I INTRODUCTION
Saudi Arabia is returning to space with a bold vision, over 37 years after Prince Sultan ibn Salman Al Saud's space trip that made him the first Saudi Arabian citizen, Arab, Muslim, and the first member of a royal family to ever visit the final frontier.
Nowadays, two astronauts including the first female Arab to join a mission on the ISS , discussing next-generation space stations and conducting experiments providing important data for Earth.
This is only a part of Saudi Arabia's activities in exploring and expanding its space capabilities and investing in its future in space, which may be a golden opportunity for space.
Saudi Arabia has been witnessing exciting advancements in space law sectors as they are constantly evolving to meet Saudi ambitions to exploit the space sector with an emphasis on satellite communication, earth observation, research, international cooperation, and tourism. This is only to name a few of the activities within the emerging space industry in Saudi Arabia, aligning with international space legal frameworks and regulations.
II LEGAL, REGULATORY AND POLICY FRAMEWORK
At the core of Saudi Arabia's space ambitions is a regulatory framework formed largely in line with the United Nations and the International Telecommunication Union's (ITU) requirements and standards. Historically, Saudi Arabia signed and ratified five main international treaties and agreements that regulate space activities. These included UN treaties like the 1967 Outer Space Treaty (ratified by Saudi Arabia in 1976), the 1968 Rescue Agreement (ratified by Saudi Arabia in 2021), the 1972 Liability Convention (ratified by Saudi Arabia in 1976), the 1975 registration convention (ratified by Saudi Arabia in 2012). It is worth highlighting that Saudi Arabia withdrew from the 1984 moon agreement on 5 January 2023 and this withdrawal will take effect as of 5 January 2024 . Saudi Arabia also signed the Artemis Accords on 16 July 2023 , which would signify that its eyes are set on the moon, and its resolve on peaceful and sustainable space exploration and exploitation.
Saudi Arabia is also a signatory to other agreements, namely the 1971 Agreement Relating to the International Telecommunications Satellite Organization, the 1976 ARABSAT Agreement, the 1976 Convention on the International Mobile Satellite Organization, the 1992 International Telecommunication Constitution.
The Saudi Council of Ministers' resolution dated 1 November 2022 established the Supreme Space Council, a government agency headed by Crown Prince Mohamad Bin Salman. Its responsibilities include approving policies and strategies for space programs, and annual plans. As well as monitoring the implementation of the strategy and achieving compatibility with various sectors and national needs. The Council of Ministers also changed the name of the Communications and Information Technology Commission (CITC) to the Communications, Space and Technology Commission (CSTC).
The Council of Ministers later approved changing the Saudi Space Commission into an agency named to Saudi Space Agency (SSA) on 13 June 2023.
The Saudi Space Agency's statutes have been approved and its objectives align with the Kingdom's aspirations for a more advanced quality of life, as the statutes aim to create better and "safer environments for its citizens while creating new opportunities for more profitable innovations that support the Saudi economy".
The SSA had stated in a press release that its strategy requires setting goals that focus on space science and exploratory missions, creating new opportunities in the space sector as well as "empowering national cadres to achieve growth and progress in a way that serves the country and humanity".
Moreover, as conveyed by the United Nations Committee on the Peaceful Uses of Outer Space , Saudi Arabia currently does not have any practices related to the definition and delimitation of outer space and has yet to develop or implement a national framework for space law that covers such matters.
Nevertheless, the sector's regulations are being developed. Saudi Arabia has drafted a space law that falls in line with its policies and treaties which aims to encourage the expansion and regulation of its space investment, industry, and research. This space law draft (the "Draft") remains to be passed as a law is currently following the Saudi legislative process.
The Draft, though neither final nor in force yet, describes the territorial boundaries and areas covered by space law including Saudi Arabia's land territory and territorial waters subject to the sovereignty of Saudi Arabia and the airspace above it. This includes any area enjoying special economic status, airspace, as well as Outer Space and the Space Operations Area.
The Draft defined Air space as any area beginning at mean sea level and reaching the maximum possible limit for air traffic control; it defined Outer Space as the area above Earth's atmosphere and the Space Operations Area as the area above eighty kilometres or more than the mean sea level.
The Draft also addressed:
- Launch and re-entry, outlining guidelines for launching objects into space and bringing them back to Earth,
- Space Activities and Space-Related Terms, outlining guidelines for various activities related to space, including Space Activities, Space-Related Activities, High-Altitude Activities, and Astronomically Advantageous Areas,
- Scientific Research & Development Activities and Incentive Programs,
- Space Systems and Space Data,
- Satellite Navigation Systems and Earth Remote Sensing, describing the technologies used for navigation and remote sensing operations in space,
- Space Activity Licenses and Licenses used for providing Satellite Communications Services, manned space flight activities, Earth remote sensing, space monitoring activities, space data operators, Use of Space Nuclear Power Sources and Dual-Use Goods, Space Resources, and High-Altitude Activities .
- Sustainability of Space Activity and space debris mitigation .
- Utilization of resources in outer space.
- Space Nuclear Power Sources and devices used in space energy-generating activities that use nuclear material, radioisotopes, or nuclear reactors.
- Dual-use goods are defined as goods and technologies of shared civil, commercial, and military uses.
The Draft also differentiated between incidents and accidents related to space activities, detailing their potential consequences, and addressed space safety, incidents, operators liability, describing the guidelines, roles, and responsibilities of Operators of Space Activities and Licensed Persons (natural or juristic) in space-related activities.
Article Sixteen of the Draft outlines the liability of the Operator caused to either the surface of the Earth or to aircrafts in flight because of carrying out of Space Activities or to other Space Objects. Such claims against the Operator shall be made within one year and the Operator shall not be held liable if all license obligations had been fulfilled unless wilful misconduct or gross negligence are involved.
Article Seventeen of the Draft outlines Saudi Arabia's liability towards third parties in the event of damage incurred by Space Activities. Saudi Arabia may seek recourse against the Operator who carried out the operation related to the compensation and the amount of insurance or financial guarantees provided or paid by the Operator. Saudi Arabia shall compensate the injured for the sums exceeding the amount of available insurance and guarantees.
Except for Space Activity carried out by the Government of Saudi Arabia, Article Eighteen of the Draft mandates Operators to maintain an insurance policy, from an insurance company approved by the CSTC, against liability that may be incurred in the context of the licensed 18 activity in order to compensate for damage that may be caused to a third party by the Operator's Space Activity.
CSTC regulations shall set the necessary criteria for liability insurance requirements in relation to Space Activities and exemptions from this requirement may be partially or fully granted to an Operator in case of low-risk activities.
Article Nineteen of the Draft covers miscellaneous provisions pertaining to liability according to which the Operator shall be held liable for damages to natural persons or property during Manned Space Flight. This article also stipulates that a special agreement with the owner of such a facility shall be made by the Operator if the latter uses Saudi Arabia's launch sites or facilities, detailing any applicable Limitations of liability between the parties for any damage that may be caused to Saudi Arabia, its facilities or property. When determining compensation, various elements are observed, including launch specifics, hardware and technological information, and technical data.
In this context, claims must be filed within one year from the day following the date on which the damage occurred. Further reinforcing Operator liability, the last paragraph of Article Nineteen stipulates that in all other cases not covered by the provisions of Chapter Four (Above mentioned Articles Sixteen through Nineteen) the Operator shall be held liable for any damage resulting from the activities carried out by the Operator.
III REGULATION IN PRACTICE
Until the Space Law Draft becomes into force, the CSTC remains Saudi Arabia's digital regulator, according to Saudi Arabia's Telecom Regulations (issued by Royal Decree No. (M/12) of 12/03/1422H (3 June 2001); Council of Ministers Resolution No. (74) of 05/03/1422H (27 May 2001), and it remains the agency charged with regulating and issuing telecommunications-related licenses in Saudi Arabia, including space-related telecommunication.
On the international level, the International Telecommunication Union (ITU) is the United Nations specialized agency for information and communication technologies. This global agency handles the provision of satellite space segment capacity and its coordination. The ITU is represented in Saudi Arabia by the CSTC as the local administrator and national regulator of frequency spectrum that determines and allocates the future need of frequency spectrum for space services and ensures coordination on both the national and international levels.
According to the Telecom Regulations, and its implementing regulations, the main license categories are telecommunications licenses, Radio frequency licenses, Numbering licenses, and Equipment licenses.
When it comes to regulating space telecommunication, the CSTC has been working to improve and update the regulatory framework on the space sector by best practices and international recommendations and issued Non-Terrestrial Networks ("NTN") regulations following the principle of "technology-neutral" under three main regulatory texts (the "NTN Regulations"):
- Regulations for Provisioning of Operation Services of NTN
- Regulations for Provisioning of Telecommunication Services over NTN
- Regulation for Registration of Telecommunication Space Stations.
NTN Regulations clearly distinguish between providers of NTN operation services, providers of Telecommunication Services, and the registration of Telecommunication Space Stations.
The regulation for registration of Telecommunication Space Stations applies to all telecommunication space station operators who provide their capacity over Saudi Arabia of Saudi Arabia. Any telecommunication space station capacity provider who is providing satellite capacity over Saudi Arabia must register with CSTC as a registered telecommunication space station capacity provider. Registered telecommunication space station capacity providers may only provide their capacity to the holders of the "provision of operation service of NTN telecommunication networks" permit, or any other service provider who holds a license or other permit to provide such services in the Kingdom. This registration does not grant the right to provide telecommunication services over NTN or provide operation services of NTN telecommunication networks.
Incorporating in the registry and updating any information is free of charges or fees. There is no defined duration of the registry. However, all registered telecommunication space station capacity providers must update the registry in case of any amendments or notify CSTC if the telecommunication space station is replaced, or its lifespan has expired.
Under the principle of "technology-neutral", NTN consists of variants of space-borne and aerial communication networks including GEO, MEO, LEO satellite constellations, High Altitude Platform Systems (HAPS), Low Altitude Platform Systems (LAPS), Earth stations in motion (ESIM), air-to-ground (A2G) networks, Direct-to-device (D2D) satellite communication services, Mega Constellations, 55G CGC, altogether setting the field to become an integral part of the much-anticipated 6G .
According to the CSTC, A2G communication is defined as heterogeneous networks that are engineered to utilize satellites, HAPS, and LAPS to build communication access platforms. Furthermore, A2G is a special application of air-born that provides internet on civilian aircraft via terrestrial network . HAPS is defined by the CSTC as a station located on an object at an altitude of 20 to 50 km and at a specified, nominal, fixed point relative to the Earth . While LAPS is defined by the CSTC as a station located on an object at an altitude of 1 to 12 km and at a specified, nominal, fixed point relative to the Earth.
Additionally, the CSTC defined the Satellite Internet of Things (SAT-IoT), as working on communication between satellite networks and IoT sensors or IoT end nodes Earth stations in motion (ESIM) technology which can be defined as Earth stations communicating with GSO or non-GSO space stations operating in the fixed-satellite service (FSS) operating on moving platforms (such as aircraft, ships or any vessel) in specified frequency, with an express exemption of foreign licensed ESIMSs crossing Saudi Arabia from local licensing.
NTN Regulations distinguish between electronic communications networks (ECN) and non-publicly available electronic communications services (ECS) providers and operators and regulate the necessary licensing under a simplified General Class Licence (GCL) which replaces the previous Telecom Regulation class B licence. GCL is defined by the CSTC (Article 6.2 of the Regulations for Provisioning of Operation Services of NTN, and Article 6.2 of the Regulations for Provisioning of Telecommunication Services over NTN) as a class licence that allows the provision of any of the Telecommunications Services authorized under the license.
The Regulations for Provisioning of Operation Services of Non-terrestrial Networks applies to providers of operation services of non-terrestrial networks that are authorized by the CSTC, and any other service provider who has obtained a license or other permit that allows the provision of these services in Saudi Arabia.
The conditions of Regulations for Provisioning of Operation Services of Non-terrestrial Networks apply to anyone who builds and operates a non-terrestrial networks for the provisioning of voice telecommunications services through non-terrestrial networks, provisioning of internet and data transmission services through non-terrestrial networks, value-added services related to services through non-terrestrial networks, any other telecommunication services related to NTN that CSTC deems necessary to according to the growth and expansion of the telecommunications sector and based on CSTC's judgment. Such services may include one or more of the following technologies:
- Personal mobile communications systems and networks via satellite (GMPCS-Network),
- VSAT services,
- Broadband satellite services,
- Systems of identical earth stations,
- Connectivity systems on aircrafts (airborne or spaceborne),
- Any other technology related to non-terrestrial networks that CSTC deems necessary to include in the scope of this document according to the growth and expansion of the telecommunications sector and based on CSTC's judgment.
The Regulations for Provisioning of Telecommunication Services over Non-terrestrial Networks on the other hand applies to service providers of telecommunications services over non-terrestrial networks that are authorized by the CSTC. These services include the provisioning of voice telecommunications services through non-terrestrial networks, provisioning of internet services and data transmission through non-terrestrial networks, value-added services related to services through non-terrestrial networks, and any other telecommunication services related to non-terrestrial networks that CSTC deems necessary via the same technologies listed in the Regulations for Provisioning of Operation Services of Non-terrestrial Networks. A "Provision of operation services of non-terrestrial network permit" is required before the building before building or operating any non-terrestrial networks. The duration of the permit to provide the authorized services would be the same as the duration of the General Class license unless any of the permits is cancelled or terminated by the CSTC.
Accordingly, the CSTC regulates satellite telecommunications service largely in line with ITU guidelines and covers VSAT (Very Small Aperture Antenna) networks, Global Mobile Personal Communication Services (GMPCS), Broadband Satellite Services (BSS), Fixed Satellite Service (FSS) and Mobile Satellite Service (MSS), and ground-based satellite terminals located in Saudi Arabia.
" Accordingly, the CSTC regulates satellite telecommunications service largely in line with ITU guidelines and covers VSAT (Very Small Aperture Antenna) networks, Global Mobile Personal Communication Services (GMPCS), Broadband Satellite Services (BSS), Fixed Satellite Service (FSS) and Mobile Satellite Service (MSS), and ground-based satellite terminals located in Saudi Arabia.
" Accordingly, the CSTC regulates satellite telecommunications service largely in line with ITU guidelines and covers VSAT (Very Small Aperture Antenna) networks, Global Mobile Personal Communication Services (GMPCS), Broadband Satellite Services (BSS), Fixed Satellite Service (FSS) and Mobile Satellite Service (MSS), and ground-based satellite terminals located in Saudi Arabia.
" Accordingly, the CSTC regulates satellite telecommunications service largely in line with ITU guidelines and covers VSAT (Very Small Aperture Antenna) networks, Global Mobile Personal Communication Services (GMPCS), Broadband Satellite Services (BSS), Fixed Satellite Service (FSS) and Mobile Satellite Service (MSS), and ground-based satellite terminals located in Saudi Arabia.
" GMPCS Systems, Networks, and Services generally know a distinction between GMPCS Operations and GMPCS Provision. GMPCS Operations allows the installation, operation, and management of networks for GMPCS in Saudi Arabia according to CSTC guidelines and requirements aiming to ensure reliability, reporting, and continuity of service according to international standards. GMPCS Provision allows providing services covering basic services; emergency services; SMS services, short information messages services; data services; value added services; and closed user groups on a non-exclusive basis. CSTC requirements for such services cover aspects such as invoicing, non-discrimination, quality of service, reporting to CSTC, and consultation on tariffs.
" BSS provision allows the provision of broadband satellite services, including the provision of voice services, data services, internet, and related value-added services, whether mobile, fixed, or limited in mobility telephone, in addition to satellite capacities, according to the Saudi National Platform describing the procedure to obtain Permit For the Provision of The Broadband Satellite Services . Receive-only terminals receiving authorised broadcast signals in the Broadcasting Satellite Service (BSS) do not require a licence. Similarly, receive-only terminals operating in exclusive Fixed Satellite Service (FSS) bands do not require a licence.
On a relevant note, the import activity of telecommunication and IT hardware and equipment to Saudi Arabia is also regulated by the CSTC according to the "Procedure for Approving and Importing Telecommunications and IT Equipment" enacted by Council of Ministers' decree No. (100) dated 8/8/1415 H (corresponding to 10/1/1995 G). Some of these conditions are related to the type of entity that can undertake the importation while other requirements apply to the importation process and the release of equipment at Saudi customs or with other agencies or authorities.
Fees for obtaining licenses for the Provisioning of Telecommunication Services over Non-terrestrial Networks and the Provisioning of Operation Services of Non-terrestrial Networks are subject to the "Frequency Use Licence Remuneration Regulation" applicable to spectrum licenses in accordance with the decision of the Council of Ministers No. (632) dated 14 June 2022 and published on the CSTC website.
IV YEAR IN REVIEW
Saudi Arabia has been witnessing groundbreaking development in many fields, not limited to its space program and space law. Recent years also witnessed a tangible acceleration in Saudi Arabia's space program and space activities. Additionally, the KSU-CUBESAT satellite was the first 1-U launched by King Saud University in Saudi Arabia. The satellite was built and developed by the College of Engineering students to prepare and train Handbook on Small Satellites 145 engineering students at the university in the field of designing and programming satellites in line with Saudi Arabia's Vision 2030. The specific objective of the CubeSat is to send telemetry and images by a small camera from space and repeat a received voice signal .
According to the Saudi Press agency the Saudi Space Commission launched Saudi Arabia's first astronaut program, dedicated to training Saudi competent personnel to undertake long- and short-term space flights. Human space flights aim to increase Saudi Arabia's expansion and global presence and improve its capabilities and competitiveness in areas such as science, engineering, research, and innovation. In the coming months, Saudi Arabia plans to launch its National Space Strategy, which will reveal space programs and initiatives that aim to serve humanity from space.
The Council of Ministers resolution dated 1 November 2022, established the Saudi Space Council (SSC) headed by Prime Minister Crown Prince Mohamad Bin Salman. Its roles include approving policies and strategies for space programs, annual plans, monitoring the implementation of the strategy, and achieving compatibility with various sectors and national needs.
The Council of Ministers also changed the name of the Communications and Information Technology Commission (CITC) to the Communications, Space and Technology Commission (CSTC), which reflected Saudi Arabia's growing interest in space and technology.
The Council of Ministers also approved changing the name from Saudi Space Commission (the "SSC") to Saudi Space Agency (the "SSA") on 13 June 2023 .
Additionally, the Council of Ministers' Resolution approved the Saudi Space Agency statute for the importance of focusing on industry and innovation in the space sector. The Saudi Space Agency's strategy focused on the development of satellite systems and technologies, monitoring and tracking space objects and debris, executing human exploration and operation missions, preparing and supporting studies and research related to the space sector and its technologies, developing the capabilities of national cadres in all areas of the space sector, cooperating with international and regional bodies to support the space sector locally, representing the KSA in regional and international events, concluding agreements and MoU related to the Agency's activities locally and internationally and finally developing human and technological skills.
Saudi Arabia has also established initiatives like the CST's space entrepreneurship alliance and the Saudi Space Accelerator Program aiming to attract, incubate, and accelerate 20 space startups and entrepreneurs invested in the fields of space tourism, exploration, satellite communication, and space photography.
In May 2023, Saudi Arabia sent two astronauts, including its first female astronaut, to the International Space Station, in collaboration with Axiom Space. Astronauts Rayyanah Barnawi and Ali al-Qarni lifted off to the ISS from NASA's Kennedy Space Centre in Florida on a SpaceX Falcon 9 rocket aboard a SpaceX Dragon spacecraft, as part of the Axiom 2 space mission.
In the last quarter of 2023, the SSA and King Abdullah University of Science and Technology (KAUST) reinforced collaboration under their Space Research, Development and Innovation Workshop intending to place Saudi Arabia's space program among the top 10 space programs on the international level, with research, development and innovation targets ranging across six research focus areas, including earth observation, communication and positioning, navigation and timing, launch, astronomy and space exploration, microgravity research, and space situational and domain awareness.
Another significant event, marking the international diplomatic and space scene, was Saudi Arabia's withdrawal from the Moon agreement. Not long after it had joined the Artemis Accords on 16 July 2023, Saudi Arabia became the first state to ever withdraw from any of the United Nation's space treaties. Australia, Mexico, and Saudi Arabia are the only signatories to both the Artemis Accords and the Moon Agreement. Some speculate that Saudi Arabia's withdrawal from the Moon Agreement was a result of conflicts between the principles of the Moon Agreement and those of the Artemis Accords.
The Artemis Accords are a set of non-binding multilateral arrangements aimed to guide the future of space activity and space exploration with the goal of a manned landing on the lunar surface by 2025 .
According to NASA , the principles Artemis Accords reinforce and implement the 1967 Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer Space, Including the Moon, and Other Celestial Bodies, otherwise known as the Outer Space Treaty. The principles of the Artemis Accords also reinforce the commitment to the Registration Convention, the Agreement on the Rescue of Astronauts.
Artemis Accords' principals commit the signatories to peaceful space non-military exploration and deconfliction of activities as signatory nations commit to preventing harmful interference and supporting the principle of due regard, as required by the Outer Space Treaty.
Artemis accords also guarantee transparency, Interoperability, and inter-commitment to emergency assistance to guarantee full cooperation between signatories that undertake to implement "Safety Zones" that remain to be universally defined but should form a basis for long-term lunar civil and commercial missions and should also prevent harmful interference, implementing Article IX of the Outer Space Treaty and reinforcing the principle of due regard .
Additionally, signatories commit to the release of scientific data, to preserving outer-space heritage, to sustainable, responsible, and safe exploration and exploitation of space resource in compliance with the Outer Space treaty, and to properly planning for the safe disposal of orbital debris and to guaranteeing the full commitment to the registration of Space Objects
since any nation participating in Artemis Accords must be or become a signatory to the Registration Convention.
V Outlook and Conclusions
With Vision 2030 as a catalyst and the CSTC and the SSA at its vanguard, Saudi Arabia's ascent in the space sector has made it an active participant in the global space race for sustainable space exploration and exploitation.
In summation, Saudi Arabia's plans and activities in the space sector stand as a testament to its vision and its responsible and forward-looking ambitions of space exploration. Currently, the space law draft is following the Saudi legislative process, nevertheless, the trajectory of Saudi Arabia's space industry and regulations seems set for exponential evolution. Anticipated trends include the passing of the space law draft, its implementing regulations with an emphasis on galvanizing economic growth through the space industry, technological innovation, safety, and collaboration with local and international stakeholders.
Footnotes
1 Author: Patrick Chabhar, Attorney at Law, BSA-BH. pi>2 Sultan ibn Salman Al Saud | Biography & Facts | Britannica
3 https://ara.tv/revpk (https://english.alarabiya.net/)
4 Saudi Arabia in talks over plans for next-generation space stations (thenationalnews.com)
5 Saudi space mission delivers groundbreaking data for Earth: Astronaut, scientists | Al Arabiya English
6 Saudi Arabia plans $2 billion boost for space program by 2030 | Reuters
7 Saudi Arabia's Vision 2030: A Golden Opportunity for Space? - SpaceWatch.Global
8 United Nations Treaty Collection - Depositary Notification C.N.4. 2023.TREATIES-XXIV.2 (https://treaties.un.org)
9 "Saudi Arabia Signs Artemis Accords and Joins International Space Exploration Program (https://www.spa.gov.sa/2370318)
10 HRH Crown Prince Chairs Cabinet Session (spa.gov.sa)
11 Saudi Space Agency (ssa.gov.sa)
12 https://ssa.gov.sa/
13 UNOOSA documents and resolutions database, National legislation and practice relating to the definition and delimitation of outer space, 2022 (A/AC.105/865/Add.27)
14 Articles 6 through 12 of the Space Law Draft
15 Article 14 of the Space Law Draft
16 Ibid, CSTC's space radio communication services outlook
17 https://www.spa.gov.sa/w1787110 (CITC Publishes Non-Terrestrial Networks (NTN) Regulations)
18 CSTC's space radio communication services outlook - August 2023- (https://regulations.citc.gov.sa/)
19 Air-borne (cst.gov.sa) https://www.cst.gov.sa/en/ntn/Pages/air-borne.aspx
20 Ibid. CSTC's space radio communication services outlook
21 Ibid
22 Ibid
23 https://www.my.gov.sa/ ; Permit For the Provision of The Broadband Satellite Services (my.gov.sa)
24 Up to date information on licence application and the applicable fees can be found at CSTC Web Site.
25 https://www.itu.int/pub/R-HDB-65-2023
26 Saudi Arabia Launches Astronaut Program to Send First Saudi Woman to Space in 2023
27 HRH Crown Prince Chairs Cabinet Session (spa.gov.sa)
28 https://ssa.gov.sa/en/news/acceleratorprogram/
29 https://ara.tv/revpk (https://english.alarabiya.net/)
30 KAUST Forms Cooperation Partnership with SSA to Support Research, Development, Innovation (spa.gov.sa)
31 How NASA's Artemis program plans to return astronauts to the moon (nationalgeographic.com)
32 NASA, International Partners Advance Cooperation with First Signings of Artemis Accords - NASA
33 https://www.nasa.gov/ (Michelle L.D. Hanlon, Due Regard and Safety Zones: Understanding the Commercial Implications of Recent Policy and Legislation)
Originally published by Lexology.
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