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
Date: 2022-02-15
Institutions: Directorate-General for Defence Industry and Space, European Commission
Subjects: EU programme, European security, critical infrastructure security, information security, provision of services, satellite communications, space policy, space technology, use of outer space

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   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}  
 
 
Table of contents 

1. 

2. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT .......................................................................................... 3 

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 ACT? ................................................................................................................................... 19 

3.1. 
3.2. 

Legal basis ........................................................................................................................................................ 19 
Subsidiarity ....................................................................................................................................................... 19 

4. 

OBJECTIVES: WHAT IS TO BE ACHIEVED? .......................................................................................................... 21 

4.1. 
4.2. 
4.3. 

General objective .............................................................................................................................................. 21 
Specific objectives ............................................................................................................................................ 21 
Consistency with other policies and objectives ................................................................................................. 21 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ................................................................................................ 23 

5.1. 
5.2. 
5.3. 
5.4. 
5.5. 
5.6. 
5.7. 

Definition of options ......................................................................................................................................... 23 
Option 0: Baseline ............................................................................................................................................. 24 
Option 1: Fully Public ....................................................................................................................................... 25 
Option 2: Public-private-partnership: EU Concession ...................................................................................... 25 
Option 3: Service procurement from a non-EU private constellation ............................................................... 26 
Other Options discarded .................................................................................................................................... 27 
Summary ........................................................................................................................................................... 28 

6.  WHAT IS THE IMPACT OF THE POLICY OPTIONS? ............................................................................................. 29 

6.1. 
6.2. 
6.3. 

Economic impact............................................................................................................................................... 29 
Social impact ..................................................................................................................................................... 33 
Environmental impact ....................................................................................................................................... 34 

7. 

HOW DO THE OPTIONS COMPARE? ....................................................................................................................... 36 

7.1. 
7.2. 
7.3. 
7.4. 
7.5. 

Effectiveness ..................................................................................................................................................... 36 
Efficiency .......................................................................................................................................................... 38 
Coherence ......................................................................................................................................................... 41 
Feasibility .......................................................................................................................................................... 41 
Comparison summary ....................................................................................................................................... 42 

8. 

PREFERRED OPTION ................................................................................................................................................. 43 

8.1. 
8.2. 

Concession as the Preferred Option .................................................................................................................. 43 
Implementation of the Concession .................................................................................................................... 44 

9. 

HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ............................................................. 45 

ANNEX 1: PROCEDURAL INFORMATION AND FOLLOW-UP OF COMMENTS FROM THE REGULATORY SCRUTINY 

BOARD ......................................................................................................................................................................... 48 

ANNEX 2: STAKEHOLDER CONSULTATION ................................................................................................................... 83 

ANNEX 3: WHO IS AFFECTED AND HOW? ................................................................................................................... 95 

ANNEX 4: CAPACITY DEMAND GROWTH ....................................................................................................................... 98 

ANNEX 5: ENVIRONMENTAL IMPACT ........................................................................................................................... 100 

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Glossary 

Term or acronym 

Meaning or definition 

CAPEX  

Capital expenditures 

COMSATCOM 

Commercial Satellite Communication 

EDA 

EEAS 

ENISA 

ESA  

EUSPA 

GDP 

GEO 

European Defence Agency 

European External Action Service 

European Union Agency for Cybersecurity 

European Space Agency 

European Space Programme Agency 

Gross Domestic Product 

Geostationary Earth Orbit 

GOVSATCOM 

Governmental Satellite Communication 

IoT 

ITU 

Latency 

LEO 

MEO 

Internet of things 

International Telecommunication Union 

Amount of delay, measured in milliseconds (ms), that occurs in a round-trip data transmission to a satellite.  

Low Earth Orbit 

Medium Earth Orbit 

MILSATCOM 

Military Satellite Communication 

M2M 

OPEX 

RR 

QKD 

Machine to Machine  

Operational expenditures 

Radio Regulations (ITU) 

Quantum Key Distribution 

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1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

The culmination of a long political process 

Satellite  communications  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 absent (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 is 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. Moreover, 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  affecting  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 multifaceted 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  communication  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  computing  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 the EU’s Strategic Compass 
8 European Quantum Communication Infrastructure (EuroQCI) | Shaping Europe’s digital future (europa.eu) 

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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. Increased 
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, hyper- 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 connect 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 prompted 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  October  2020  call  for  strategic  autonomy  while 
including  on  secure 

industrial  alliances, 

preserving  an  open  economy  and  new 
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 final - 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) ranging 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 solutions 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,  

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  The secure connectivity initiative is mentioned as a mean ‘towards an innovative, resilient and 
competitive  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,  the  European  Council  conclusions  of  21-22  October  2021  stressed  ‘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 Council 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’ of 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 happens’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 ‘acknowledge 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 will 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, security 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  ensuring  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,  President  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 digital 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 European 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 European 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_Foresight_Report_2021_en.pdf (europa.eu) 
23 JOIN(2021) 30 final 
24 State of the Union 2021 letter of intent (europa.eu) 

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Governmental satellite 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 addresses 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  Inmarsat,  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 
Commission,  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  document30 
(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 defined 
as both private and public actors which act in the interest 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 Governmental Satellite Communications (HLUN) 

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operations  typically  need  various  manned  or  un-manned  connected  platforms  (ships,  airplanes, 
satellites, drones) for ‘intelligence, surveillance, reconnaissance’ 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 
characterised  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 
communication 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  level  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. 

 Key infrastructures. 

iii. 
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  such  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  communications.  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  that  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  and  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 providers. 

31 PwC (2016) 'Satellite Communication to support EU Security Policies and Infrastructures' 

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-  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 should 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 (M2M) 
and Internet of Things (IoT), user needs are moving towards higher security solutions, low latency33 
and global coverage.  However, the current EU Satcom assets cannot meet these 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. 

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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 risks 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 threats 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  reporting  on  the 
implementation of this framework36 has highlighted that hybrid 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 requirements 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 threats’ with 

35  JOIN/2016/018 final 
36 COM_SWD(2020)0153 

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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 building 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 the crisis’39.  In 2019 European critical infrastructures 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 other 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,  decrypt  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 pandemic 
40  JRC (2020) , Cybersecurity – Our Digital Anchor quoted in JOIN(2020) 18 Final 
41  McKinsey (2020) A game plan for quantum computing 
42 Rethinking strategic autonomy in the digital age - Publications Office of the EU (europa.eu) 
43 https://www.eea.europa.eu/publications/europes-changing-climate-hazards-1/climate-hazards-indices 

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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 breakdown 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  floods  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 Database, 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.  

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expected to use both space and terrestrial infrastructure.  M2M and IoT provides connection between 
one or more applications 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.  

Typically M2M and IoT communications require low data rates 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 been 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 RPAS will create 
cost-saving and efficiency gains for the operations. However, in order to succeed, they require a 
robust,  continuous  communication  link  to  command  the  RPAS  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 classified 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 

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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  connectivity  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 trains 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. 

Surveillance 

Border surveillance and control 

Maritime surveillance and control 

Crisis 
Management 

Key 
infrastructures  

Maritime emergencies  

Humanitarian aid 

Civil protection  

Law enforcement interventions 

EU external action  

Forces deployment 

Transport infrastructures 

Space infrastructure 

Institutional communications 

Other key infrastructures 

Polar Regions 

RPAS 

M2M 
communication 
and IoT 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 Wideband Global Satcom (WGS). Crisis management mission and 
operations 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 

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important  because  our  strategic  partners  are  reconsidering  their  priorities,  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 fill 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, etc. 

53 Through the use of non-geosynchronous-orbit (NGSO) communications constellations, including low-Earth-orbit (LEO) and medium-Earth-orbit 
(MEO) satellites 
54   Latency: amount of delay, measured in milliseconds (ms), that occurs in a round-trip data transmission to a satellite.  

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2.  Its orbits would allow to cover high latitudes (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 presence. 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 threats, 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 

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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 Member States to act autonomously to protect their interests. Such impairment does, in turn, 
curtail sovereignty, increases technological dependence and weakens 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 satcom 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 Member State actors in Kabul revealed challenges 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 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  Eurospace55 
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 market.56 

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 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 would not be 
marketable for B2C commercial applications. 

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Figure 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 the 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) 

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demand from other radio uses, such as terrestrial mobile phone systems, and is ultimately limited by 
the  international  Radio  Regulations,  an  international  treaty  based  regulation  that  allocates  what 
frequencies can be used for what purpose. 

A  well  as  defining  frequency  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 first-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 the 
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. 

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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 for 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 security 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 objectives of the proposed 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 evolving 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 acquiring Milsatcom capabilities. Furthermore, the space enabled services expenditure for military operations will not 
be part of this initiative, hence Article 41(2) TEU is not applicable. 

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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 Member State thematic policies would benefit, too. 

3.2.2.  The objectives of the proposed action, 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 duplication 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 ensuring 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 efficiency, 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. 

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4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

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 Member 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. 

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  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  response, 
helping  EU  security  actors  with  the  tools  and  information  they  need.  Secure  satellite 
communication is a recognised 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, which 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 wider 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  Member  State’  freedom  of  action,  as 
highlighted  in  the  2021 update  of  the  New  Industrial  Strategy64.  They  would  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 Mobility. 
  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(2021) 27 final 

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Africa67, where the EU declared 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 AVAILABLE POLICY OPTIONS? 

5.1.  Definition of options  

The  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.  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 

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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 baseline 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 satellites, 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  and  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 entities 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 established 
(cf. Article 55 of Commission Decision (EU/EURATOM) 2015/44). Even if this requirement 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.  

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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 capacity 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, depending 
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 public 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  Commission  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 would be fully integrated to the system. 

5.4.  Option 2: Public-private-partnership: EU Concession  

Similar to Option 1, this scenario foresees the development of a dedicated infrastructure allowing to 
provide low latency secured services 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 Article 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. 

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or the provision and management of services to an economic 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. 

ii. 

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  payments  to  cover  provision  of  services  to  EU 
institutions and Member States. 
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  will  be  based  on  the  capital  expenditure  sharing 
model between public and private sector agreed under the concession contract. In all cases, to 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 an non-exclusive and unrestricted access and use of the other parts of 
infrastructure which are necessary for the provision 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 validation 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 would 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 equity 
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 portfolio to be 
offered to EU governmental users). The instrument to be used by the Union to buy and detain corporate 

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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 third 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 supervision 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 availability 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 programmes 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 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 
74 Regulation (EU) 2021/695 of the European Parliament and of the Council of 28 April 2021 establishing Horizon 
Europe – 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: “European 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 public 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 to market, regulatory or 
policy uptake.” 

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DRAFT - PRELIMINARY 

5.7. 

Summary  

The following table provides an overview of the policy options discussed in this chapter:  

Ownership  

Operations  

Governance 

Services  

Option 0: 
Baseline 

Option 1: 
Fully public  

EU 

EU  

Public-owned 
security assets 
Private owning 
operational and 
commercial 
assets 
Private (with 
minority  EU 
stake) 

Option 2: 
Public-
private-
partnership: 
EU 
Concession 
Option 3: 
Service 
procurement 
from a non-
EU 
constellation 

EU 

Commission,  with  tasks 
entrusted to EUSPA  

Service  contract  with  EU  and 
Member States  

 Public Sector  

Commercial  
 Market  
N/A 

Security 

Subject to Space Regulation 

If the security 
level allows, 
some assets can 
be contracted to 
industrial 
operator 

Private  (except 
security assets, 
directly 
operated by EU) 

Commission, with tasks 
entrusted to EUSPA and 
ESA 

Services to public 
stakeholders managed by EU.   

None 

Commission,  with  tasks 
entrusted to EUSPA and 
ESA 

Industrial  Operators  could  be 
tasked  with  the  operation  of 
the  system,  through  a  service 
contract 
Commitment 
long-term 
service payments to cover the 
demand of Member States and 
EU 
regarding 
public secure satellite services 

institutions 

to 

entirely 

Concessionaire free to market 
commercial services, provided 
he 
and 
additional 
deploys 
infrastructure 
to 
deliver such services.   

required 

finances 

the 

to 

the 

No integration of QKD into the system.  
security  governance 
Similar 
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. 

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 

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6.  WHAT IS THE IMPACT OF THE POLICY 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  the  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 governmental 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  
180 
million 

Option 0: 
Baseline 

6 billion 

Option 1: 
Fully public  
Option 2: 
PPP / Concession   4 billion 

Option 3: 
Stake in non-EU 
constellation  

tbd76 

Annual 
OPEX for 
the Union in  
EUR 

Annual Service 
costs paid by the 
Union in  EUR 

Comments 

Not 
applicable 

40 million from 
2025 to 2027 

250 million 

Not applicable 

170 million  Not applicable 

Not 
applicable 

400 million 

Services  would  be  procured  depending  on  budgetary 
availability (currently 40m in current MFF) 

Current assumption based on power/bandwidth allocation: 
two-third of costs for public sector (EU+MS) 

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’) 

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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 increases 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 industry.  

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 reach 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 investment directly 
in the EU space sector, except for adjustments on the ground segment footprint that 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  enhance  their  business.  These  are 
estimated to have an impact at 1.8-3.2 (i.e. EUR 1 invested in the space sector leads to a GDP increase 
of EUR 1.8-3.2).  As Options 1 and 2 would require 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-output 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.  

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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  enabling  ‘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  for  humidity  and  temperature  to 
manage irrigation), manufacturing, logistics and other sectors84.  

Satcom communication could 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 would create new jobs85. These new services, technologies and data would also 

83   PwC (2019): Main trends and challenges in the space sector 
84   Apart from the overall economy the areas profiting 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, mining and construction. OECD (2019): 
The Space Economy in figures. https://read.oecd-ilibrary.org/science-and-technology/the-space-economy-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 

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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,  additional  government  revenues  that  stem  from  taxes  on  transactions,  salaries  and 
consumption, 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:  

Option 0 

Upstream 
 Economic growth limited to the economic impact 

Downstream 
 No EU triggering of economic growth stemming from 

of EU GOVSATCOM 

SatCom commercial market services  

 Risk of lagging behind the competition from non-

EU companies  

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 services  

Option 2  

 Additional investment required to build the new 
infrastructure would provide transactional effects 
of 1.4-2.0. 

 Investment in the space upstream infrastructure is 

estimated to generate a six-fold impact in the downstream 
sectors 

 Competition during concession-award process 
and in operations would lead to well-suited 
market solutions  

 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 sectors (including New Space). This includes 
the economic benefits of bridging the digital divide. 

Option 3 

 The equity investment will have marginal impact 

 Commercial satcom solutions would lead to economic 

on the EU space economy  

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 remote 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 
ITU (2020):  The economic contribution of broadband, digitization and ICT regulation: Econometric modelling for 
the ITU Europe region 

87  

88   PwC (2019): Main trends and challenges in the space sector  

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 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 result 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 addition, 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 in 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 States and EU institutions, but the 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 access 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 

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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,  86%  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 impacts of building 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  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  Regulation94.  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 access 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 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. 

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Figure 11: PWC (2020) Analysis of the Environmental Impact of the EU Space Programme 

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 constellations 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 the 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 (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 1999/45/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 

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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  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.  

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 COMPARE? 

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 
Specific Objective I  

Assessment criteria 

Ensure the provision of secure satcom for 
evolving public needs  

Specific Objective II   

Increase resilience of Member States and EU 
missions and operations by guaranteed access to 
satcom  

Specific Objective III  

Ensure that governmental communication needs 
are not critically dependent on non-EU operations 

-  Ability to scale the capacity to meet future 

needs in a flexible manner 

-  Extent of information assurance & guarantee 

of access through the GOVSATCOM hub and 
security accreditation board 

-  QKD payload  

-  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 

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Baseline 

Option 1 

Option 2 

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 

Specific Objective II   

(+++)  

 

 EU ownership allows the ability to scale up 
according to each MS’ identified needs 

Option 3 

(-) 

  The service provided would be commercial-off-the shelf, 
and would not meet several governmental requirements 
(e.g. signal robustness, use of governmental frequencies)   

(=)  

(+++)  

(-) 

  EU GOVSATCOM hub and security 

accreditation applies  

  However, no possibility to implement low 
latency services, global coverage and QKD 
payloads 

Increase resilience 
of Member States 
and EU missions 
and operations by 
guaranteed access to 
satcom 

 

 

 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 authority).  

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on non-EU 
operations 

7.2.  Efficiency 

 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 satcom industry losing industrial 
competitiveness in the field of low latency  

Table 5: Effectiveness assessment 

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 recapped in this table, as services are not fully comparable. 
However, impacts are measured against baseline 

Option 1 – Full Public 

Option 2 – PPP/Concession 

Option 3 – Stake in non-EU constellation 

Costs 

Infrastructure  

6 billion 

Service costs 

Not applicable 

4 billion 

Not applicable 

Depending on the Equity stake to be taken 

400 million, bandwidth valued on market 
price basis. 

OPEX for the Union 

250 million 

170 million 

Not applicable 

Benefits  

Economy (GVA) 

(++) 

(+++) 

(+) 

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  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 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 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 sectors (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)  

Environmental 
benefits  

(++)  

(+++) 

(+) 

  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 
regarding 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).  

(-) 

(-) 

(=) 

 

 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 

  Governmental 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 could be used for environmental 

monitoring  

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Negative  environmental  impact  of  developing  and 
launching additional satellites 

Table 6: Efficiency 

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7.3.  Coherence 

As regards coherence with key EU policy objectives, the main objective of the initiative is to 
provide Member States 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 Strategy and in the global strategy for the European Union’s Foreign 
and Security Policy.  

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 targets 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.  

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 

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 States 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 

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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 needs98.   

Option 1 (Fully public) 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 
procurements 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 feasibility 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  the 
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.  Consultations  with  stakeholders  reveals  that  the 
majority of industrial stakeholders favours the PPP approach.  

Option  3 (Stake in  non-EU constellation) is  assessed to  have the 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,  because  it  would  require  the  EU  to  acquire  a 
significant amount of shares of a company established 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:  

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   

(=) 

(=) 

(=)  

(=)  

(=) 

(=)  

(=) 

(=) 

(=) 

(=) 

(=) 

(+++) 

(+++) 

(+++) 

(+++)   

(+) 

(--) 

(++) 

(++)  

(-) 

(+) 

(+) 

(+++) 

(+++) 

(+++) 

(+++)   

(++) 

(-) 

(+++) 

(+++) 

(-) 

(++) 

(+) 

(-) 

(-) 

(-) 

(--) 

(+) 

(=)  

(+) 

(+) 

(=) 

(-) 

(-) 

98 Detailed views of the different stakeholder groups can be found in Annex 2. 
99 Recital 104 of the Space Regulation 

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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  drawback  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. 

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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 services (economic growth, social benefits) 

  Optimises costs:  

-  development and deployment with economies of scale  
-  operations 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 commercial 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, the 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 ensure 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 

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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 relevant 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  concessionaire  should  be  the  only  architect  and  operator  of  the 
system.  

Finally, to 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 IMPACTS BE MONITORED AND EVALUATED?  

The initiative 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 threats/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 certain level (classified) and the equivalent 

101 Through its Security Accreditation Board 

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level of national classification in all EU Member States,  following the principles set 
in Council Decision (2013/488/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  

Frequency of 
measurement 

Ensure the provision of 
secure satcom for 
evolving governmental 
needs 

Increase the resilience of 
Member States and EU 
missions and operations 
by guaranteed access to 
satcom 

Ensure that 
governmental 
communication needs are 
not critically dependent 
on non-EU infrastructure 

  Global coverage (30° over 

  Concessionaire (with EUSPA 

  Daily 

horizon) 

  Service availability 
  Average latency 
  throughput 
  number of users 
  User’s satisfaction 

validation) 

  Member States 
  End-user EU Institutions and 

Agencies 

  Number of users 
  Volume of data used (i.e. 

  Concessionnaire 
  EUSPA 

  Quarterly 

  Quarterly 

system is used and 
capacity is sized properly) 

  Resilience to adverse 
events and threats 

  Availability of various 
ranges of end-user 
terminals 

  Report on use-cases in 
non-classified areas – 
level of ‘cross-
fertilisation’ between 
users 

  Assessment on critical 

components and maturity 
of EU supply chain 

  Member States 
  End-user EU Institutions and 

Agencies 

  Yearly 

  Commission with support of 

  Every second 

ESA and EUSPA 

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.  

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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, an end-user forum, similar to the one of Copernicus, 
would be established. 

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ANNEX  1:  PROCEDURAL 
COMMENTS FROM THE REGULATORY SCRUTINY BOARD 

INFORMATION AND  FOLLOW-UP  OF 

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  Commission  website  on  31  August 
2021102. 

2.  ORGANISATION AND TIMING  

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,  Content  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 Migration 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 Agriculture 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), European 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 

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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 
comparison 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 options to the implementation of this predetermined outcome; 
absence of a timescale and identification of funding sources 
clarity on methodological assumptions and validity of secondary data cited  
lack  of  explanations  on  the  compatibility  of  the  initiative  with  the  objectives  of  the 
Climate Law. 

(3) 
(4) 
(5) 

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  towards  higher 
security solutions, low latency103 and global coverage.   

However, the current EU satcom 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 there is not today any EU low latency solution 
(LEO and MEO) that could meet the evolving user needs.  

As explained in section 2.4, EU public and private stakeholders have indicated their intention 
not to pursue 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: amount of delay, measured in milliseconds (ms), that occurs in a round-trip data transmission to a satellite.  

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which requires an amount of CAPEX that could not reasonably be covered by a single 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  threat  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 disaster, as well as quantum 
computers.  

With regard to quantum key distribution, the initiative will include quantum technology with 
a  view  to  avoiding  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 distance 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  activities  need  to  be  conducted  between 
2022  and  2027  to  ensure  that  such  a  system  can  be  accredited  to  convey  EU  classified 
information (EUCI).It is important to remind that the Secure Connectivity initiative does not 
create the EuroQCI infrastructure or its space 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 average 
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).  

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The  use  of  private  satellites  is  not  considered  compatible  with  the  high  security 
requirements of QKD, because the satellite itself should be trusted 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 Internet 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  increasingly 
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. 

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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. 

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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 finally 
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 linked 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. 

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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 
below108; 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 ,  

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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 additions  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 operations.  

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 

Assessment.  

o  For  efficiency  against  the  preceding  analyses  carried  out  in  section  6  of  the 
Impact Assessment in terms of economic, social and environmental impacts. 

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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 Assessment) and the monitoring indicators (cf. section 9 of the 
Impact  Assessment)  comparison  criteria  have  been  systematically  flown  down  into 
monitoring indicators. The following table illustrates this point: 

Section 7 

Section 9 

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(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 significantly clarified between the first and second submissions 
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 
Communications  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 private 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  potential  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 optimized by profiting from such a well-established market. 

The situation is different from other EU space initiatives like Galileo, where in 2012 there 
was no functioning market for navigation and positioning services, no existing 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 Governmental Satellite Communications 
(HLUN) 

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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, the 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 requirements 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. 

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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  process  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 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 
costs 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 
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 

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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  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 infrastructure; 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 uncertainty of government’s demand 

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 manage 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’; 

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- 

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  beyond  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 States.  

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. The 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 be 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  allow  other  EU 
telecom operators to use a share of the commercial capacity; and 

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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 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 
intended 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 Title 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 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 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 to 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 along 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 solutions 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 procurement documents. 

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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. 

-  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 approach, 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 the 
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 concession 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 

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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 provided 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 envisaged to have recourse to a blending of various budgetary 
sources stemming from:  

o 

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); 
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. 

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, the 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 needed 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 financial scheme and the cost sharing between the public 

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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  contributions  can  be  envisaged,  in  accordance  with  the  following 
principle:  

  Public sector would 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  through  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 economic 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 addressed. 

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) 

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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 from 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 from 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 found 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 

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The environmental impacts 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 expected 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, compared to other industry sectors, 
the manufacturing of spacecraft does not emit significant greenhouse 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 per 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 large 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) 

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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  constellations  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 the 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 
contemplated 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  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. 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 aux 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 1999/45/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 
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. 

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significant 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, 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 and response 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 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 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.  

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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 technological 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, the 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 being 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  the  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  capacities.  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 already 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 Connectivity 

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  Consequently, several Member States stress the fact that  the capacity of the future 
system  needs  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 highlighted 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 solution:  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 Union 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 fact 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. 

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This Member Stated stressed the importance of including lessons learned 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 could 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 secure 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. 

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 coverage needs: 

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 transportation, 
machine-to-machine  and 
internet-of-
things  considerations,  and  access  to 
frequencies) reflect the general use cases. 

Second,  the  problem  definition  should 
clearly demonstrate the issues associated 
satellite 
with 
using 
infrastructure, 
the 
thus 
inclusion  of  a  specific  objective  on 
autonomous solutions.  

justifying 

non-EU 

Third,  the  options  should  address  the 
identified  problem  and  problem  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 

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.  

Connectivity  gap  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.  

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. 

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 to emerge. There is not today any EU LEO and MEO operational or project 

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problem  description 
insufficient supply.  

that 

there 

is 

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 this 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 expected 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 

o 

o 

o 

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 Eurospace122 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 market123; and finally  
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. 

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. 

74 

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It  should  further  explain  the  evidence-
based  rationale  and  urgency  for  the 
initiative,  which 
seems  accelerated 
compared  with  the  timing  of  the  two 
the  governmental  satellite 
phases  of 
(GOVSATCOM) 
communication 
deployment. 

C3 

The  problem  description  should  explain 
the  link between the European Quantum 
computing  infrastructure  initiative  and 
the  need  for  EU  government  satellite 
infrastructure. 
in 
particular, why quantum key distribution 
cannot  happen 
land 
through  private 
communication  or 
satellites,  and  whether  key  distribution 
through  satellites  would  not  depend  on 

It  should  clarify, 

through  secure 

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 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;  

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 database;  

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. 

The Quantum communication infrastructure EuroQCI is based complementary on a terrestrial 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 cybersecurity point of 
view, such infrastructure could still be subject to physical attacks on the terrestrial links themselves (i.e. damaging optical 
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 infrastructure 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.  

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75 

 
 
 
 
 
 
 
 
 
 
 
 
 
land  communication  for  at  least  part  of 
the connection. 

C7 

The  comparison  of  effectiveness  of 
options  should  stem  logically  from  the 
the 
preceding  analysis.  Moreover, 
the 
measures  used  under  each  of 
comparison 
security 
criteria 
accreditation,  quantum  key  distribution 
payloads,  etc.)  should  be  explained, 
allowing  for  clear  comparability  and 
more straightforward identification of the 
preferred policy option. 

(e.g. 

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 high security requirements, because the satellite 
itself should be trusted as it generates (or has access to) the cryptographic keys. 

  Options are compared 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  options  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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76 

 
 
 
 
 
 
 
 
 
 
 
 
 
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  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. 

During  the  procurement  process  of  the  concession,  the  applicants  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  would  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 costs 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 research 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 governmental services, no matter whether it concerns 
option 1 or option 2.  

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77 

 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

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 
public 
and 
procurement  process  as  well  as  the 
effective  participation  of  SMEs  and 
innovative start-ups would be ensured. It 
should  also  clarify  how  uncertainty  on 

efficient 

timely 

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. We envisage a 
blending of various budgetary sources stemming from:  

o 

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); 
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,  will be 
foreseen under the concession contract.  

Regarding 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. 

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 principles 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 

EN 

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78 

 
 
 
 
 
 
 
 
 
 
 
 
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  consistent  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 to 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 along 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 solutions 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 procurement 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 governments’ 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: 

EN 

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79 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
-  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 

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); 
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 cited and broadly employed for the 
economic estimates, benchmarks and multipliers in relation to the present initiative.  
C
5 

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 therefore 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 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 from EUR 27bn in 2009 to EUR 675bn in 2019, reaching a market share comparable to the US. 

The  report  should  further  discuss  the 
methodological validity and assumptions 
behind 
impact 
the  broad  economic 
estimates,  benchmarks  and  multipliers 
just  extracted  from  secondary  sources 
and done for projects of different scope 
and characteristics. It should also 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. 

EN 

    EN 

80 

 
 
 
 
 
 
 
 
 
to 

EU 

from 

similar 

  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 
represent 0.0008% of 2020 emissions. 

(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 
space 
other 
programmes.  It  is,  for  example,  not 
clear  why  the  environmental  benefits 
would  be 
those  of 
Copernicus, which has a much clearer 
focus  on 
for 
environmental  purposes.  The  report 
should also specify how it would ensure 
that  the  increased  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. 

  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  satellites  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  benefits,  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. 

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. 

earth  observation 

 

  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 

81 

EN 

    EN 

 
 
 
 
 
 
 
 
                                                           
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 within 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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82 

    EN 

 
 
 
 
  
 
 
 
 
 
ANNEX 2: STAKEHOLDER CONSULTATION   

Introduction 

The Commission actively engaged the stakeholders in the process of the initiative and consulted them 
on GOVSATCOM services and European secure quantum communication infrastructure (EuroQCI), 
as well as in the context 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 through 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  2021  on  the  inception  impact  assessment  of  the  space-based  secure  connectivity 
initiative125. The key findings of this consultation are summarised below.  

The facts and date collected via the stakeholder 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  consultations  of  stakeholders  have  taken  place  or  are  planned,  including 
workshops 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-    

connectivity-initiative_en  

EN 

83 

    EN 

 
 
 
 
 
 
 
 
                                                           
15.03.201
7 
(or 
we 
could  say 
ongoing 
as we still 
get input)  

High  Level  Civil 
User 
Military 
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) 

some 

80 
Brought 
together 
representatives  of 
the  various 
sectors  concerned.  In  both  events, 
the  hybrid  policy-options 
for 
GOVSATCOM  were  presented 
to 
which  had  been 
incorporate 
initial 
comments. Both meetings delivered 
the 
the  necessary  feedback  for 
Impact 
for 
GOVSATCOM. 

stakeholders' 

Assessment 

adapted 

06.06.201
7 

High-level 
meeting 
with 
member states and 
observers 
on 
GOVSATCOM 

High-level 
meeting  with 
member  states 
and observers  

2019 

Preliminary 
market 
consultation 
GOVSATCOM 

on 

Preliminary 
market 
consultation 

30.06.202
0 

EUSPA 
Market 
consultation  

Market 
consultation 
in 
preparation  of  the 
innovation 
partnership 
procurement 
GOVSATCOM 
Hub(s) 

of 

Workshop  with  EU  Member 
States  satellite  communications 
security  users,  EU  agencies 
involved, 
actors 
(space  agencies,  procurement 
agencies, 
Industry 
etc.)  and 
Associations for GOVSATCOM. 

institutional 

As  part  of  the  preparation  of  the 
GOVSATCOM  programme,  an 
extensive 
preliminary 
market  consultation  was  carried 
out  through  a  call  for  Call  for 
Expression of Interest. 

public 

for 

The  objective  of 
the  market 
consultation was to confirm whether 
the 
technical 
solutions 
Hub(s) 
GOVSATCOM 
infrastructure,  as  described 
in 
paragraph  1,  already  exist  in  the 
to  market 
market  or  as  near 
development activity. 

Link 

Link 

EN 

84 

    EN 

 
 
 
 
 
12-13.11. 
2020 

23.11.202
0 

16.12.202
0 

of 

the 

Impact 
Covid-19 
pandemic  on  EU 
and 
Aerospace 
Defence 
ecosystem 

Roadmap  for  the 
Action  Plan  on 
Synergies 
between 
Defence 
Space Industries 

Civil, 
and 

The 
Cybersecurity 
Strategy  for 
Digital Decade 

EU's 

the 

Workshop  

in  particular 
The  workshop 
consulted  on  space-based  secure 
connectivity. 

Link 

Public 
Consultation 

The  roadmap  included  a  point 
regarding secure connectivity.  

Link 

EU’s 
cybersecurity 
strategy 

EuroQCI 
cybersecurity strategy. 

is  part  of 

the  EU’s 

JOIN(2020) 18 final 

19.03.202
1 

Digital Day 2021  Event 

with 
Member States 

Ongoing  GOVSATCOM 
and 
EuroQCI: 
Building  Blocks 
Towards  a  Secure 
Space 
Connectivity 
System 

on 

Study 
GOVSATCO
M 
EuroQCI 

and 

Link 

Contract ref. DEFIS/2020/ 
OP/0008 

event 

brought 

The 
together 
Member States to discuss current 
and  future  challenges  of  digital 
technologies 
to 
and 
addressing  them,  including  secure 
connectivity.  

commit 

relevant 

than  60 

The  study  is  collecting  data  from 
more 
input 
documents  on  the  subject,  and  will 
deliver  an  aggregated  elaboration 
of  user  needs  for  GOVSATCOM 
and  EuroQCI  in  the  first  half  of 
2021. 

Ongoing 

ENTRUSTED 

Study  

Link 

of  Users 

A 
network 
for 
governmental 
Satellite 
(including 
Communications 
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 
coordinated  and  support  action 
the  GSA  called 
managed  by 

EN 

85 

    EN 

 
 
 
2  Studies  on 
EuroQCI 

Ongoing 

on 

the 

Study 
System 
Architecture  of  a 
Quantum 
Communication 
Infrastructure 

Ongoing 

EU 
space 
economics and the 
global context 

Study 
by 
SpaceTEC  and 
EuroConsult 

31.05.202
1 

States 
on 

Member 
workshop 
Secure 
Connectivity 

Workshop 
with  Member 
States 

15.06.202
1 

Secure 
Connectivity 
Initiative: 
Opportunities  for 

Workshop 
with SMEs and 
start-ups  

SMART 2019/0086 - LC-
01381549 
LC-
01381564 

and 

DG 
DEFIS 
712/PP/2018/FC 

FWC 

ENTRUSTED,  which  is  open  to 
participation  of  EU  Member  States 
institutions. 

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, 
further 
allow 
which  will 
accurately 
user 
describe 
requirements and use cases in order 
to determine the possible options of 
the architecture design. 

to 
the 

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. 

The  workshop  shared  the  technical 
findings  of  the  consortium  study, 
and  of  the  legislative  process  by 
who 
representatives, 
COM 
interacted  with  Member  States 
during the Q&A. 

The  workshop  was  designed  to  be 
attended by both industry and COM 
representatives,  who 
interacted 
within  guided  discussion  sessions 
and 
scheduled 
short 
matchmaking  sessions.  The  event 

via 

EN 

86 

    EN 

 
 
 
 
 
the European New 
Space Ecosystem. 

26.08.202
1 to  

Inception 
assessment 

impact 

23.09.202
1 

Public 
Consultation 
on 
Inception 
Impact 
Assessment  

the 

included  technology  focus  sessions 
at  which  preselected  presenters 
showcased 
solutions  and 
engaged in guided panel discussions 
relevant for the topics of the Secure 
Connectivity Initiative. 

their 

Link 

30.11.202
1 

States 
on 

Member 
workshop 
Secure 
Connectivity 

Workshop 
with  Member 
States 

The  workshop  shared  the  technical 
findings  of  the  consortium  study, 
and  of  the  legislative  process  by 
COM 
who 
representatives, 
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   

EN 

87 

    EN 

 
 
 
 
 
 
 
 
 
It has to be noted that since the public consultation exercise, option 2 - full private infrastructure has 
been discarded but for the sake of transparency and completeness, it is still presented. 

Private companies:  

0 

1 

2 

SES 

Intelsat 

Hispasat 

Airbus DS 

Telesat 

Eutelsat 

Oneweb 

ArianeEspace 

- 

--- 

+ 

+ 

--- 

--- 

--- 

3 

+ 

+ 

+ 

+ 

+ 

+ 

+ 

4 

For Commercial 

+ 

++126 

++ 

--- 

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  

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Positive towards the ESSCS initiative. No explicit statement on which model is preferred but stresses 
the need for:   

  Durable partnerships 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 deemed 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  

Strongly 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 terrestrial 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 connectivity 
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 the 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 evolution 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 initiative 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 elaborate 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  part  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-Ministries, 
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 operators 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  Member  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 
commercial 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  military 
satcom assets. One other Member State underlined that the initiative should federate civilian 
and military demands. It should also rely on Member 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 Member 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  should  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 Member 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 
satellites 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 satellites 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 yet 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  Connectivity  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 exploitation 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 potential interoperability with a foreign constellation (option 
3).  

o  Several  Member  States  asked  about  how  the  Commission  would  separate  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 innovative satcom solutions. The workshop showed 
that the New Space ecosystem is  technological  advanced 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 respect, 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 flexibility 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 satellites 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  Participants brought new technologies to the table ranging from 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 AFFECTED 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 system 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  interoperability  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  would  benefit  from  the  increased  capacity  and  reliable  service  offered  by  the  proposed 
infrastructure,  and  therefore  would  be  offer  a  higher  quality  of  service  to  their  customers.  If  the 
commercial services are exploited, the retail services would be able to reach more customers 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,  would  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, the citizens, particularly 
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 benefit 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  
Amount  
Description  
Direct benefits  
N/A 

 N/A 

Indirect benefits  

Fostering  the  growth 
of the EU space sector  

Six times the invested value 

Comments  

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.  

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.  
The initiative is estimated to generate an increase 
of  the  European  GDP  through  transactional 
effects  (investment 
the  space  economy 
in 
increase  the  value  added  in  this  sector,  of 
to 
suppliers  and 
expanding business and additional salaries which 
effects 
raise 
(downstream 
services, 
technologies  and  data  provided  by  the  space 
sector  to  enhance  their  business)  and  additional 
government revenues.  

consumption), 
sectors 

the  wider  economy  due 

spillover 
the 

use 

GDP increase  

Six times the invested value 

EN 

Investments  in  Space  upstream  infrastructure  is 
estimated  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  

Direct costs  
Indirect costs  

Establishment 
an  EU 
of 
space-based 
secure 
connectivity 
system 

Citizens/Consumers   
One-off  
N/A 

Recurrent  
N/A 

Businesses  
One-off  
 N/A 

Recurrent  
 N/A 

Administrations  
One-off  
N/A  

Recurrent  
 N/A 

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 GROWTH 

Extract from the study 'Building Blocks Towards a Secure Space Connectivity System’ 

Group 

Use case 

Surveillance  

Surveillance  

Border & Coast 
Surveillance 

Maritime surveillance 
and control 

2025-2030 

2030-2040 

Total addressable market 
(Mbps) 

Total addressable market 
(Mbps) 

                600.00  

              1,200.00  

             1,600.00  

              4,000.00  

Surveillance  

Connectivity for Vessel 
operators 

           96,000.00  

          192,000.00  

External Action and 
Crisis Management  

External action and 
crisis management  

External action and 
crisis management  

External action and 
crisis management  

External action and 
crisis management  

Maritime Emergencies 

                120.00  

                 240.00  

Police interventions 

             1,600.00  

              5,000.00  

Civil protection 

             6,000.00  

            15,000.00  

CSDP/CFSP missions 
and national defence 
operations 

             4,200.00  

              8,200.00  

Humanitarian aid 

         360,000.00  

          710,000.00  

# 

1 

2 

3 

4 

5 

6 

7 

8 

9 

Key Infrastructure  

10 

Key Infrastructure  

Institutional 
communications 

Air Traffic Management 
(ATM) 

Future Reduced Crew 
Operations 

Urban Air Mobility 

                500.00  

                 800.00  

                    1.12  

                     2.86  

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11 

Key Infrastructure  

Flight operations and 
Maintenance 
connectivity 

GADSS (Global 
Aeronautical Distress & 
Safety System) 

                  83.00  

                 188.00  

                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  

15 

Key Infrastructure  

16 

Key Infrastructure  

Space infrastructure – 
Copernicus secure data 
relay 

Space infrastructure – 
Galileo/EGNOS data 
transmission 

Energy production and 
transport 

Utilities production and 
transport 

             5,000.00  

            10,000.00  

                  43.75  

                   85.00  

             9,000.00  

            15,000.00  

             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) 

Finance – Banking (High 
Frequency Trading - 
HFT) 

                600.00  

                 800.00  

             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 initiative 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 
to  significant  greenhouse  gas 
leads 
(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. 

No further environmental impact as it rely 
only on existing satcom capacities.  

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. 

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 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. 

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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 environmental 
monitoring.  

See also application of article 17 (a). 

to 

(c)  An activity is considered to do significant 
harm 
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 
the  good 
environmental status of marine waters; 

to 

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. 

In general connectivity and IoT constitute a key enabler of circular economy solutions. 

(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  the  long-term 

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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) and hence 
their recyclability could rely on the provision of a ubiquitous IoT connectivity service.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 to 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  

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In conclusion, the secure connectivity does not significantly harm any of the environmental objectives, and even more can contribute to reduce the 
environmental 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.  

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