You Manage What You Measure: Achieving Space Sustainability and Self-Regulation of the Outer Space Industry Through Environmental,Social,and Governance Corporate Disclosure

Abstract

The prospect of self-regulation for the space sector is discussed in this study. The article is divided into three sections. The Overview section offers an outline of international guidelines and industry standards and the benefits they provide on controlling commercial use of space. The Case Study and Implications for the Commercial Use of Space section examines how publicly listed corporations disclose outer space activities in accordance with international guidelines and standards. This section offers insights on disclosure practices from U.S. and non-U.S.-based corporations that are found in the Procure Space Exchange Traded Fund. Some of the corporations included in the Exchange Traded Fund are Dish Network Corporation, Garmin Ltd, Sirius XM, Virgin Galactic Holdings, Inc., Lockheed Martin Corporation, Boeing, and Echostar Corporation. The Case Study and Implications for the Commercial Use of Space section highlights that the commercial use of space is not widely considered by international guidelines and industry standards. The Recommendations and Challenges section concludes by not only offering recommendations but also recognizing future challenges for space sustainability.

OVERVIEW

Introduction

This article proposes the possibility of self-regulation for the space industry, as found in the extractive and mineral processing sector. The Overview section begins by outlining the international space law framework, international guidelines, industry standards, and the Environmental, Social and Governance (ESG) movement and what they each offer in terms of regulating the commercial use of space. The Case Study and Implications for the Commercial Use of Space section sets out a case study on Procure's Space Exchange Traded Fund (ETF) (Ticker: UFO) and analyzes the available sustainability reporting from the corporations that are included in this ETF portfolio.

This section offers insights on disclosure practices from U.S. and non-U.S. based corporations, corporations that file global reporting initiative (GRI) Reporting, and corporations that are influenced by the United Nations Sustainability Development Goals (SDGs). This is in an effort to answer: What information is made available from the disclosure documents provided by corporations that conduct business activities in outer space? The Case Study and Implications for the Commercial Use of Space section illustrates that international guidelines and industry standards are silent on the commercial use of space. The Recommendations and Challenges section outlines recommendations and future challenges on space sustainability.

International Space Law Framework

Treaties, declarations, and resolutions

Although only a brief description of the international space law framework is provided here, it is, nonetheless, pertinent for any reader to be aware of the legal instruments that come to play for space sustainability.¹^,^* International space law is one segment of public international law. The Outer Space Treaty (OST)²^,^† is the only space treaty out of the five that is considered to have entered customary international law status.³ One of the central principles found under the OST is that the free access, exploration, and peaceful use of outer space is governed within the domain of international law.²

The remaining space treaties, declarations of principles, and United Nations (UN) resolutions add color to the OST by providing guidance on liability issues,⁴ governing how information regarding the registration and accountability measures can be promptly requested and provided to a public register maintained by the UN,⁵ and promoting consistency on national legislation and practices among space-faring states.⁶ The crux of this article focuses on international guidelines and industry standards that can also create further leverage to regulate the commercial use of space.

Environmental, Social, and Governance

Corporate action

The emergence of both Corporate Social Responsibility (CSR) and ESG stem from the adoption of policies and practices that aim at creating a positive societal change. The precursor to ESG is CSR. However, the concepts should not be used interchangeably because each concept has definitive characteristics and goals. The CSR is a management philosophy that aims at benefiting society through charitable efforts and philanthropy by using corporate profits. Therefore, CSR develops internally from board directors and senior management.

The CSR is intended for business accountability, whereas ESG standards and guidelines are intended to quantify business performance in reference to sustainability. The ESG refers to three separate components used by socially motivated investors and stakeholders to identify a corporation's societal impact (whether negative or positive). Therefore, the development of ESG is external. Both CSR and ESG promote self-regulation whereas ESG also allows investors, consumers, and stakeholders to understand the corporate practices in relation to ESG issues.

For ESG investors, the primary goal of investing is not only to make profits but also to improve sustainability for long-term investment. Consumers are also socially motivated, as their purchasing decisions are impacted by a corporation's measure of sustainable and socially responsible business practices. The ESG movement has intensified since the COVID-19 pandemic, which allowed corporations and governments to reassess business operations. The ESG principles are also prominent in international guidelines and industry standards.

International Guidelines and Industry Standards

United Nations SDGs

The United Nations established the SDGs in 2015 to create economic, social, and environmental outcomes for member countries to achieve by 2030. The SDGs succeed the Millennium Development Goals (MDGs), which created a framework to address global issues and achieve intergenerational equity. Although the goals were designed for nation-states, corporations were also expected to contribute toward achieving the SDGs.⁷

The United Nations Global Compact in collaboration with the GRI and the World Business Council on Sustainable Development (WBCSD) created a Guide for Business with 17 goals. The UN Guide for Business ascribes to several frameworks, principles, and guidelines for responsible and ethical business conduct such as the UN Guiding Principles on Business and Human Rights, the UN Global Compact Principles, and the International Labour Organization (ILO) Tripartite Declaration of Principles Concerning Multinational Enterprises and Social Policy.⁷

These frameworks, principles, and guidelines instruct corporations to uphold certain minimum standards and respect universal rights. The United Nations SDGs require corporations to understand SDGs, define their priorities, set goals, integrate their goals with their corporate behavior, and report and communicate on their SDG performance. In its current state, there is no specific reference in the UN SDGs made to space sustainability. However, among the goals, the most relevant to space sustainability are to ensure access to affordable, reliable, sustainable, and modern energy for all; industry, innovation, and infrastructure; responsible consumption and production; and partnerships for the goals.⁷

International soft law instruments create expectations for corporations to understand the risks of their activities and address adverse impacts on human rights. There are several tools that companies can use to measure progress and to report a company's contributions, including the UN Global Compact,⁸ the SDG Compass⁹ as created by the GRI, the International Standards of Accounting and Reporting,¹⁰ and the WBCSD.¹¹

Other international frameworks, principles, and guidelines that are designed to direct corporations to respect universal rights include the UN Global Compact Principles¹² and the UN Guiding Principles on Business and Human Rights (UNGP).¹³ As identified by The Hague in Shell, “the UNGP constitute an authoritative and internationally endorsed ‘soft law’ instrument, which set out the responsibilities of states and businesses in relation to human rights.”¹⁴ The UNGP asserts that the states are responsible toward protecting human rights abuse within their jurisdiction by third parties, including corporations.

The Court in Shell recognizes that the UNGP and other soft law instruments—such as the UN Global Compact and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises—universally endorse that corporations must respect human rights, which includes “the need to protect the environment, public health and safety, and generally to conduct their activities in a manner contributing to the wider goal of sustainable development.”¹⁴

The SDG Compass can also be used by corporations to discover new growth opportunities in areas of innovative technologies, protect and create value by strengthening the brand or improving operational efficiency, strengthen stakeholder relations, strengthen societies and markets, and unify the priorities and purposes for all corporations.⁷

Global reporting initiative

The GRI is an independent, international organization supported by the United Nations Environment Programme and created by the Coalition of Environmentally Responsible Economies (CERES) and Tellus Institute.¹⁵ The GRI created standards for sustainability reporting for businesses and other organizations. The establishment of the GRI stems from the sustainable development goals made by the World Commission on Environment and Development in 1987, in which the GRI serves as a voluntary, multi-stakeholder accounting tool for corporations and enables greater transparency. Corporations that participate in GRI Standards for sustainability reporting follow standards relating to economic, environmental, and social topics.¹⁶

The framework includes “general standard disclosures” and “specific standard disclosures” based on specific industrial ESG risks and opportunities. The GRI standards are recognized as providing technical expertise and are reflected in stock exchange listing requirements and in some domestic laws.¹⁷

In a 2004 UN Global Compact report called “Who Cares Wins: Connecting Financial Markets to a Changing World,” 18 institutions in the financial industry with more than 6 trillion USD in total assets under management from 9 countries reported recommendations to integrate ESG issues in their lending and investment analysis, asset management, and securities brokerage.¹⁸ A central finding from the report indicates that corporations tend to perform better and increase shareholder value when incorporating ESG principles, corporate policies, and risk management. The report highlights various recommendations to properly consider ESG factors for different stakeholders:

Analysts, consultants, and financial advisors are urged to include ESG analysis in their research and use tools, models, and research from academic institutions and research organizations to explore the implications for sustainable development. They should demand research on ESG aspects with industry-level expectations.

Financial institutions are encouraged to commit to ESG factors at the senior management and Board level in a systematic way toward investment research.

Companies are advised to adopt ESG principles and policies, and to provide corporate disclosure reports in a standardized format and identify ESG challenges and value creation opportunities.

Investors, asset managers, and pension fund trustees and selection consultants should request research on ESG principles and consider well-managed corporations. Those with a fiduciary obligation to participants and beneficiaries should invest in corporations that endorse sustainable development.

Regulators, governments, multilateral agencies, and non-governmental organizations (NGOs) should create legal frameworks based on promoting transparency and accountability on ESG issues and should encourage voluntary participation in the GRI.

Stock exchanges are encouraged to include ESG criteria for listed corporations, including minimum disclosure requirements on ESG issues.

These recommendations based on enhanced disclosure practices aim at improving sustainable development, creating more resilient financial markets, improving trust in financial institutions, and promoting uniform understanding and standards for involved stakeholders.

Sustainability Accounting Standards Board

The Sustainability Accounting Standards Board (SASB) is an independent non-profit organization that established industry standards to maximize the disclosure of financial sustainability information by publicly listed corporations to their stakeholders. This would improve the ability of investors to assess the business valuation of a corporation more accurately and provide information to stakeholders. The SASB Standards set out ESG issues for 77 industries, which are voluntary. The industry-specific SASB Standards include disclosure topics, accounting and activity metrics, and technical protocols for each industry.

The SASB refers to sustainability as “ESG” and promotes sustainability accounting standards to ensure corporate activities “maintain or enhance the ability of the company to create value over the long term.”¹⁹ The SASB Standards are recognized as being globally applicable by leading global asset managers and investment intermediaries such as Vanguard, BlackRock, Bank of America, J.P. Morgan Asset Management, Morgan Stanley, Wells Fargo, and Royal Bank of Canada, among others in the Investor Advisory Group of the SASB Alliance.

The SASB requires the reporting of sustainability and financial information that meets the definition of materiality as defined by the US Securities and Exchange Commission (SEC).²⁰ The SEC has faced two contradictory pressures to adjust the “materiality” definition. On one front, proponents of sustainability metrics have urged the SEC to use the “advance societal good” mandate. In addition, the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 required the SEC to pass rules compelling public companies to provide disclosure on mine safety, conflict minerals, and payments made to foreign governments.

In contrast, there are also deregulatory forces from the Jumpstart Our Business Startups Act of 2012.²¹ The concern is that the definition of materiality carries a different meaning for the purposes of the SEC and the SASB.²² The use of the term materiality is important to corporations in two ways. First, securities regulation has compliance requirements based on timely and continuous disclosure. Materiality informs the disclosure thresholds and creates legal obligations for publicly listed corporations.

Second, the requirements relating to the disclosure of material information are intended to protect investors. The SASB is of the view that the standard for sustainability information fits within the definition of materiality and is crucial information demanded by investors,²³ whereas the SEC has not taken this position for its disclosure requirements.

Based on findings from these guidelines and standards, it is revealing that there are many gaps between voluntary disclosure and corporate performance. The usefulness of disclosure may be limited without a mandatory regulatory and enforcement framework to monitor the accuracy and reliability of sustainability reporting.²⁴ A mandatory regime based on transparency would produce comprehensive, useful, and valuable information, which would cause a shift in corporate behavior.²⁵

Therefore, investor preferences is one important factor that will promote corporate efforts to achieve sustainability and allow for a self-regulating industry to emerge and flourish. Other factors include public policy (regulation and enforcement to mandate ESG-based disclosure), consumer, employee, and activist pressures, and technology. Investment behavior alone will not achieve ESG performance improvements.²⁶ Once mandatory disclosure on ESG issues is implemented, investors and regulators would create the necessary pressure to alter corporate behavior, thus creating self-regulating industries. The process starts with stakeholder pressures, as ultimately there is no publicly listed corporation that can ignore its investors.

CASE STUDY AND IMPLICATIONS FOR THE COMMERCIAL USE OF SPACE

The Case Study and Implications for the Commercial Use of Space section aims at answering: What information is made available from the disclosure documents provided by corporations that conduct business activities in outer space? Also included in this section is a case study on Procure's UFO ETF and it analyzes the available space sustainability reporting from the corporations included in the portfolio. This Section highlights insights on U.S. and non-U.S.-based corporations, corporations that file GRI Reporting, and corporations that are influenced by the UN SDGs.

The section further identifies a significant gap in existing international frameworks and corporate disclosure practices on space sustainability. The Case Study and Implications for the Commercial Use of Space section concludes by reporting the study limitations.

Procure Space ETF (Ticker: UFO) and Space Sustainability Reporting

Overview and hypothesis

The purpose of this case study is to examine how publicly listed corporations disclose business activities in accordance with domestic and international securities laws and standards. To the author's knowledge, there is no literature on the examination of corporate disclosure from corporations who operate in space. This will be the first study to examine whether these corporations in relation to the UN SDGs (1) fail to provide complete disclosure, (2) fail to report targets and challenges, or (3) fail to report negative outcomes from business activities, such as space debris.

The Procure Space ETF, UFO, captured interest from investors who are attracted to the commercialization of the space economy. The author selected this ETF, because the portfolio comprises corporations that have material exposure to space-related industries such as satellite and telecommunications (manufacturing and operation), space technology, and space resource exploration and extraction. Most of these publicly listed corporations have a website dedicated to investor relations, where recent disclosure documents may be found. In addition, nearly half of the corporations are GRI participants. Some of these corporations are participants in the UN Global Compact.

Procure Holdings is a parent company in the ETF industry. The UFO is listed on the NASDAQ securities exchange as of April 11, 2019.²⁷ Eighty percent of the investment portfolio are companies that generate 50% or more revenue or profits from one or more segments of the space industry. Space-related industries include (1) rocket and satellite manufacturing and operation, (2) ground equipment manufacturing used with satellite systems, (3) space technology and hardware, (4) space-based imagery and intelligence services, and (5) telecommunications, television, and radio broadcasting.

This ETF also includes emerging industries, such as: (1) space colonization/infrastructure, (2) space resource exploration/extraction, (3) space-based military/defense systems, (4) space tourism, including transportation and hospitality, and (5) space technologies that enable the space economy. Some of the corporations included in the ETF are Dish Network Corporation, Garmin Ltd, Sirius XM, Virgin Galactic Holdings, Inc., Lockheed Martin Corporation, Boeing, and Echostar Corporation.

This study has three hypotheses. First, all corporations in the United States will provide less disclosure on space sustainability in their corporate disclosure documents compared with non-U.S.-based corporations. Second, it is expected that corporations that file GRI reporting will likely offer a higher level of transparency on space sustainability issues compared with corporations that do not. Finally, it is expected that the disclosure documents for all corporations will fail to provide full disclosure in reference to the UN SDGs in terms of key indicators and challenges. The UN SDGs issues are used as a benchmark for this study due to their comprehensiveness and their applicability to the space industry.

Methodology

This study will review the corporate disclosure provided by the corporations found in the Procure Space ETF. The coding of the data will be in reference to the UN SDGs.²⁸ In its existing form, the UN SDGs do not include space sustainability goals; however, the framework is the most comprehensive set of ESG issues that are applicable for space sustainability, such as, SDG 7 (affordable and clean energy), SDG 9 (industry, innovation, and infrastructure), SDG 12 (responsible consumption and production), and SDG 17 (partnerships for the goals).²⁹ For this reason, this case study will examine the publicly listed corporations found in Procure Space ETF in accordance with these UN SDGs.

The corporate disclosure documents are retrieved from the GRI Sustainability Disclosure Database,³⁰ the UN Global Compact participants list,³¹ and corporate investor relations websites. The Database was last updated in December 2020. A review of the corporation's investor relations website was necessary to find the most up-to-date sustainability reporting for most of the corporations.

Twenty-six out of the 36 corporations in the UFO portfolio have investor websites on ESG/Sustainability/CSR matters. The investor relations websites are designed as a centralized database for disclosure documents. These websites are useful tools for researchers and stakeholders of the companies; they can help to bridge the gap on full disclosure pertaining to any issue, including space sustainability. All investor relations websites are expected to be up to date due to compliance with securities laws, which is an advantage compared with the lack of updates made to the GRI Sustainability Disclosure Database.

Results

U.S. corporations and disclosure practices

Among the 10 US corporations that provide GRI reporting, only 2 corporations (Lockheed Martin Corporation and Boeing Corporation) offer disclosure on space sustainability shown in Table 1. As found on the GRI Sustainability Disclosure Database, the 2019 Sustainability Report from Lockheed Martin discusses space debris under its Product Impact section. Lockheed Martin reports a case study on an advanced radar technology solution for space debris and satellites, referred to as Space Fence.

Table 1.

U.S. Corporations and Sustainability Statistics

No. of U.S.-Based Corporations	GRI Reporting	UN Global Compact Participants	Corporate Sustainability Resource Website	Corporations That Provide Disclosure on Space Sustainability
23	10 out of 23	1 out of 23	17 out of 23	7 out of 23

GRI, global reporting initiative.

This solution offers the ability to detect and track objects found in low Earth orbit (LEO) (even as small as a peanut), as well as objects found in the medium Earth and geosynchronous Earth orbit. Space Fence aims at accurately predicting the orbit of debris and satellites to avoid future collisions and satellite breakups, which would allow for the increase in the United States Space Surveillance Network's catalog and reduce the threats for important space assets, including the International Space Station.

Lockheed Martin recognizes that space debris “litters the skies” and is a threat to essential services such as banking, communications, GPS, weather forecasting, and other services.³² In the foreseeable future, Lockheed Martin predicts tens of thousands of new objects launched into space, in which the Space Fence program would help to address such emerging threats in advance. In 2019, Lockheed Martin was recognized by Corporate Responsibility Magazine on its 100 Best Corporate Citizens List, and the company is ranked first out of 16 Aerospace and Defence companies and 41st out of 922 companies overall by JUST Capital.

Boeing is a GRI Reporting participant that provides disclosure in its 2020 Annual Report on nine space-related programs, products, and services, including its CST-100 Starliner, Space Launch System, commercial and government satellites, and X-37B Orbital Test Vehicle. Boeing supported every major U.S.-based endeavor to space, including work completed for the National Aeronautics and Space Administration (NASA), the International Space Station and United Launch Alliance (a joint venture with Lockheed Martin).

Boeing does not include disclosure on space debris as a risk to business performance in its 2020 Annual Report but does note technological advances on efficiency and energy management for its space products as a future area of concern for space sustainability.

Among the 13 corporations that do not provide GRI Reporting, nearly half (6 corporations) highlight some outlook on space sustainability in its disclosure documents. However, half of these corporations offer limited transparency. Out of the six corporations, Orbcomm in its 2020 Annual Report and Sirius XM in its 2019 Annual Report reference limited disclosure on space sustainability or space debris. Both companies mention space debris and potential satellite collisions in their forward-looking statements or in their business risk section, but there is no ESG or sustainability disclosure of their space activities or resources.

In addition, as found in Trimble's 2020 Sustainability Report, the company promotes the UN SDGs, which are used to inform its own targets, goals, and priorities. Although Trimble is listed in the Responsible Business Alliance (2021) and among Investor's Business Daily 50 Best ESG Companies, the company's Sustainability Report (2020) discloses limited information on its second largest business segment (geospatial).

The remaining three corporations offer considerable disclosure on space debris and space sustainability. In its 2020 Annual Report, Globalstar not only recognizes space debris as a business risk to its satellite network and performance but also acknowledges central limitations. First, Globalstar recognizes that their capability to maneuver satellites in orbit is limited due to inaccuracies and uncertainties in the orbit location. It is possible that the debris objects tracked and catalogued by the U.S. government may not capture up-to-date changes in space or the debris may be too small to be tracked.

The risks from space debris or collision could create significant losses for the satellite company, which is mentioned throughout the Annual Report. Likewise, Loral Space in its 2020 Annual Report recognizes the risks of space debris and collision on the life cycle of its satellites. Loral Space identifies environmental risks from LEO constellations such as the potential for “light pollution” from the reflection of light off satellites during night.³³ According to Loral Space, future environmental policy may impose restrictions or regulations on satellite operations due to space debris, collisions, or light pollution.

In Iridium's 2020 ESG Report, the company provides a breakdown on environmental impacts from satellite operations. The company recognizes the increasing risk of collisions from space debris and satellites. Iridium states its commitment toward keeping space clean and aims at becoming a leader for other organizations on responsible space stewardship. Iridium shares its experience on space impact with regulatory bodies to help create and maintain industrial standards for space debris mitigation and satellite management.

In its 2020 ESG Report, Iridium reports a collision of an uncontrolled satellite that crashed into Iridium-33 in 2009. This created an opportunity for the company to work closely with the U.S. government, NASA, and the U.S. Air Force to create best practices for end-of-life satellite disposal and space operations. The company works with other industry participants that conduct business activities in space to promote enhanced monitoring of space objects and transparency.

Iridium works with the U.S. Air Force Combined Space Operations Center, which, according to Iridium, is the primary knowledge leader in space debris. This partnership allows for the creation of data for space catalogs to track space debris. Iridium also works with other working groups such as the Space Safety Coalition, the Joint Functional Component Command for Space, and the Conjunction Assessment technical Advisory Council to communicate and monitor space traffic data and improve space situational awareness.

Iridium received the SpaceNews Space Stewardship Award in 2019 for the successful deorbiting of its first-generation constellation. Since its inception, Iridium has removed more than 36,000 kg of space debris by removing its satellites safely. Iridium participates in government lobbying, public appearances and in ongoing media activities to implement clear requirements for a space traffic management policy and to ensure “there remains enough space for us all.”³⁴

Non-U.S.-based corporations and disclosure practices

Out of the GRI participants who are non-U.S.-based corporations, only three corporations (Eutelsat Communications, SES S.A., Airbus Group), provides disclosure on space sustainability shown in Table 2. In Eutelsat's 2019–2020 Universal Registration Document, the company acknowledges that space debris and end-of-life of satellites is becoming progressively important to the company's communication satellites in space. The company made commitments to de-orbit satellites and reduce the risk of space pollution.

Table 2.

Non-U.S.-Based Corporations and Sustainability Statistics

Number of Non-U.S.-Based Corporations	GRI Reporting	UN Global Compact Participants	Corporate Sustainability Resource Website	Corporations That Provide Disclosure on Space Sustainability
13	6 out of 13	4 out of 13	9 out of 13	4 out of 13

The company provides complete transparency on its success rates. Eutelsat has a 95% success rate on de-orbiting and passivating 21 satellites that reached their end-of-life by June 2020. Eutelsat repositioned 107 satellites in the geostationary orbit with a 100% success rate as of May 2020. These indicators on space debris and repositioning were not highlighted by any of the U.S. corporations.

Eutelsat incorporated a global environmental policy that includes satellite fleet management. Within this area, Eutelsat is conscious of space congestion issues, the environmental impact of a satellite's life cycle, and takes a proactive approach to reduce space debris. Eutelsat works with its satellite manufacturers (Airbus Group, Northrop Grumman, Maxar Technologies, and Thales) and launch service providers (Arianespace and International Launch Services) to reduce the environmental impact. To reduce space debris in the geostationary orbit, Eutelsat re-orbits its satellites into a “graveyard orbit, approximately 300 kilometers beyond geostationary orbit using the remaining on-board propellant.

Satellites never return to Earth, nor do they re-enter the Earth's atmosphere.”³⁵ In the near future, Eutelsat aims at launching low-orbit nano-satellites that will comply with French space laws (French Space Operations Act)³⁶ and international regulations. Eutelsat received the ISO 9001 standard certification for satellite control and operations. Eutelsat's Space Debris Mitigation Plan (“Plan”) includes end-of-life operations, remedial measures for anomalies, colocation strategies, repositioning, and station-keeping maneuvers.

The Plan is informed by the Inter-Agency Space Debris Coordination Committee (“IADC”) Space Debris Mitigation Guidelines,³⁷ the European Code of Conduct for Space Debris Mitigation,³⁸ and the French Space Operations Act³⁶; however, the company's policy is more stringent than the requirements found in the regulations and is updated frequently to incorporate new standards.

To avoid repositioning collisions, Eutelsat seeks aid from U.S. Strategic Command data and the EU Space Surveillance and Tracking anti-collision service found in the Space Data Association database. Eutelsat conducts studies on the dangers associated with space object collisions that can impact the environment, life on Earth, and public health. Eutelsat conducts workshops on end-of-life operations and outer space debris, including its workshop with the United Nations Committee on the Peaceful Uses of Outer Space (“COPUOS”) Scientific and Technical Subcommittee on “Long-term Sustainability of Outer Space Activities.”³⁵

The SES in its 2020 Annual Report provides an ESG section on space debris management and lifecycle analysis of satellites. Like Eutelsat, SES has a corporate policy on responsible satellite fleet management, which includes working closely with satellite manufacturers and launch service providers (SpaceX) to mitigate and minimize space debris and other environmental impacts. The SES conducts internal and third-party annual audits with accredited organizations to reduce the company's environmental footprint.

The SES cites in its ESG disclosure document that the United Nations General Assembly recognizes “that space debris is an issue of concern to all nations.”³⁹ Similar to Eutelsat, SES refers to a graveyard orbit, stringent international standards, and the use of the Space Data Association (SES is a founder) to enhance the integrity and safety of satellite operations. According to the SES website on ESG matters, building and launching satellites into orbit has an impact on the terrestrial environment because of falling space debris occurrences.

The SES acknowledges that although many of the impacts remain unknown, the company aims at taking a proactive approach to maintaining the highest environmental standards for satellite operations and creating better tracking measures for risks and problems relating to “space junk.”

Airbus also refers to space debris in its 2020 Annual Report. For the company's space sector, Airbus works with European governments and institutions to promote the long-term sustainable usage of space and the prevention of space debris. In its Annual Report, Airbus claims it is the first company to test technologies (harpoon, net, and vision-based navigation) that clears space debris and prevents collisions of spacecraft. This aligns with the French Space Operations Act, which requires the safe removal of space objects at their end-of-life cycle from a useful orbit and to avoid collisions in space. Airbus has a Sustainability website, which includes a product responsibility section. However, this does not include its satellite operations and disclosure on space debris.

Among the 13 non-U.S.-based corporations, two corporations (Sky Perfect and Avio) provide some disclosure on space debris and space sustainability in accordance with the UN SDGs (but do not provide GRI Reporting). Sky Perfect recognizes that there are many satellites that are no longer functional or used and if such space debris is not removed there are heightened risks of space collisions. In reference to space debris, Sky Perfect claims it is the first company to design and develop a satellite that uses a laser to remove space debris. The laser technology “nudges” the space debris back into the atmosphere, which causes it to burn up when falling. This method is considered safe, because physical contact is eliminated entirely.

The laser satellite does not require fuel to move space debris, making the method economical for removal. Avio is aiming at developing new technologies to remove space debris. Avio proposes a Vega In-Orbit Service, which uses an Avum Orbital Module and a Service Module. These Modules in combination allow for the use of propulsion and the use of a robotic arm to approach the debris and perform a de-orbit maneuver. This can be either a controlled return to Earth or parking the debris in a “graveyard orbit.” Avio is also a part of a collaboration with the United Nations Office for Outer Space Affairs (“UNOOSA”), “Access to Space 4 All.” This initiative includes launching nine mini-satellites for member states of the United Nations who are developing countries. The goal is to encourage developing countries to enter the space economy while maintaining sustainable development objectives.

UN SDG reporting

Out of the 36 total corporations in the UFO ETF, 8 corporations report on UN SDGs. However, four out of the eight corporations (Trimble, Weathernews, AT&T, and TomTom) do not clearly formulate their disclosure reporting on space sustainability in relation to the UN SDGs. The remaining four corporations relate space sustainability disclosure to their UN SDGs.

Sky Perfect identifies nine materiality themes based on the UN SDGs, which includes improving the environment in space. Under this theme, Sky Perfect announces initiatives to remove space debris. For Sky Perfect, space debris and improving the energy efficiency of satellites are identified as an issue. These two issues are found under the UN SDGs 7, 9, 12, 13, and 15 as reported by Sky Perfect. For space debris, Sky Perfect classified the concern under UN SDGs 9 (9.1, 9.4, and 9.5) and 12 (12.1, 12.2, 12.4, and 12.5). For improving energy efficiency, Sky Perfect considered the company initiatives under UN SDGs 7 (7.2 and 7.3), 9 (9.4), 12 (12.5), 13 (13.1 and 13.2), and 15 (15.1). Sky Perfect's efforts toward improving these environmental concerns are addressed earlier.

In its 2020 ESG Report, Iridium analyzed their business operations in accordance with the UN SDGs and SASB. However, it is not clear which UN SDG is referred to when considering the disclosure on product end-of-life management and mitigation of orbital debris. Iridium focused on 6 UN SDGs, including: 4 (Quality Education), 9 (Industry, Innovation, and Infrastructure), 12 (Responsible Consumption and Production), 13 (Climate Action), 14 (Life Below Water), and 15 (Life on Land). Among the most relevant UN SDGs to space debris, it is likely that the UN SDGs 9, 12, and 13 were used to inform Iridium's 2020 ESG disclosure document on space sustainability.

In Avio's 2019 Consolidated Non-Financial Statement, the company identifies sustainability and innovation as a core influence on its business model, especially its potential impact on the Space Sector. Among the eight UN SDGs that Avio follows, three of the SDGs and Statements are linked to space exploration, including: UN SDG 4 (Quality Education and initiatives aimed toward incubating technical skills), UN SDG 9 (Industry, Innovation and Infrastructure for launch applications and orbital applications), and UN SDG 17 (partnerships to improve sustainability in space and decrease the technological gap between countries).

Lastly, Thales also reports based on the UN SDGs as found in its Corporate Responsibility Integrated Report 2019–2020. Thales recently incorporated additional UN SDGs into its CSR policy (increasing from 4 UN SDGs to 10). Under UN SDG 13 (Climate Action), Thales focuses on reducing the impact of space activities and products on climate change. One example of this is its autonomous Stratobus stratospheric geostationary platform, which uses 100% solar energy to reduce its environmental impact.

The Stratobus is manufactured from recyclable subsystems. Another example of Thales climate action responsibility is its SWOT satellite, which, according to the Integrated Report (2019–2020), will be the first satellite in the world designed not to leave any orbital debris at the end of its life cycle.

Discussion

Hypothesis 1: Corporate disclosure practices

Hypothesis 1 predicted that non-U.S.-based corporations would provide more transparent disclosure on space sustainability concerns compared with U.S.-based corporations. In terms of the number of U.S. corporations that provided some disclosure on space sustainability compared with non-U.S. corporations, the difference is negligible. Seven out of 23 U.S. corporations included some disclosure (30.4%) compared with four out of thirteen non-U.S.-based corporations (30.8%). Collectively, Iridium, Eutelsat, and SES are the only corporations that include important indicators on space debris and space collisions. However, only the two European companies (Eutelsat and SES) have corporate policies in place on responsible satellite fleet management. Iridium is currently lobbying for space traffic management policy, but it is not clear whether the company has an internal corporate policy on space traffic.

Further, Airbus, Sky Perfect, and Lockheed are the only corporations that have initiatives on detecting, tracking, and avoiding collisions in space. Airbus and Sky Perfect have made technological advancements toward clearing the space debris, whereas Lockheed's initiative focuses solely on tracking objects to avoid collisions. European companies are governed by laws and guidelines that enforce the safe disposal of space objects at their end-of-life cycle from the orbit and to avoid collisions in space.

This may be the reason why there is a higher level of disclosure and initiatives on space debris removal from non-U.S.- based companies compared with U.S. companies. Aside from Iridium and Lockheed, the remaining five U.S. companies indicate some acknowledgment of the risks of space debris, but they do not include disclosure on how the companies address the risks. Three other U.S. companies addressed separate space sustainability issues. Both Boeing and Thales recognized the need for enhanced efficiency and energy management in space products, and Loral Space acknowledged the potential for “light pollution” from satellites.

Overall, the number of U.S.-based and non-U.S. corporations found in the UFO ETF that provide space sustainability disclosure is similar. However, there are nuances in the type of disclosure, as noted earlier, which indicates that non-U.S.-based corporations include a higher degree of information and transparency compared with U.S.-based corporations. Due to this finding, Hypothesis 1 was an accurate prediction.

Hypothesis 2: GRI reporting

Hypothesis 2 predicts that GRI reporting corporations are likely to provide more transparency on space sustainability issues compared with non-GRI reporting corporations. The difference between corporations that provide GRI reporting and those that do not is negligible, as shown under Table 3. It does not appear that GRI reporting influences the level of disclosure a corporation makes on space sustainability issues.

Table 3.

Corporations that Provide Material Disclosure Pertaining to Space Sustainability

Non-GRI reporting Corporations	GRI reporting Corporations
Orbcomm	Eutelsat
Trimble	SES
Sirius XM	Lockheed
Sky Perfect	Boeing
Iridium	Airbus
Avio	Thales
Loral Space
Globalstar
Total: 8 out of 20 (40%)	Total: 6 out of 16 (37.5%)

This finding is likely due to two observations. First, when reviewing the GRI Sustainability Disclosure Database, many of the disclosure documents were outdated. Although the website states that the documents were last updated in December 2020, there was a gap of 1–2 years compared with reviewing documents on the corporations' investor relations websites. Second, there are currently no GRI Reporting Standards that relate specifically to space sustainability. Although it is still possible for corporations to report their space exploration activities through GRI 302 (Energy), GRI 305 (Emissions), GRI 306 (Waste), or GRI 307 (Environmental Compliance), this is not evident for the 36 corporations found in the UFO ETF.

Hypothesis 3: UN SDGs

Finally, Hypothesis 3 predicted that corporations will fail to provide full disclosure in reference to UN SDGs. This was true for all but one corporation, Sky Perfect. Although three other corporations (Iridium, Avio, and Thales) also reported on UN SDGs, it was not clear which goal was in place for which space sustainability concerns. To improve the quality of UN SDG reporting, this would require enhanced organization and clarity on part of the corporation.

The disclosure offered by Sky Perfect can serve as a reference document (accessed from the company's Sustainability website) for other corporations for their own disclosure on space sustainability. For space debris, Sky Perfect classifies the concern under UN SDGs 9 (9.1, 9.4 and 9.5) and 12 (12.1, 12.2, 12.4, and 12.5). For improving energy efficiency, Sky Perfect considers the initiatives under UN SDGs 7 (7.2 and 7.3), 9 (9.4), 12 (12.5), 13 (13.1 and 13.2), and 15 (15.1).

There are other relevant UN SDGs that were not carefully considered during the data coding phase of this study. For example, Avio in its 2019 Consolidated Non-Financial Statement identified UN SDG 4 (Quality Education and initiatives aimed toward incubating technical skills), which is applicable for space exploration and activity. Further, Thales in its Corporate Responsibility Integrated Report 2019–2020 incorporated UN SDG 13 (Climate Action), as a guideline for the company to focus on reducing the impact of space activities and products on climate change. Although both UN SDGs were unaccounted for coding purposes, they are, nevertheless, found to be important for advancing space sustainability.

Study limitations

There are several limitations found for this case study. The number of publicly listed corporations that were reviewed for this case study was 36, which is a small sample of corporations that conduct space activities. Further, this case study only reviewed recent disclosure reports on space sustainability. As a result, the case study may have omitted potentially novel information on space collisions or space debris disclosed by the corporations in previous annual reports.

Another related limitation noted during the data collection phase is that corporations may provide varied disclosure and commentary on space sustainability issues in 1 year compared with another. There were two examples of this. Lockheed Martin in its 2020 Sustainability Report did not include disclosure on space debris and other related sustainability information; however, important information on space sustainability was found in its 2019 Sustainability Report.

Similarly, Thales included disclosure on space debris in its 2019–2020 Corporate Responsibility Integrated Report; however, this information was not reflected in its 2020–2021 Corporate Responsibility Integrated Report. Therefore, this limitation notes that information on space sustainability may be found in other disclosure documents or elsewhere.

Although the outer space industry can be applied to some of the topics found under GRI 300: Environmental, there are important factors that are missing such as outer space debris. Outer space debris does not clearly fit in with any of the topics listed in GRI 300 except for incorporating it with the “waste” topic. However, waste management in GRI 306 refers to significant waste-related impacts only. This raises the concern that space debris and its impacts may not meet the materiality threshold for corporate disclosure purposes.

Most corporations did not report negative information and are not required to if it is deemed non-material. Since the ecological impacts from space debris and poor energy management in outer space are not yet clear, it is reasonable to assume that corporations find such disclosure to be unwarranted. In addition, some corporations found in the UFO ETF disclosed their involvement in various initiatives and policies on space sustainability concerns; however, the full extent of this information is not available publicly.

In addition, 5 out of the 36 corporations (Weathernews, SKY Perfect JSAT, Viasat, MDA INC, and AST SpaceMobile) did not have corporate disclosure documents available. However, three out of the five corporations had informative websites on ESG/Sustainability/CSR matters, which were used in lieu of corporate documentation. Although this information may not be audited as would a disclosure report, this information is still made available to the public and was reviewed for the purposes of this study.

RECOMMENDATIONS AND CHALLENGES

To improve space sustainability, this article makes two recommendations while also locating three challenges. The first recommendation is to create a section for space exploration and activity within international guidelines and standards. The GRI and SASB can implement a new non-legally binding industry standard on Outer Space spanning business segments such as space mining, satellites and spacecrafts, space tourism, launch vehicles, payloads, propulsion services, and others.

Voluntary disclosure requirements can focus on issues such as greenhouse gas emissions, water management, waste and hazardous management (including space debris), biodiversity impacts, human rights and rights of Indigenous Peoples (including access to space for all and limiting space congestion), community relations, energy management (including clean fuel blends and other product specifications), business ethics and transparency, critical incident risk management (including collisions in space or space debris falling to Earth), and ecological impacts (including light pollution).

There are two major challenges with this recommendation. First, the case study indicates that there are gaps between voluntary disclosure and corporate performance. The usefulness of this recommendation is limited without a mandatory regulatory and enforcement framework that promotes accurate and reliable sustainability reporting. Another challenge with voluntary ESG disclosure is the potential for arbitrage.²⁶ Arbitrage is the process of exploiting a difference in share price by simultaneously buying and selling a security in a different market.

Arbitrage may also occur if there are two corporations that are nearly identical. However, there may be a market premium due to non-financial indicators.⁴⁰ It is expected that if two corporations are alike except one provides ESG disclosure and the other does not, there would be an initial premium to own equity in the corporation with ESG disclosure. However, since the corporations are identical in profitability, socially neutral investors would sell their shares and buy shares of the other corporation, eventually eliminating the premium in share price and social value added. Only socially conscious investors would pay a premium to own equity, which would produce an arbitrage opportunity for the market. Arbitrage is likely to occur if the assumption is that most investors are socially neutral. Arbitrage is not likely to occur if investor sentiment shifts to ESG prioritization.

The second recommendation is to implement mandatory disclosure on key information for space exploration and activity. One approach to achieving this is through mandatory minimum disclosure requirements based on GRI and SASB guidelines and standards or to implement new stock exchange listing requirements based on stringent ESG disclosure for space exploration and activity. This shift would change corporate behavior and produce valuable, comprehensive, and useful information that can be used to achieve space sustainability and a self-regulating industry.

Both the GRI and SASB guidelines and industry standards function as soft law; however, these international instruments overcome the “lack of accountability” disadvantage associated with soft law.⁴¹ Another proposal for domestic securities commissions is to create a tiered disclosure system that would require smaller and newer publicly listed corporations to make fewer disclosures but larger or multinational corporations to provide enhanced disclosure, including sustainability metrics. As a result of financial power, accountability can arise from informed investors and stakeholders.

Alternatively, as found in the French Space Operations Act, governments can enforce stringent authorization and registration requirements for launching a space object or for the re-entry of a space object. The requirements can include checks and balances on the space project such as, but not limited to verifying compliance with domestic or international space debris guidelines, ensuring a thorough plan on safety concerns is in place, and confirming insurance and financial guarantees to protect against potential damages.

Through this option, there is full transparency between the operator and the domestic government. This alternative can also be reached by way of a UN resolution, which can be formalized through binding documents. Both alternatives and recommendations utilize soft law principles, align with ESG practices, and create compliance through the existing domestic and international space law frameworks. A cautionary note is that the root to ESG practice is internally driven by the corporation rather than achieved through national laws and regulations.

The biggest challenge to space sustainability and mandatory disclosure is the lack of verification. Currently, outer space compliance verification is not established for any outer space activity. This concern is also voiced by the United States for banning the deployment of weapons in outer space and establishing a verification mechanism.⁴² As a result of a lack of transparency and confidence in outer space, there are concerns as to why corporations would disclose information on corporate activities conducted in space or who would monitor corporate activity in space.

One solution to this concern is a call for further UN action. The United Nations can act as a legitimate watchdog in space. The existing UN SDGs can be applied to outer space activities. The United Nations can build confidence and transparency by working directly (or indirectly) with corporations to foster commitments toward reliable and consistent ESG disclosure of outer space activities. A secondary solution is a call for further collaboration between GRI and SASB.

A joint initiative between the two international independent standards organizations has occurred in the past. In 2020, SASB and the GRI had announced a forthcoming collaborative workplan, a joint effort to combine industry-specific standards and sustainability-related risks and opportunities with the GRI Standards that focus on the broader economic, environmental, and social impacts of a company. A collaborative workplan to standardize the disclosure of outer space activities would also be a step forward toward resolving verification and monitoring concerns.

Footnotes

ACKNOWLEDGMENTS

The authors would like to thank the Faculty of Law at Western University for awarding the Western Undergraduate Student Research Internship. Without this opportunity, the author would not have received the mentorship and training from Faculty Mentors, Professor Oosterveld and Professor Steyn. The author would also like to thank Professor Steyn and Professor Oosterveld for their meticulous feedback on various drafts. Without their guidance, the author would not have been exposed to newfound research interests in space law and sustainable development.

DISCLAIMER

The conclusions from this article remain those of the author of this study. No statement herein represents any other individual or organization. Inclusion in the case study does not constitute an endorsement of the study nor its conclusion.

AUTHOR DISCLOSURE STATEMENT

No competing financial interests exist.

FUNDING INFORMATION

No funding was received for this article.

References

Dunk

Fvd

, Tronchetti

Handbook of Space Law. Cheltenham, United Kingdom: Edward Elgar Publishing Ltd., 2015.

Lyall

, Larsen

. Space Law: A Treatise, 2nd ed. London, United Kingdom: Taylor & Francis Group, 2018.

Lyall

Space Law: Overview. University of Oxford, Oxford, UK: Oxford Research Encyclopedia of Planetary Science, 2021.

Convention on International Liability for Damage Caused by Space Objects, March 29 1972, 861 UNTS 187 (Entered into Force September 1, 1972).

Convention on Registration of Objects Launched into Outer Space, January 14, 1975, 1023 UNTS 15 (Entered into Force September 15, 1976).

United Nations General Assembly, Recommendations on National Legislation Relevant to the Peaceful Exploration and Use of Outer Space, A/Res/68/74, UNGA, 68th session, 2013.

United Nations Global Compact, SDG Compass the Guide for Business Action on the SDGs. United Nations, GRI, WBCSD, 2015.

UN Global Compact. https://www.unglobalcompact.org (Last accessed on July 25, 2022).

SDG Compass. https://www.unglobalcompact.org/library/3101 (Last accessed on July 25, 2022).

10.

International Standards of Accounting and Reporting. https://isar.unctad.org (Last accessed on July 25, 2022).

11.

WBCSD. https://www.wbcsd.org (Last accessed on July 25, 2022).

12.

UN Global Compact Principles. https://www.unglobalcompact.org/what-is-gc/mission/principles (Last accessed on July 25, 2022).

13.

UNGP. https://www.ungpreporting.org (Last accessed on July 25, 2022).

14.

The Hague District Court and Commerce Team

, Den

Haag

, May 26, 2021, Vereniging Milieudefensie and the other parties it represents (or Milieudefensie et al.) v Royal Dutch Shell PLC 2021 Case number C/09/571932/HA ZA 19-379 (English version) Netherlands. https://uitspraken.rechtspraak.nl/inziendocument?id=ECLI:NL:RBDHA:2021:5339 (Last accessed on July 25, 2022).

15.

Global Reporting

Initiative

, Our Mission and

History

. https://www.globalreporting.org/about-gri/mission-history/ (Last accessed on July 25, 2022).

16.

Global Reporting Initiative. Consolidated Set of GRI Sustainability Reporting Standards, 2020. (Last accessed on July 25, 2022).

17.

Williams

CA.

The global reporting initiative, transnational corporate accountability, and global regulatory counter-currents. UC Irvine J Int Trans Comp Law, 2016; 1:67–90.

18.

The Global

Compact

, who cares wins connecting financial markets to a changing

World

, United Nations and Swiss Federal Department of Foreign

Affairs 2004

. https://www.unepfi.org/fileadmin/events/2004/stocks/who_cares_wins_global_compact_2004.pdf. (Last accessed on July 25, 2022).

19.

Sustainability Accounting Standards Board

, SB Conceptual

Framework 2017

. https://www.sasb.org/wp-content/uploads/2020/02/SASB_Conceptual-Framework_WATERMARK.pdf. (Last accessed on July 25, 2022).

20.

Securities Act of 1933, 1 USC 112, 204 § 77b 1933.

21.

Karmel

RS.

Disclosure reform—The SEC is riding off in two directions at once. Bus Law. 2021; 71(3):781–834.

22.

Jebe

The convergence of financial and ESG materiality: Taking sustainability mainstream. Am Bus Law J. 2019; 56(3):645–702.

23.

SASB

About Us

. https://www.sasb.org/why-sasb/ (Last accessed on July 25, 2022).

24.

Carroll

AB.

Corporate social responsibility: Evolution of a definitional construct. Bus Soc. 1999; 38(3):268–295.

25.

Grewal

, Riedl

, Serefeim

. Market reaction to mandatory nonfinancial disclosure. Manage Sci. 2018; 65(7):3061–3084.

26.

Brest

, Gilson

, Wolfson

. Essay: How investors can (and can't) create social value. J Corp Law. 2018; 44(2):205–230.

27.

UFO

ETF

, Prospectus. https://procureetfs.com/investormaterials/Prospectus.pdf. (Last accessed on July 25, 2022).

28.

UN SDGs. https://sdgs.un.org/goals. (Last accessed on July 25, 2022).

29.

UN SDGs and Targets. https://sdgs.un.org/goals. (Last accessed on July 25, 2022).

30.

Sustainability Disclosure Database. https://database.globalreporting.org/search. (Last accessed on July 25, 2022).

31.

United Nations Global

Compact

, Participants. https://www.unglobalcompact.org/what-is-gc/participants. (Last accessed on July 25, 2022).

32.

Lockheed Martin

Corporation

, 2019 Sustainability

Report

, The Science of

Citizenship 2019

. https://www.lockheedmartin.com/content/dam/lockheed-martin/eo/documents/sustainability/Lockheed_Martin_Sustainability_Report_Full_2019.pdf. (Last accessed on July 25, 2022).

33.

Loral Space & Communications

Inc

, Form 10-K, 2020 Annual

Report

. https://d18rn0p25nwr6d.cloudfront.net/CIK-0001006269/3df04896-e6cb-4754-a627-23fb040f7757.pdf. (Last accessed on July 25, 2022).

34.

Iridium Satellite

Communications

, 2020 ESG

Report

, 2020 Environmental

Social and Governance Report 2020

. https://filecache.investorroom.com/mr5ir_iridium/609/2020%20ESG%20Report%20%283_29_21%29%20LowRes.pdf. (Last accessed on July 25, 2022).

35.

Eutelsat

Corporation

, Reference

Document

, 2019/20 Universal Registration

Document 2020

. https://www.eutelsat.com/files/PDF/investors/2019-20/ETL%20COM_URD%202019-20.pdf. (Last accessed on July 25, 2022).

36.

Loi n° 2008–518 du 3 juin 2008 relative aux opérations spatiales (1), JO

June 4

, 2008 (NC). https://aerospace.org/sites/default/files/policy_archives/French%20Space%20Ops%20Act%202008%20unofficial%20translation.pdf. (Last accessed on July 25, 2022).

37.

Inter-Agency Space Debris Coordination Committee

, DC Space Debris Mitigation

Guidelines

, 2020. https://orbitaldebris.jsc.nasa.gov/library/iadc-space-debris-guidelines-revision-2.pdf. (Last accessed on July 25, 2022). These guidelines may be updated at any time when new information on space activities becomes available.

38.

United Nations Office for Outer Space

Affairs

, European Code of Conduct for Space Debris Mitigation

I, BNSC

, ES

R, ESA, 2004. https://www.unoosa.org/documents/pdf/spacelaw/sd/2004-B5-10.pdf. (Last accessed on July 25, 2022).

39.

SES

S.A.

, Annual

Report

, Annual

Report 2020

. https://www.ses.com/sites/default/files/2021-03/210322_SES-AR2020_final.pdf. (Last accessed on July 25, 2022).

40.

Allegaert

PJ.

Codetermination and ESG: Viable alternatives to shareholder primacy?. N Y Univ J Int Law Politics. 2020; 52(2):641–683.

41.

Park

, Berger-Walliser

. A firm-driven approach to global governance and sustainability. Am Bus Law J. 2015; 52(2):255–315.

42.

Mosteshar

Space Law and Weapons in Space. Oxford Research Encyclopedia of Planetary Science, 2019.