## 2 Satellites and 'Mega-Constellations'
### Satellite Constellations  
While [PERSON] states that satellite constellations are not yet subject to a formal legal definition ([PERSON], 2020, p. 246), [PERSON] describes them as \"a number of similar satellites, of a similar type and function, designed to be in similar, complementary, orbits for a shared purpose, under shared control\" ([PERSON], 2003, p. 13). Furthermore, similarities can be drawn between [PERSON]'s definition of satellite constellations and the definition of a 'communications satellite system' provided in the United States' Communications Satellite Act 1962 as follows:  
\"The term \"communications satellite system\" refers to a system of communications satellites in space whose purpose is to relay telecommunication information between satellite terminal stations, together with such associated equipment and facilities for tracking, guidance, control, and command functions as are not part of the generalised launching, tracking, control, and command facilities for all space purposes\".1  
Footnote 1: Communications Satellite Act 1962 (US) Section 103(1).  
Satellite constellations are not a wholly recent concept--they have existed since the 'Space Race' era. The first constellation of satellites was the Soviet Union's 1968 \"Molniya-1 constellation consisting of ten satellites\" ([PERSON], 2020, p. 247), which was launched in 1965. As to be expected, the other main actor in Outer Space in the 1960's, the United States, also launched a satellite constellation, specifically \"the first global satellite navigation system called 'Transit'. The first satellite of the Transit system was launched in 1960, and until 1968 there was a fully functional constellation of thirty-six satellites\" ([PERSON], 2020, p. 247). Furthermore, [PERSON] describes that \"[t]he 1990s were perhaps the public heyday of satellite constellations\" ([PERSON], 2003, p. 13), in this period when the expansion of mobile telephone and broadband services was truly taking off.  
Thus, satellite constellations have been in existence since some of humankind's first interactions with Outer Space. However, [PERSON] emphasises that \"the second decade of the twenty-first century brings about much larger projects, often referred to as mega-constellations. These projects consist of hundreds and even thousands of satellites synchronised under common control\" ([PERSON], 2020, p. 248).  
The present and future situation with regards to satellite constellations is detailed by [PERSON] et al.:\"Currently operating constellations serve a variety of important and crucial functions for society, including navigation and geodesy (for example, GPS, Galileo and GLONASS), satellite telephony (for example, Iridium), internet and TV (for example, ViaSat, Orbcom, GlobalStar) and Earth observation (for example, Copernicus and Planet). In the future, companies such as SpaceX, Amazon, Samsung, Telesat and OneWeb, and several national entities (for example, the Chinese and Indian Space Agencies) are planning very large constellations in low Earth orbit (LEO)\" ([PERSON] et al., 2021, p. 3).  
It was in 2019 that [PERSON]'s SpaceX began launching the first satellites for the 'Starlink' constellation that would be made up of thousands of satellites in LEO ([PERSON], 2020, p. 1). It was after this launch that it was realised that some of the satellites in LEO \"remained naked eye objects\" ([PERSON], 2020, p. 1) in the sky and this move towards satellite mega-constellations and many of the considerations of its impact on astronomy that form the crux of this article arose.  
With the current situation in Outer Space with regards to satellites and mega-constellations outlined, the next section will investigate the law applicable to these satellites and satellite constellations.