth Observation satellites (such Copernicus) to ensure high -speed delivery 
of time -critical data to be better prepared, inform citizens, and take action. The services 
provided by a space -based secure connectivity infrastructure are also expec ted to provide the 
communication channels for autonomous vehicles, thus resulting in more energy efficient road 
transport.   
Where the private industry choose to exploit the system for commercial services (potentially 
Option 2 and 3), low -latency broadband  can be beneficial for the environment. For example, 
smart systems creates energy efficiency by enabling households to have better understand and 
control their energy management, precision farming can increase input use efficiency and 
reduce emissions,  and IoT applications can be used to track wildlife extension.   
 
 

 
EN             70     EN  
  
 
Stakeholders’ views, including dissenting views, – particularly those of  
Member States (who will provide the funding) and SMEs and potential disruptive  
innovators (who will provide the technol ogical  input) are still not reflected . 
 
Stakeholders views are extensively reflected in the problem definition, as well as regarding 
their views on the possible options. Some additional insights and potential orientations are 
furthermore given by governmental stakeholders regarding the implementation of the preferred 
option.  
a) Problem definition  and objectives  
As far as demand  is concerned, t he governmental satcom use cases have been defined in a 
joint work with Member States, the EEAS, the European Defence Agency, with the support of 
the European Space Agency  by consulting Member States and EU Satcom end -user 
communities. The evolving needs for improved latency , data rate, and other features of the 
services to be provided are b eing updated within a classified study that consults EU Member 
£Stes governmental user capacities on the technical features of their demand.120. There is 
overall a consensus of Member States and end -user communities on the fact that these new 
evolving needs should  be met, and confirm the increasing governmental needs for guaranteed 
access to secure satcom.  
On the ways to meet these demands , while there is not yet an aligned view on a single solution, 
several attention points  have been highlighted : 
 Several Member States have stressed that t he principles established for EU 
GOVSATCOM should remain: for uses that can cope with less stringent latency needs, 
the future Secure Connectivity solution should also rely on existing Member States' 
and commercial satcom assets and capaciti es. New development activities should 
focus on complementing gaps and missing links . In particular, several Member States 
have stressed the need to cover gaps that are alrea dy known , such as the coverage of 
the Arctic.  
 A similar view is expressed by  the French Air and Space Academy  that considers that 
‘For all services considered as essential for a sovereign and secure European 
communication system, the GEO infrastructure meets and will continue to meet needs 
where there is no stringent requirement as to latency or Polar Regions / global 
coverage. ’121 
                                                           
120 Excerpts of ENTRUSTED study first outcomes are shared in a classified note.  
121 Académie de l’Air et de l’Espace (2021) – AAE Opinion n°12 on European Secure Conne ctivity  
 
EN             71     EN  
  Consequently, several Member States stress the fact that the capacity of the future 
system nee ds to be adequately sized . This sizing should be carried out in a joint 
technical work with Member States. Other Member States have asked that the technical 
synergies with new National initiatives  are assessed.  
 Several Member States suggested that the system should be scalable and flexible  
enough to adapt to evolving demand . 
 One Member State highlighted the need for the system to be able to work together with 
governmental terrestrial infrastructures  and another asked about the potential 
interoperability with foreign constellations.  This need is also h ighlighted by the French  
Air and Space Academy  for which ‘ The envisaged EU infrastructure should be doubly 
inclusive: a) working alongside and blending with the terrestrial infrastructure; b) 
integrating European private actors, companies and operators. It  is important not to 
squeeze out the private market but rather to encourage new agile players, such as 
startups and SMEs, to participate. ’  
 Industry players  have highlighted the need for a significant commitment of the 
public sector  to build such a solutio n: Some governmental needs cannot be met by 
commercial off -the-shelf solutions and will require bespoke technical developments. 
To venture into these capital -intensive activities, the private sector needs an assurance 
on the long -term commitment of the Uni on to buy the services.  
 Most Member States have highlighted the necessity to ensure a strong involvement of 
NewSpace enterprises  in the setup for service provision.  
 Several public and private stakeholders have highlighted the urgency , having in mind 
the progress and advance of non -EU public a  nd private projects  
 
b) Available policy options  
 Several Member States supported the concession option , reminding that the Space 
Regulation already foresaw that scheme to be adequate to compelement Govasatcom.  
The fa ct that several Member States have used a public -private partnership scheme to 
launch their national govasatcom infrastructure has been recalled.  
 In particular, this scheme allows for a flexible technical solution  and for incremental 
developments , leveraging existing assest and technical synergies, which also allows for 
technical evolutions to meet new service needs.  
 However, these Member States have also highlighted the fact that a successful 
implementation of a public -private partnership scheme  entail pre -requisites  that the 
Commission should consider in terms of roles and responsibilities, in particular on 
security and technical trade offs.  
 One Member State has highlighted that priority setting rules between governmental 
and commercial objectives  should be clear . 
 One Member State suggested that the use cases for governmental and commercial 
services should be split , with the former being fully public and the latter fully private.  
 
EN             72     EN  
 This Member Stated stressed the importance of including lessons learn ed from Galileo 
and its first attempt at a concessionaire  
 A Member State stressed the need for a civilian solution under civilian control , 
although military users might use the system for their non -Milsatcom needs.  
 Most Industry stakeholders have favoured the Concession option  (See Annex 2  for 
details ). Very few see the possibility of a pure private solution. The Trade  association 
of the European Space Industry  shared an economic analysis further explaining why 
the profitability of such a constellation coul d not be sustained only by commercial use 
cases.  
 Non EU satcom operators have also highlighted the attractiveness of a solution relying 
on non-EU constellations . A partnership with non -EU constellations (in the form of 
interoperability) is partially supported by some EU operators as long  as this partnership  
is limited to commercial use -cases.  
 
Most of these stakeholders’ views have been incorporated in the text of this second version, in 
particular in sections:  
 2.2.2 Evolving nature of se cure governmental satcom needs  – on the evolution of 
needs (global coverage, latency)  
 2.4 How will the problem evolve?   
 7. How do the options compare  
 8.1 Concession as the preferred option  
 
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 Overview of how the five main and eight specific comments (C1-C8) of the Regulatory Scrutiny Board (RSB) in its 2nd  opinion have been addressed  
RSB comments  Report revisions  
1) There is still no analytical coherence between the problem definition, objectives, options, criteria for the comparison of options and the definition of future monitoring 
indicators.  
C1 Building on the clearer scope of the 
initiative, the report should create a more 
consistent intervention logic.  
 
First, it should link the governmental 
needs and use cases identified in a 
general way at the beginning of the report 
with the subsequent analysis. The report 
should demonstrate how the specific 
needs analysed in the problem definition 
(e.g. push for autonomous tran sportation, 
machine -to-machine and internet -of-
things considerations, and access to 
frequencies) reflect the general use cases.  
  Traditionally, satcom has been used for voice communication and data transfer in remote areas (e.g. at sea), but the nature 
of use cases is rapidly evolving, driven by both technological developments and geopolitical shifts.  
 Machine to Machine (M2M) and Internet of Things (IoT)  
 Move towards autonomous transportation and Remote Piloted Aircraft Systems (RPAS)  
 Increased global co verage needs:  
 
Table  1 page 13 provides a visual synthesis of  the above linkages . All identified use -cases are affected for instance by 
Machine -to-Machine (e.g. border surveillance increasingly relies on sensors spread on land and maritime borders that 
require connectivity), or RPAS (e.g. Civil protection operations  increasingly rely on unmanned aircraft)  
 
It is important to note that the issue of frequency is not driving a change in user needs  but it is an essential condition 
to be able to secure future satcom capabilities. The attrition of EU MS frequency portfolio is a factor driving the urgency 
to act now.  
 Second , the problem definition should 
clearly demonstrate the issues associated 
with using non -EU satellite 
infrastructure, thus justifying the 
inclusion of a specific objective on 
autonomous solutions.   Connectivity gap cannot be adequately addressed through a non -EU solution  since Member States and EU 
Institutions require, for gover nmental needs, a guaranteed access  in an unrestricted manner to secure connectivity 
services without soliciting the assent of a third party.  
 
It should thus be avoided that EU governmental operations could be disrupted by a unilateral decision of a third public 
or private party.  Therefore, any critical dependence on non -EU satcom infrastructure would be detrimental to the 
integrity, resilience and sustainability of the Union’s operations.  
 
 Third, the options should address the 
identified problem and prob lem drivers 
and be coherent with them. In particular, 
there is an apparent contradiction 
between the assumption in the options 
that there is supply of the necessary 
satellite services, and the argument in the The problem is not about a quantitative gap  between supply and demand (GEO capacity) but rather a qualitative one  
between new low latency needs (LEO/MEO capacity) and the existing EU fleet.  
 
Initially, satcom has been relying on geosynchronous (GEO) spacecraft. Technical progress has  allowed the emergence 
of non -geosynchronous -orbit (NGSO) communications constellations, comprising low -Earth -orbit (LEO) and medium -
Earth -orbit (MEO) satellites t o emerge. There is not today any EU LEO and MEO operational or project 
 
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 problem description that there is 
insufficient supply.  
 capabilities that could meet the evolving governmental user needs.  Figure 4  page 14 below explains these various 
concepts  
 Finally , the analysis should be more 
consistent between the criteria used for 
the comparison of options and the 
monitoring  indicators . We ensured an identical correlation between the criteria used for comparison (section 7.1) and the monitoring 
indicators (table 8)  by flowing down systematically comparison criteria into monitoring indicators. The following table 
illustrates t his point.  
 
Assessment criteria  have been  further clarified in this annex.  
 
C2 When discussing how the current EU 
satellite assets are insufficient to meet the 
evolving government needs, the problem 
description should contain a more 
specific analysis of e xpected future supply 
and demand trends and explain and 
analyse the drivers behind the lack of 
supply.  A figure on the evolution of EU governmental satcom volume demand has been added in this annex.   Furthermore, a 
detailed table on demand per use case has been added as Annex 4 in this document.  
 
It should be underlined that the problem is not about a quantitative gap between supply and demand but rather a 
qualitative one  between new low latency needs and the existing EU fleet.  
 
- On the demand side, the classified note accompanying the impact assessment provides further information on 
how MS qualitative requirements are evolving over time.  
 
- On the supply side :  
o the provision of satcom services is a complex interplay between national decisions for governme ntal 
systems, and decisions of private companies regarding new investments in satcom commercial systems;  
o since the Govsatcom market segment is relatively small (compared to the needs of the private sector), 
and none of the EU Member States has sufficient market power to leverage fully private solutions, it is 
unlikely that future EU and Member States Govsatcom needs will be spontaneously met by EU private 
actors;  
o cost modelling analyses performed by ASD Eurospace122 highlight that the magnitude of the invest ment 
would require a commitment of the public sector to alleviate the risk. Industrial stakeholders have also 
confirmed this assessment of the market123; and finally  
o although some EU Member States have national satcom systems, none of the EU Member States i s 
planning to develop a global low latency system in the coming decade.  
                                                           
122 Trade association of the European Space Industry . Annex 3 – Stakeholders consultation further expands the rationale  
123 It is worth highlighting that the lack of a ‘technology push’ offer from Industry does not constitute a market failure, but rather a logical outcome for such a product that (i) requires several 
hundred -millions upfront non -recurring cost and (ii) that would not be marketable for B2C commercial applications.  
 
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EN      EN 
  
 It should further explain the evidence -
based rationale and urgency for the 
initiative, which seems accelerated 
compared with the timing of the two 
phases of the governmental satellite 
communication (GOVSATCOM) 
deployment.  
 Urgency for the initiative is mainly due to:  
 
- technological progress  (as evidenced in section 2.2.) that has led to the emergence of low latency solution s as 
from 2018/19;  
 
- the emergence of various public -supported or subsidised non -EU mega -constellations  in the US, China and 
Russia spurred by this technological progress;  
 
- risk of shortage of available filing and orbital slots due to exponential increase of these mega -constellations. 
As each orbit can hardly support more than one or two constellations, the first -comers are better served in terms 
of positions, bandwidth and priority on frequency use; the others might be prevented  reasonable and sustainable 
service operation. Without timely action, the currently available EU filings will become obsolete. There is 
therefore a need to proceed urgently, in order to profit from these existing filings. Figure 8  page 18 in section 2.4 
illustrates the analysis we conducted on the ITU filing databas e;  
 
- in addition the EU available frequency filings  that would allow to establish a LEO infrastructure is facing strong 
attrition  over time. On top, the EU has a very limited number of filings compared to other players as illustrated 
in the figure below;  
 
- the lead time  for the design, development and deployment of a space -based system takes several years and needs 
to be anticipated well in advance. Not all space -based services necessary to satisfy our needs can be developed 
at a moment’s notice.  
 
C3 The problem description should explain 
the link between the European Quantum 
computing infrastructure initiative and 
the need for EU government satellite 
infrastructure. It should clarify, in 
particular, why quantum key distribution 
cannot happen through secur e land 
communication or through private 
satellites, and whether key distribution 
through satellites would not depend on The Quantum communication infrastructure EuroQCI is based complementary on a ter restrial and a space component.  
The terrestrial infrastructure will allow covering distances in the range of few hundreds of kilometers. It will be based on 
Quantum Key Distribution (QKD) nodes linked via optical fibres. Although very secure from a cyberse curity point of 
view, such infrastructure could still be subject to physical attacks on the terrestrial links themselves (i.e. damaging optic al 
fibres) that would make the service unavailable.  
 
The space component allows covering very large distances that are not possible to attain today in absence of quantum 
repeaters. Once these devices will become available, still, some very large distances would be too costly to cover through 
ground links, so the space links will remain preferred. Also, the space infras tructure will allow reaching remote/isolated 
sites all around the globe and specific EU sites that could be located in non -trusted territories such as embassies, etc.  
 
76 
EN      EN 
 land communication for at least part of 
the connection.   
Even if both terrestrial and satellite quantum key distribution infrastructures will be  interlinked, they will be designed so 
that they function independently: the availability of the space -based QKD service would not be impacted by unavailability 
of the terrestrial QKD.  
 
The use of private satellites is not considered compatible with the hi gh security requirements, because the satellite 
itself should be trusted as it generates (or has access to) the cryptographic keys.  
 
C7 The comparison of effectiveness of 
options should stem logically from the 
preceding analysis. Moreover, the 
measures used under each of the 
comparison criteria (e.g. security 
accreditation, quantum key distribution 
payloads, etc.) should be explained, 
allowing for clear comparability and 
more straightforward identification of the 
preferred policy option.   Options are comp ared vis -à-vis: 
o For effectiveness: against policy objectives set in section 3.  
o For efficiency against the preceding analyses carried out in section 6 in terms of economic, social and 
environmental impacts.  
 
 The various assessment criteria have been clarified in this annex  
 
 
 
(2) The report continues to assume a predetermined technical solution – without specifying it – and consequently artificially limits the scope, design and content of the 
options to the implementation of this predetermined outcome.  
C4 The report should provide a wider set of 
policy options or explain why policy 
choices are limited to the modes of 
implementation of the initiative, leaving 
aside options pertaining to system 
architecture or scope.  The logic for our policy opt ions follows a service -based approach  and not an infrastructure -based one. To acquire a low 
latency service, our options are:  
- either to buy off -the-shelf -services;  
- build our own system; or  
- co-invest.  
 
 
The policy options to consider do not go through building an ex -nihilo infrastructure  (with potential architectural trade -offs, 
as it was the case for Galileo), but consider how the satcom ecosystem could address the gap in the provision of low latency 
secured services.  
 
Therefore we assess:  
 
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EN      EN 
 i. whether the public or private sector can provide these secure accredited services based on their current capacity 
(Option 0 – Baseline, or Option 3 – from foreign market providers); or  
ii. whether the EU needs to ensure the provision of these services by either  
a. procuring its own system (Option 1 – Fully Public); or  
b. establishing a public -private partnership (Option 2: Public -private -partnership: EU Concession).  
 
In the options where we woul d buy a service  (and thus where the private sector has to reflect upon the best architectural 
approach to meet public sector demand), the assessment of any architectural trade -off is irrelevant.  
 
During the procurement process  of the concession, the applic ants will propose technical/architectural designs. The 
Commission will evaluate these proposals against their ability to meet service  needs.  
 
However, when assessing the options, it becomes clear that the concession scheme offers also the opportunity to create a 
considerable amount of benefits through commercial services, and at the same time, to mutualise capabilities with a 
governmental system that, alone, would be significantly more expensive and wou ld not create any direct socio -economic 
benefits.  
 
This concession scheme could permit to build upon  the existing EU satellite communication technological and infrastructural 
base and to provide robust and innovative governmental services, while allowing the private partner to complement the 
governmental infrastructure with additional capabilities to offer commercial services including through its own investments.  
 
Such a scheme would furthermore optimise the costs by sharing development and deployment co sts on components common 
to both governmental and commercial infrastructures, as well as operational costs by allowing a high level of capacity 
mutualisation.  
 
Finally, it would stimulate innovation  in particular for New Space by enabling the sharing of r esearch and development risks 
between public and private partners.  
 
 In particular, it should explain why the 
capacity (and cost) of the system would 
be the same under the fully public option 
and the public private -partnership 
option.  What is the same in  options 1 (full public) and 2 (concession scheme) is not the total capacity of the system but the Union’s 
demand for governmental services. To that end, the cost for the Union is different for each option as set out in Table 3  
page 29 in section 6.1.1.  
 
In other words, the costs are based on the same Union’s demand for govern mental services, no matter whether it concerns 
option 1 or option 2.  
 
 
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  As to the content of the policy options, the 
report should be more explicit with 
regard to funding (from EU, Member 
State and private sources), third party 
access regime for commercial services, 
liability as regards joint assets (e.g. 
satellites), governance and security 
aspects, explicitly explaining which 
decisions need to be taken now, which in 
the future, what they will depend on and 
what actions they will require.  
 Regard ing the funding sources , these are as follows:  
 
- Baseline: 100% EU funding  
- Full public:  100% EU funding  
- PPP:  The cost sharing that will be defined in the context of the negotiation of the concession contract. We envisage a 
blending of various budgetary sources stemming from:  
o the public sector (2/3) to cover the investment for the governmental service component via EU budget and 
national fund ing (either through ESA or national budgets, or in kind contributions);  
o the private sector (1/3) investment to leverage the commercial service component.  
 
- Stake in Non -EU constellation. The Union would fully finance the acquisition of shares.  
 
Regarding third party access :  
- an adequate mechanism should be foreseen in the concession contract to allow other EU telecom operators to use a 
share of the commercial capacity; and  
- adequate safeguards should be foreseen to avoid any overcompensation of the contractor, distortions of competition, 
any conflict of interest, undue discrimination and any other hidden indirect advantages.  
 
As regards the allocation of liability  for loss and damages to assets (and related insurance approach) as well as for service 
provision, with relevant possible limitation of liability as necessary to ensure the financial viability of the contract, wil l be 
foreseen under the concession contract.  
 
Regarding security  governance, the process set out in the Space Regulation will be f ollowed.  In terms of steps, this requires 
that first, a threat and risk analysis is being undertaken, on which basis subsequently general and specific security require ments 
will be developed and finally flown down to the concession contract.  
 
 It should clarify to what extent the level 
of private funding will be subject to the 
outcome of a (competitive) concession 
award procedure. It should explain how 
an efficient and timely public 
procurement process as well as the 
effective participation of SMEs and 
innovative start -ups would be ensured. It 
should also clarify how uncertainty on Regarding the procurement process, it would be carried out in accordance with Title VII of the Financial Regulation, 
ensuring fair and open competition.  In developing the procurement documents, several key pr inciples should be addressed in 
order for the concession contract to:  
• define a  clear distribution of tasks and responsibilities between the partners;  
• ensure an appropriate prioritisation of governmental user needs;  
• the approach to access/exploitation of the infrastructure components, in particular security -related components  
• allow the provision of commercial services to be defined by the private sector; the Commission should retain the 
right to assess and approve such services to ensure that the Union’ s essential interests and Programme’s objectives 
 
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 the governments’ demand for satellite 
capacity would be managed under the 
different options. The report should set 
out a clear timescale for the deployment 
of the initiative con sistent with the 
immediate needs it identifies  are preserved and adequate safeguards are put in place to prevent distortions of competition and avoiding any 
overcompensation of the private partner;  
• define the financing scheme proposed in terms of split between the required public sector investment (either in kind 
or through availability payments), the offered private sector investment (either in cash or in kind);  
• define the ownership regime of the assets, implementing a clear distinction between assets t o be owned by the Union 
and assets to be owned by the contractor.  
 
- In order to ensure the New Space involvement  in the initiative, the procurement should elaborate criteria for the award 
of the concession ensuring the participation of start -ups and SMEs al ong the whole value chain of the concession, 
hereby incentivising the development of innovative and disruptive technologies. New Space stakeholders have 
demonstrated their innovative ideas for the initiative, and the following two studies on ‘New Space sol utions for long -
term availability of reliable, secure, cost effective space based connectivity building on GOVSATCOM’ enabled the 
Commission to leverage these early ideas. The outcome of these studies inputs should be duly considered when 
drafting the proc urement documents.  
 
- The procurement should reinforce the non-critical dependence  of the EU in technological terms, and ensure 
compliance with requirements related to security, service continuity and reliability by inserting them as minimum 
requirements or award criteria in the tender documentation.  
 
- The Commission should ensure effective and transparent competition by continuing spreading awareness of the 
procurement within the limits of the Financial Regulation.  
 
Regarding the uncertainty on the governmen ts’ demand , a full public infrastructure would need to be sized at peak demand 
whereas a PPP option would allow for more flexibility.  
 
(3) The report does not contain any timescale for the initiative nor does it identify where the necessary funding would come from.  
  An indicative timeline  supporting this objective could be as follows:  
 End 2022: Adoption of Regulation by European Parliament and Council  
 2023: Award of the Concession  
 2023 -2027: Development and deployment of the infrastructure  
 2025: Provision of first low latency services  
 2027: Provision of full portfolio of services  
 
  Regarding the funding sources , these are as follows:  
 
 
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 - Baseline: 100% EU funding  
- Full public:  100% EU funding  
- PPP:  The cost sharing that will be defined in the context of the negotiation of the concession contract. We envisage a 
blending of various budgetary sources stemming from:  
o the public sector (2/3) to cover the investment for the governmental service component via EU budget and 
national fund ing (either through ESA or national budgets, or in kind contributions);  
o the private sector (1/3) investment to leverage the commercial service component.  
 
- Stake in Non -EU constellation. The Union would fully finance the acquisition of shares.  
 
 
(4) The impact analysis is incomplete as it continues to lack clarity on methodological assumptions and validity of secondary data ci ted and broadly employed for the 
economic estimates, benchmarks and multipliers in relation to the present initiative.   
C
5 The report should further discuss the 
methodological validity and assumptions 
behind the broad economic impact 
estimates, benchmarks and multipliers 
just extracted from secondary sources 
and done for projects of different scope 
and characteristics. It should a lso align 
the used economic multipliers between 
different parts of the report and the 
annexes. It should better argue why the 
public -private -partnership option would 
generate additional commercial services, 
as it seems that these services could 
largely be provided through commercial 
(most likely non -EU) satellite providers 
under the baseline.  Methodological assumptions  and data stem from authoritative sources:  
- For the upstream (i.e. space infrastructure deployment), the metrics used stem from Eurostat Input /Output tables and  
have already been applied in the most recent IA of the Space Regulation, in particular the GOVSATCOM component;  
- For the downstream, the metrics needed to be adapted to the Telecommunication sector. The authoritative table used 
is theref ore relying on an econometric model developed by the International Telecommunication Union.  
 
On additional commercial services , our methodological choice is to measure benefits only within the EU. In this context, 
several evidences tend to demonstrate that  space downstream activities emerge preferably close to the upstream ecosystem. An 
example stemming from the satellite navigation field illustrates this: while GPS has been accessible to civilian use since 19 83, 
location -based services have thrived in the EU only after the start of the deployment of Galileo. The EU satellite navigation 
market has grown from EUR 27bn in 2009 to EUR 675bn in 2019, reaching a market share comparable to the US.  
  
 
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 (5) The report does not specify how the increased greenhouse gas  emissions generated by the initiative would be compatible with the objectives of the Climate Law.  
C6 Also for the environmental impacts, the 
report should better justify why impacts 
from this initiative would be similar to 
those from other EU space 
progr ammes. It is, for example, not 
clear why the environmental benefits 
would be similar to those of 
Copernicus, which has a much clearer 
focus on earth observation for 
environmental purposes. The report 
should also specify how it would ensure 
that the increas ed greenhouse gas 
emissions from large -scale satellite 
production and launches would not 
have negative effects on the trajectory 
to climate neutrality of the Climate 
Law.   Greenhouse gas emissions . We acknowledge that deployment generates greenhouse gas emissions. Using the metrics 
developed by PwC, we estimate that deploying and maintaining the constellation (in the heaviest architecture 
contemplated by the private sector124) over 20 years would generate 5 Mt CO2, i.e  0,25 MT per year, which would 
represe nt 0.0008% of 2020 emissions.  
 
 It should be noted that technologies allowing space industry to be carbon neutral do not exist for the time being. 
Therefore, a carbon offsetting scheme  is being proposed.  
 
 As regards the environmental footprint , there is no difference between manufacturing and launching a satellite, 
whether it is aiming at serving Copernicus or secure connectivity. The conclusions of the PwC study assessing the 
impacts of the Space Programme is valid for Secure connectivity. The number of sat ellites may be bigger in this 
initiative than in Galileo or Copernicus, however satcom satellites have a comparably smaller size and mass, which 
means that they can be launched in large groups, hereby reducing launch emissions.  
 
 As regards environmental be nefits , out of the 20 positive impacts identified by PwC, secure connectivity could 
contribute to 16 of them: for example, in -situ sensors monitoring marine environment rely today on radio to transmit 
data, requiring significant energy and thus heavy (and toxic) batteries. A low -data rate (“IoT”) solution would enable 
smaller, energy efficient in -situ sensors.  
 
 Finally, it should be noted that the size of the envisaged the Secure Connectivity constellation is not comparable to 
US and UK constellations (over  10 000 for Starlink in final configuration, 650 for Oneweb, vs a maximum of 200 
satellites in the heaviest architecture scenario contemplated by industry).  
 
                                                           
124 Described in classified annex  
 
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5. EVIDENCE , SOURCES AND QUALITY   
  
The Commission contracted an independent consultant Roland Berger to support the analysis of the 
indirect benefits of the initiative through providing the econometric support and analysis.  
Quantitative and quantitative data supporting this impact assessment has been collected from Member 
States,  and relevant industry stakeholders . This report also draws on the work of the  Commission on 
the GOVSATCOM component of the EU Space Programme, and EuroQCI, as well as on the research 
activities conducted wi thin the framework of the ENTRUSTED project . The impact assessment has 
also leveraged the consultation of end -user communities held within the framework of the study on 
‘Building Blocks Towards a Secure Space Connectivity System’.  
 
 
 
  
 
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 ANNEX 2: STAKEHOLDER CONSULTATION    
 
Introduction  
The Commission actively engaged the stakeholders  in the process of the initiative  and consult ed them  
on GOVSATCOM services and European secure quantum communication infrastructure (EuroQCI), 
as well as in the contex t of the Action Plan on Synergies between Civil, Defence and Space Industries.  
 
Interaction with stakeholders will also regularly take place via the Expert Group on the Aerospace & 
Defence Ecosystem. Public consultation regarding civil user needs has been conducted in relation to 
the Digital Single Market Strategy and is ongoing throu gh studies on the SatCom market. The relevant 
consultation activities are listed below.  
 
In addition, a public consultation was conducted within the period between 26 August and 23 
September 202 1 on the inception i mpact assessment  of the space -based secur e connectivity 
initiative125. The key findings of this consultation are summarised below.  
 
The facts and date collected via the s takeholder involvement were  important  for the impact assessment , 
enabling the Commission to substantiate, validate, develop or modify the problems and their drivers, 
and the corresponding objectives identified in the inception impact assessment and to elaborate a list 
of specific possible policy measures and policy options which could address each of the problem 
drivers identified . 
 
1.1. Overview of the Relevant Stakeholder Consultations  
The following relevant consultation s of stakeholders have taken place or are planned, including 
worksh ops and ongoing studies:  
Date  Name  Activity  Description  Reference  
2016  Satellite 
Communications 
to support EU 
Security Policies 
and 
infrastructures  PwC study  for 
GOVSATCO
M impact 
assessment  This study analysed the risks and 
problems associated with each 
mission of security actors as 
potential EU GOVSATCOM 
users.  Ref. Ares (2016) 1563278, 
see here 
                                                           
125 https://ec.europa.eu/info/law/better -regulation/have -your-say/initiatives/13189 -EU-space -policy -space -based -secure -    
conn ectivity -initiative_en   
 
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 15.03.201
7 
(or we 
could say 
ongoing 
as we still 
get input)  High Level Civil 
Military User 
Needs for 
Governmental 
Satellite 
Communications 
(GOVSATCOM)  Distribution to 
Member States 
(the Political 
and Security 
Committee)   The user needs for governmental 
users  have been largely collected in 
the phase that led to the definition of 
the GOVSATCOM component of 
the EU Space Regulation, on which 
the secure connectivity initiative is 
based. The data have been collected 
in the document.   ref. EEAS(2017) 359 
published here 
15.06.201
7 Workshop on 
security users for 
GOVSATCOM  Workshop 
industrial 
actors 
(manufactures, 
operators)  Brought together some 80 
representatives of the various 
sectors concerned. In both events, 
the hybrid policy -options for 
GOVSATCOM were presented 
which had been adapted to 
incorporate stakeholders' initial 
comments. Both meetings delivered 
the necessary feedback for the 
Impact Assessment for 
GOVSATCOM.   
06.06.201
7 High -level 
meeting with 
member states and 
observers on 
GOVSATCOM  High -level 
meeting with 
member states 
and observers  Workshop with EU Member 
States satellite communications 
security users, EU agencies 
involved, institutional actors 
(space agencies, proc urement 
agencies, etc.) and Industry 
Associations for GOVSATCOM.   
2019  Preliminary 
market 
consultation on 
GOVSATCOM  Preliminary 
market 
consultation  As part of the preparation of the 
GOVSATCOM programme, an 
extensive public preliminary 
market consultation  was carried 
out through a call for Call for 
Expression of Interest.  Link  
30.06.202
0 Market 
consultation in 
preparation of the 
innovation 
partnership 
procurement of 
GOVSATCOM 
Hub(s)  EUSPA  
Market 
consultation  The objective of the market 
consultation was to confirm whether 
technical solutions for the 
GOVSATCOM Hub(s)  
infrastructure, as described in 
paragraph 1, already exist in the 
market or as near to marke t 
development activity.  Link  
 
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 12-13.11. 
2020  Impact of the 
Covid -19 
pandemic on EU 
Aerospace and 
Defence 
ecosystem  Workshop  The workshop in particular 
consulted on space -based secure 
connectivity.  Link  
23.11.202
0 Roadmap for the 
Action Plan on 
Synergies 
between Civil, 
Defence and 
Space Industries  Public 
Consultation  The roadmap included a point 
regarding secure connectivity.   Link  
16.12.202
0 The EU's 
Cybersecurity 
Strategy for the 
Digital Decade  EU’s 
cybersecurity 
strategy  EuroQCI is part of the EU’s 
cybersecurity strategy.  JOIN(2020) 18 final  
19.03.202
1 Digital Day 2021  Event with 
Member States  The event brought together 
Member States to discuss current 
and future challenges of digital 
technologies  and commit to 
addressing them, including secure 
connectivity.  Link  
Ongoing  GOVSATCOM 
and EuroQCI: 
Building Blocks 
Towards a Secure 
Space 
Connectivity 
System  Study on 
GOVSATCO
M and 
EuroQCI  The study is coll ecting data from 
more than 60 relevant input 
documents on the subject, and will 
deliver an aggregated elaboration 
of user needs for GOVSATCOM 
and EuroQCI  in the first half of 
2021.  Contract ref. DEFIS/2020/ 
OP/0008  
Ongoing  ENTRUSTED  Study  A n etwork of Users for 
governmental Satellite 
Communications  (including 
Member States and EU agencies) 
has been set up which will support 
the establishment of high level 
civil and military user needs for 
EU GOVSATCOM . They  are 
currently being represented in the 
coordin ated and support action 
managed by the GSA called Link  
 
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EN      EN 
 ENTRUSTED, which is open to 
participation of EU Member States 
institutions.  
Ongoing  Study on the 
System 
Architecture of a 
Quantum 
Communication 
Infrastructure  2 Studies on 
EuroQCI  Launched in 2020, the studies did 
contribute to the analysis of use 
cases and the description of the 
corresponding user requirements 
that the QCI  would have to satisfy. 
This work was carried out through a 
wide consultation of governmental 
and private users, with the support 
of participating Members States of 
the EuroQCI initiative. The user 
needs for the EuroQCI use cases are 
now defined to a great  extent. A new 
system study has started in Q1 2021, 
which will allow to further 
accurately describe the user 
requirements and use cases in order 
to determine the possible options of 
the architecture design.  SMART 2019/0086 - LC-
01381549 and LC -
01381564  
Ongoing  EU space 
economics and the 
global context  Study by 
SpaceTEC and 
EuroConsult  Includes satellite communications 
sectorial analysis providing amongst 
other results a forecast on key 
sectoral trends and SWOT analysis, 
hereby identifying satcom user 
needs  for consumer broadband, 
aerospace, enterprise, maritime 
amongst others.  DG DEFIS FWC 
712/PP/2018/FC  
31.05.202
1 Member States 
workshop on 
Secure 
Connectivity  Workshop 
with Member 
States  The workshop shared the technical 
findings of the consortium study, 
and of the legislative process by 
COM representatives, who 
interacted with Member States 
during the Q&A.   
15.06.202
1 Secure 
Connectivity 
Initiative: 
Opportunities for Workshop 
with SMEs and 
start-ups  The workshop was designed to be 
attended by both industry and COM 
representatives, who interacted 
within guided discussion sessions 
and via short scheduled 
matchmaking sessions. The event  
 
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EN      EN 
 the European New 
Space Ecosystem.  included technology focus sessions 
at which preselected presenters 
showcased their solutions and 
engaged in guided panel discussions 
relevant for the topics of the Secure 
Connectivity Initiative.  
26.08.202
1 to  
23.09.202
1 Inception impact 
assessment  Public 
Consultation 
on the 
Inception 
Impact 
Assessment  
  Link  
30.11.202
1 Member States 
workshop on 
Secure 
Connectivity  Workshop 
with Member 
States  The workshop shared the technical 
findings of the consortium study, 
and of the legislative process by 
COM representatives, who 
interacted with Member States 
during the Q&A.   
 
 
1.2. Focus on Public Consultation on the Inception Impact Assessment  
On 26 August 2021 the Commission published for public feedback the draft inception impact 
assessment highlighting the core objectives of the secure connectivity initiative.  
In total 13 stakeholders submitted their feedback, representing the views of a group of EU poorly 
densed territories (1), private companies (8), business associations (2), a non -governmental 
organisation (1), and a private citizen (1) . 
Options in the public consultation was:  
0. baseline  
1. EU owned space infrastructure  
2. Fully private infrastructure  
3. Public Private Partnership – Concession  
4. Purchase of a minority stake in one of the non -EU constellations being built   
 
 
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 It has to be noted that since the public consultation exercise, option 2 - full private infrastructure has 
been discarded but for the sake of t ransparency and completeness, it is still presented.  
Private companies:   
 0 1 2 3 4 
SES       +   
Intelsat            
Hispasat        +   
Airbus DS  --- - + + For Commercial  
Telesat      + + + 
Eutelsat  --- ---   + ++126 
Oneweb        + ++ 
ArianeEspace  ---     + --- 
 
 
SES - Satellite and terrestrial telecommunications network provider   
Preference for PPP with a concession and/or availability model. Best balance of outcomes for the EU 
and member states.  Positive towards general objectives and overall framework.   
Some general remarks on ESSCS:   
 Focus shall be on principal geographies and markets indicated as of strategic interest by the 
European Commission.   
 These shall be served by a hybrid of various orbits, taking advantage of existing and 
committed assets and creating a more sustainable and less costly architecture.   
 Propose integrated multi -orbit constellation and gradually deploy and scale up – leveraging 
existing/committed MEO/GEO assets to be complemented by LEO assets, and take full 
advantage of  the relative merits of each obit, based on relevant use cases.   
 Intelsat (US HQ)  - Communications satellite provider   
                                                           
126 Eutelsat has recently acquired a 24% stake in Oneweb  
 
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 Positive towards the ESSCS initiative. No explicit statement on which model is preferred but stresses 
the need for:   
 Durable partnershi ps with industry   
 Open and fair procurement processes grounded on security, competitiveness, and 
technological -efficiency considerations crucial in ensuring that the EU remains a competitive 
market.   
 Autonomous, reliable and cost -effective access to space can only be achieved by making full 
use of available competitive and diversified solutions   
 Strong advocate for mixing of technologies: not only innovation offered by LEO satellites, 
but also state -of-the-art existing GEO capabilities, as well as combining  of terrestrial and 
space -based platforms.   
Hispasat  - Spanish satellite communication operator   
 Company endorses ESSCS.  Preference for PPP model with EC as anchor customer.   
 General comments:   
 the use of current and planned assets from EU operators is d eemed essential for ESSCS.   
 Seen the maturity of the EU satcom market, the initiative should no distort the existing 
commercial markets.   
 ESSCS should cover multiple orbits.   
 Company is working actively on GEOQKD mission with ESA.   
Airbus DS France   
Strong ly supporting ESSCS.  No clear preference for a policy option, but notes that they do not 
favour the baseline option and states that Option 1 should not preclude the private sector from 
running  the services . Under option 3 Airbus notes that EU long -term commitment is necessary. For 
the 4th Option they note that it should only be considered for commercial services due to the security 
requirements linked to governmental services.  
 ESSCS shall rely on seamless integration of t errestrial and space components.   
 Modular architecture to provide first services quickly, that can later be expanded.   
 In order to be more independent from non -EU states, intersatellite optical links are a way to 
go.  
 GovSatCom hub start early as possible.   
 Chosen policy option shall not compete or distort satcom commercial market.   
TELESAT - Canadian Satellite Operator  
Company endorses ESSCS.  Telesat believes that it could work with any of options 2  -4. It has 
similar PPPs with Governments of Canada, Quebec and Ontario  
General Comments  
 
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 EUTELSAT - French -Based satellite operator  
 Eutelsat welcomes the initiative and the issuance of the Inception Impact Assessments  
 strongly believes that the future EU autonomous and secure infrastructure for conne ctivity 
will be an accelerator of the EU digital transformation and a booster for competitiveness.  
 Supports option 3b and 4, somewhat positive to Option 3a, and negative towards Option 1 
and 0.  
 More generally, relying on non -EU satcom assets in which EU companies have 
industrial/capital interests and play a substantial role would help the EU to control the level 
of external dependency, and manage the associated risk . Option 4 would also help fast -track 
the EU’s access to the future of satcoms, and enjoy t he distincitive advantages that some of 
those constellations can offer.  
General comments  
 High risk that the EU lose the constellation race  
 Given this sense of urgency, the EU should meet short -term objectives, to keep up with the 
rapid growth and evolutio n of user needs  
 The EU can count on the full support of its satcom private industry  
 Providing a reasonable level of predictability of the initiative for the establishment of the 
System (calendar and budgets), as the industry would need to engage in this in itiative large, 
valuable human and financial resources, and this for a long time  
 not only focus on the long -term perspective, meant to lower dependencies and address 
technology gaps  
OneWeb – UK-Based LEO Constellation Satellite Operator  
 Company endorses ESSCS , and Option 3 and 4, and suggests a combination of the two 
options: Start with acquiring capacity through an existing constellation operator, then 
gradually build up the PPP.  Regarding Option 4 it notes that it is the most cost -efficient 
solution and  allow for the fastest implementation timeline.  
Arianespace  
• Company endorses ESSCS , and notes that Options 0 and 4 would not bring  answers to the 
Key Problems listed by the Commission, starting with the growing demand and lack of 
infrastructures and well as the risk of strategic dependency & loss of digital and space 
sovereignty . All other options could allow to achieve the strategic  objectives set by the 
Commission, although a PPP seems a good way  to best address both the EU GovSatCom 
and commercial market needs  
Both professional organisations strongly support the initiative but both insist on urgency to implement 
because of growing scarcity of orbits and frequencies . 
ASD -Eurospace – Association representing the European space manufacturing industry  
 
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 • Associations strongly supports the initiative  - It will help the Union to remain a leading 
international player with freedom of action in the space domain, and will support the 
competitiveness and innovation capacity of space sector industries within the Union  
• Options : all possible indicative policy options  considered by the Commission would meet 
sovereignty and autonomy requirements allowing to promote and favour a support towards a 
dynamic, innovative and publicly supported EU -based industry  
• General comments:  The Association highlights the benefits from a partnership between the 
EU and ESA in particular for the underlying key technologies and product roadmaps supporting 
the programme to ensure the best use of ESA’s heritage in that domain. The Association insists 
on the urgency to implement this new Flagship.  
 
ESOA  – Association representing 22 global and regional satellite operators.   
• The Association welcomes the initiative  
• The Association notes that Non -European players have benefited from targeted industrial 
policy & funding frameworks, which led directly to significant progress and  innovation in 
satellite communications outside the EU, notably in the United States.  
• The initiative is therefore late.  There is a need for the Commission to ensure best chances of 
success, provide a demonstrable return  on taxpayers' money, and ensure minimum risk 
exposure through an initiative that would leverage the scale, knowledge, and customer base 
of European satellite operators.   
   
1.3. Focus on previous consultations on governmental satcom services (GOVSATCOM and 
high level meetings in the frame of the definition of the GOVSATCOM component of the 
EU Space Regulation   
Who was consulted?  
Governmental organisations are the main EU GOVSATCOM users and therefore main stakeholders. 
The regular meetings of the Experts Group thus covered an essential part of the consultation. Between 
April 2016 and April 2021, the Group has met 8 times to elabor ate the high -level civil -military user 
needs and to cover other relevant topics including the requirements for the potential use cases  
Additional consultations were launched to target specific stakeholder groups. These consultations were 
carried out as pa rt of the impact assessment , during bilateral contacts with MS' authorities and 
industrial actors.  
The main focus of this targeted consultation was on Member States and Industry :  
 Member States were consulted in their double function as potential providers of governmental  
satcom capacities and as future users of EU GOVSATCOM. In bilateral discussions the 
 
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 Commission discussed with the interested national administrations (including line -Ministrie s, 
Military forces and potential civilian users) their experiences and capacities, their current and 
future national needs, and their expectations with regard to an EU initiative.  
 On the side of industry, all relevant domains were covered from satellite op erators and service 
providers to satellite manufactures and SMEs  
The exchange of views took place  
a) within expert group and bilateral meetings  
b) Workshops with Member States and Industry  
Main results of the GOVSATCOM Expert Group and bilateral meetings  
 Most Member States expressed explicit support for the principle of an EU initiative to provide 
a step -by-step solution based on existing satcom assets. Interventions also generally supported 
the overarching objectives. One M ember State underlined the need to guarantee the EU's 
strategic autonomy, based on European technologies and capacities. Other salient points were 
the need to tackle the security aspects in a timely manner, and to define the overall systems 
architecture and Services'  requirements. Several Member States  confirmed the increasing 
governmental needs for guaranteed access to secure satcom.  Some suggested using existing 
national surplus capacity as a starting point, while others proposed the integration of adequate 
commerci al or PPP capacity from the outset.  
 Regarding the issue on whether and how to aggregate the existing demand across the civil and 
military spectrum, and across the EU and national boundaries, one Member State stressed the 
need for a civilian solution under  civilian control,  without recourse to national milita ry 
satcom assets. One other M ember State underlined that the initiative should federate civilian 
and military demands. It should also rely on M ember States' and commercial satcom assets and 
capacities, build on ESA and EDA work, focus on gaps and missing links, and put in place 
hybrid solutions on a permanent basis.  
 One M ember State recalled the need to tackle possible frequency and spectrum issues in 
the International Telecommunication Union (ITU)  context.  
 Several Member States stressed that national capacities alone might possibly satisfy short -term 
needs, but will not be sufficient in the long run. Some of the gaps (e.g. Arctic)  are already 
known.  
 Regarding the long -term financing of capacities , incl. the renewal of existing space assets, the 
filling of gaps, or the provision of global coverage, most interventions agreed that the EU 
Budget should pay for the EU GOVSATCOM usage by EU institutions and Agencies. Some 
also argued that EU GOVSATCOM s hould become a full -fledged, budget -financed EU 
 
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 Program. Others suggested leveraging the market to the extent possible in the short -term, to 
explore co -financing by M ember States and commercial actors, to look into what ESA could 
do on innovation and R&D, or to address the long -term issues later.   
 The Commission has held bilateral meetings with ASD Eurospace experts . The outcome is that 
there are no plans for EU private companies of creating a satcom constellation that will meet 
the evolving governmental low-latency and global needs . ASD Eurospace  provided a possible 
explanation behind  the lack of an EU initiative:  The purely commercial business case is not 
convincing due to the large price related to the infrastructure (requiring hundreds of LEO 
satellite s to be launched for assuring a dense global coverage), the limited lifetime of satellites 
and the limitations on the market. Mega -constellations provide a global coverage, however, the 
need for global coverage is not constant, and means that the satellite s often will be covering 
places on earth where there is no commercially sellable market (e.g. coverage on high seas, 
deserts or areas where competitors have the market). With an expensive system that only 
provides sellable services a limited amount of time , the demand will need to be extremely high 
to cover the investments. Because of these factors, Oneweb declared chapter 11 bankruptcy in 
March 2020, but was revived thanks to a $1 billion strategic investment by the British 
government and Bharti Global, an  Indian telecoms conglomerate. This illustrates the lack of a 
purely commercial business case, combined with major governmental strategic advantages for 
those that manage to gain access to such satcom mega -constellations . No LEO satcom 
constellation have y et proven to be profitable . 
Main results from workshops  
 During the Secure Connectivity State of Play  workshop with Member States on 31 May 
2021 , the Commission presented the outcome of the technical studies (including use -cases and 
different orbital solutions) and possible exploitation models.  
o Member States supported the integration of GOVSATCOM, EuroQCI into the Secure 
Connectivity. In addition,  Member States stressed the need for the involvement of New 
Space, and welcomed the upcoming New Space study.  
o With regards to exploitation models, one Member State suggested that the use cases for 
governmental and commercial services should be split, with the former being fully 
public and the latter fully private.  One Member Stated stressed the importance of 
including lessons learned from Galileo and its first attempt at a concessionaire. Another 
suggested the Commission look at is creating a company with public actors as 
shareholders  (option 3) .  
 During the Secure C onnectivity State of Play  workshop with Member States on 30 
November 2021 , the Commission presented  updates from the current technical study and 
information about the New Space studies. The Commission also presented the objectives and 
the target exploitati on model.  
 
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 o Member States reaffirmed the need  to integrate their existing capacity, and the 
GOVSATCOM hub. Several Member States stressed the importance of involving New 
Space and EuroQCI  in the initiative , and one asked how the Commission would handle 
risks relating to the use of disruptive technology .  One Member State highlighted the 
need for the system to be able to work together with the terrestrial infrastructure and 
another  asked about the po tentia l interoperability with a foreign constellation  (option 
3).  
o Several Member States asked about how the Commission would separat e the 
governmental and commercial services to  ensure the necessary level of security , in an 
option 2 configuration .    
 During the Secure Connectivity Workshop for the European New  Space Ecosystem  on 14 
June 2021, 458 participants (including 196 SME and start -ups) discussed innovative ideas for 
the Secure Connectivity initiative. The workshop was divided into four different sessions  where 
SME and start -ups presented and discussed in novative satcom solutions. The workshop showed 
that the  New Space ecosystem is  technological advance d and eager to contribute to the 
initiative . It also demonstrated ways in which a new initiative could benefit from their solutions  
and what challenges they have of bringing it to market , for example : 
o SMEs and startups involved in the fields of operations and service provisions, discussed 
how technological innovation can occur if the appropriate enablers are put in place. In 
this resp ect, SMEs and startups could become essential in engaging commercial 
users, because their innovation capabilities is the best instrument to drive the 
creation of new services, new solutions favouring the uptake of the system in all 
market niches  
o The flexib ility to use standard modularised components to build satellites has enabled 
New Space to find its place in the space ecosystem; European New Space will 
increasingly not only offer one -off missions, but solutions based on constellations of 
nano and small s atellites in innovative orbits. New Space companies are aiming at 
making more advanced capabilities available to potential customers using 
technologies that are not used yet (such as W -band), and that traditional players may 
not be looking at yet . 
o Particip ants brought new technologies to the table ranging f rom electric propulsion, to 
digitalized and reprogrammable satellites.  They underlined the double challenge of 
having credible commercial demand  for their satellite platforms and resilience in 
front of  increased competition . 
 
  
 
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 ANNEX 3: WHO IS AFF ECTED AND HOW ?  
1. Impacts on Affected Stakeholder Groups  
The impacts of the preferred option are expected to fall on different stakeholder groups (Member 
States, EU institutions and agencies, satellite communication service providers, and EU citizens) to 
different degrees. The estimates of the expected financial  impacts are uncertain, as they are strongly 
influenced by a large number of assumptions, limited by the available evidence used to quantify them 
and by the simplification inherent in modelling. The  indirect benefits are, however, somewhat more 
certain and  the direction of the impacts (i.e. whether a stakeholder group in aggregate benefits or incurs 
costs) are presented with a reasonable level of certainty, although it should not be used to infer the 
expected impact on individual stakeholders.  
1.1 Member States  
Member States’ national and regional governments would benefit from an access to a system that 
would provide security , civil protection, or law enforcement organisations with a connectivity system 
under EU control, rather than procuring services in several fragmented procurements with various 
service providers, some under third -countries control. The use of a common syst em should also ensure 
a better interoperability between these services, be it at national or EU level. The Member States would 
incur some direct costs in procuring the necessary ground infrastructure – i.e. user segment . However, 
the system  interoperabilit y should also favour economies of scales in the receiver segments by 
reducing the number of standards used.  
1.2 EU Institutions and Agencies  
The impact on the EU institutions and agencies would be similar  to the impact on the Member States. 
The EU institutions and agencies would also benefit from an access to a connectivity system , without 
procuring different services from different service providers.  
1.3 Satellite Communication Service Providers  
The European satcom service providers would incur part of the  initial CAPEX in order to deploy the 
infrastructure envisaged in this initiative. However, once deployed, the satcom providers, next to 
providing services to the government users, would also have the opportunity to scale the system in 
order to also provide commercial services to the mass market.  
1.4 EU Businesses  
Various EU businesses would benefit from the secure connectivity initiative . The telecommunications 
operators w ould benefit from the increased capacity and reliable service offered by the proposed 
infrastructure, and therefore w ould be offer a higher quality of service to their customers. If the 
commercial services are exploited, t he retail services would be able to reach more custo mers across 
the entire EU due to closing of the digital divide. Businesses would benefit from the secure and reliable 
 
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 connection, making them less vulnerable to cyber threats and service disruptions.  EU space industry, 
including the New Space industry, wou ld benefit from the R&D funding, enabling innovative and 
competitive solutions.  
1.5 EU Citizens  
Citizens across the EU would benefit from the enhancements brought by the secure connectivity 
initiative in the area of civil protection and national security. Furthermore, t he citizens , particular ly 
those living in remote and rural areas, could  benefit from access to a reliable and secure broadband 
connectivity. Furthermore, due to closing of the digital divide an increasing amount of the EU citizens 
could  benef it from the digital government services such as e -governance, e -health, or e -education.  
 
5. Summary of costs and benefits   
 
I. Overview of Benefits (total for all provisions) – Preferred Option   
Description   Amount   Comments   
Direct benefits   
N/A  N/A There are strategic benefits related to security and 
reliability of governmental satcom services 
stemming from the deployment of an EU space -
based secure connectivity infrastructure.  
Indirect benefits   
 
 
Fostering the growth 
of the EU space sector    
 
 
Six times the invested value  
 The initiative would enlarge the potential of the 
EU space sector, foster the downstream sectors 
with the offering of EU -based secure satellite 
solutions, and tackle weaknesses like the lack of 
ICT adoption and low investments  in remote 
regions .  
 
Investments in Space upstream infrastructure is 
estimated to generate a six -fold impact in 
downstream sectors.  
 
 
 
 
 
 
 
 
GDP increase   
 
 
 
 
 
 
 
Six times the invested value  
 
 The initiative is estimated to generate an increase 
of the European GDP through transactional 
effects (investment in the space economy 
increase the value added in this sector, of 
suppliers and the wider economy due to 
expanding business and additional sala ries which 
raise consumption), spillover  effects 
(downstream sectors use the services, 
technologies and data provided by the space 
sector to enhance their business) and additional 
government revenues.  
 
Investments in Space upstream infrastructure is 
estim ated to generate a six -fold impact in 
downstream sectors  
 
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Job creation   
 
Minor impact on jobs creation in Space 
Industry  It is estimated that the establishment of the EU 
space -based secure connectivity system would 
create new jobs directly related to the design, 
deployment and operation of such system, as well 
as in the downstream market.  
  
 
II. Overview of  costs – Preferred  option   
  Citizens/Consumers    Businesses   Administrations   
One-off  Recurrent   One-off  Recurrent   One-off  Recurrent   
Establishment 
of an EU 
space -based 
secure 
connectivity 
system  Direct costs   N/A N/A  N/A  N/A N/A   N/A 
Indirect costs    
 
N/A  
 
N/A  
 
 N/A  
 
N/A procuring the 
necessary 
ground 
infrastructure 
– i.e. user 
segment   
 
N/A 
  
  
  
 
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 ANNEX 4: CAPACITY DEMAND GROW TH 
Extract from the study 'Building Blocks Towards a Se cure Space Connectivity System’  
 
   2025 -2030  2030 -2040  
   Total addressable market 
(Mbps)  Total addressable market 
(Mbps)  # Group  Use case  
1 Surveillance  Border & Coast 
Surveillance                  600.00                1,200.00  
2 Surveillance  Maritime surveillance 
and control               1,600.00                4,000.00  
3 Surveillance  Connectivity for Vessel 
operators             96,000.00            192,000.00  
4 External Action and 
Crisis Management  Maritime Emergencies                  120.00                   240.00  
5 External action and 
crisis management  Police interventions               1,600.00                5,000.00  
6 External action and 
crisis management  Civil protection               6,000.00              15,000.00  
7 External action and 
crisis management  CSDP/CFSP missions 
and national defence 
operations               4,200.00                8,200.00  
8 External action and 
crisis management  Humanitarian aid           360,000.00            710,000.00  
9 Key Infrastructure  Institutional 
communications                  500.00                   800.00  
10 Key Infrastructure  Air Traffic Management 
(ATM)  
                    1.12                       2.86  Future Reduced Crew 
Operations  
Urban Air Mobility  
 
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 11 Key Infrastructure  Flight operations  and 
Maintenance 
connectivity                    83.00                   188.00  
GADSS (Global 
Aeronautical Distress & 
Safety System)                  900.00                   900.00  
12 Key Infrastructure  Rail Traffic management               8,000.00              12,500.00  
13 Key Infrastructure  Road Traffic 
Management  -    
14 Key Infrastructure  Space infrastructure – 
Copernicus secure data 
relay               5,000.00              10,000.00  
15 Key Infrastructure  Space infrastructure – 
Galileo/EGNOS data 
transmission                    43.75                     85.00  
16 Key Infrastructure  Energy production and 
transport               9,000.00              15,000.00  
Utilities production and 
transport               9,000.00              15,000.00  
17 Key Infrastructure  Healthcare management 
(Medical connectivity)             40,000.00            250,000.00  
18 Key Infrastructure  Finance – Banking 
(transaction data, 
connected branches and 
ATM)                  600.00                   800.00  
Finance – Banking (High 
Frequency Trading - 
HFT)               1,600.00                2,000.00  
19 Specific Use Case for 
Arctic Region  Ν/Α -    
 
 
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 ANNEX 5: ENVIRONMENTAL IMPACT  
Developing and launching a satellite system into space has impacts on the environment. An assessment of the extent the initia tive will do harm to 
the climate  and environmental objectives  of the Green Deal, is therefore required.  
For the purposes of this initiative, the “do no significant harm” principle is to be interpreted within the meaning of Article 17 of the Taxonomy 
regulation127.  
Art. 
17 Metric  Option 1  Option 2  Option 3  
(a) An activity is considered to do significant 
harm to climate change mitigation  if it 
leads to significant greenhouse gas 
(GHG) emissions;  Compared to other industry sectors, the manufacturing of spacecraft does not emit 
significant GHG emissions128. Moreover,  once in service, the system does rely only 
on solar power.  
The initiative has similar positive contribution towards environmental objectives 
as the Galileo and Copernicus components of the Space Regulation129. A dedicated 
study on the environmental benefits  stemming from the use of the components is 
approximately 2 orders of magnitude higher than the environmental footprint 
generated by the construction, deployment (including the launches and the 
production of launchers) and use over the complete life time ( 22 years) of these 
systems.  No further environmental impact as it rely 
only on existing satcom capacities.  
                                                           
127 The ‘Taxonomy Regulation’ refers to Regulation (EU) No 2020/852 on the establishment of a framework to facilitate  
sustainable investment, by setting out a classification system (or ‘taxonomy’) for environmentally sustainable  
economic activities.    
128 Eurostat Manual of Supply, Use and Input -Output Tables (2008)  
129 Note that even though of the number of satellites are bigger in this activity than in Galileo or Coper nicus, the small size and mass of the satellites coupled with the 
possibility to launch them in groups of large numbers (e.g. from 12 to 36 satellites in one launch) results in relatively com parable footprint evaluation . 
 
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Option 2 and 3 allows for a wider range of downstream applications  that can 
have positive benefits for climate change mitigation. For example, by 
improving connectivity in the EU population can lead to a higher uptake of 
environmental friendly solutions, such as ‘smart’ systems and applications, and 
create less pressure on polluting transportation.   
(b) An activity is considered to do significant 
harm to climate change adaptation  if it 
leads to an increased adverse impact of 
the current climate and the expected 
future climate, on the activity itself or on 
people, nature or assets;  The initiative will have positive impact on the climate change adaptation, by providing a continuous communications 
infrastructure in situation of disrupted infrastructure, notably caused by floods, hurricanes or other extreme weather events  
caused by climate change. Satcom services for maritime surveillance supports pollution detection and response envir onmental 
monitoring.  
See also application of article 17 (a).  
(c) An activity is considered to do significant 
harm to the sustainable use and 
protection of  water and marine 
resources if it is detrimental to the good 
status or the good ecological potential  of 
bodies of water, including surface water 
and groundwater, or to the good 
environmental status of marine waters;  The infrastructure will provide communication through space, hereby avoiding the deployment of ground networks, submarine 
cables, high power  cables or fibres (buried in the ground or above the ground). No significant harm will therefore be done to 
the sustainable use and protection of water and marine resources.  
(d) An activity is considered to do significant 
harm to the circular economy,  including 
waste prevention and recycling, if it leads 
to significant inefficiencies in the use of 
materials or in the direct or indirect use of 
natural resources, or if it significantly 
increases the generation, incineration or 
disposal of waste, or if th e long -term In general connectivity and IoT constitute a key enabler of circular economy solutions.  
 
102 
EN      EN 
 disposal of waste may cause significant 
and long -term environmental harm;  A number of applications enabled by the present initiative will therefore enhance the circular economy. For instance,  
applications developed to ensure traceability of industrial goods (e.g. industrial gas containers, rolling stock material) an d hence 
their recyclability could rely on the provision of a ubiquitous IoT connectivity servi ce.130 
(e) An activity is considered to do significant 
harm to pollution prevention and 
control  if it leads to a significant increase 
in emissions of pollutants into air, water 
or land;  The system would be built in compliance with the REACH regulation and the EU 
Directive on Hazardous Waste. In addition, what concerns the potential long -term 
environmental impact in space, adherence to voluntary international standards on 
the protection of the space environment (COPOUS and IADC) and with national 
legislation  (e.g. French LOI n° 2008 -518 relative aux opérations spatiales)  As the infrastructure is built without EU 
involvement, adherence to environmental 
standards can therefore not be guaranteed.  
(f) An activity is considered to do significant 
harm to the protection and restoration 
of biodiversity and ecosystems  if it is 
significantly detrimental to the good 
condition and resilience of ecosystems, or 
detrimental to the conservation status of 
habitats and species, including those of 
Union interest.   Similar t o the benefits related to the application of 17 (b).  
  In addition, satcom supports IoT applications that can be used to track wildlife extension.  
Figure 13: “do no significant harm ” analysis  
 
                                                           
130 Where the circular economy and the Internet of things meet | | European Commission (europa.eu)  
 
103 
EN      EN 
 In conclusion, the  secure connectivity  does not significantly harm any of the environmental objectives , and even more can contribute to reduce the 
environme ntal impact of other activities. The benefits are therefore much higher than any harm . Finally, it is important to recall that the 
Commission  has decided to impose environmental objectives to its partners  in the Financial Framework Partnership Agreement  concluded with  
the EUSPA and ESA , when implementing the Space Programme with EU funds . The same will be foreseen for tasks to be  entrusted to EUSPA 
and ESA in the framework of the secure connectivity initiative.