The U.K. government is conducting a consultation on what its civil space strategy should be for the period 2011-2015. Given the strong position of U.K. companies in the space arena and explicit recognition of satellite contributions to the national economy, this consultation is important, and there remains time to submit comments, as the deadline is not until July 8.

The U.K. Space Agency issued the consultation as one of its first official acts as an executive agency of the government’s Department for Business Innovation and Skills (BIS). The agency itself was launched in March 2010 as a replacement for the British National Space Centre and formally placed under the BIS on April 1.

The U.K. Space Agency says this new draft strategy “is markedly different in tone and style than previous versions.” The key difference in the brief strategy is said to be that it draws upon the Space Innovation and Growth Strategy (IGS) and takes growth as the main theme. The IGS was an industry, academia and government strategy issued early last year. (We wrote about the IGS in April 2010.)

The proposed strategy is built upon six focus areas, all centered around the growth theme: growth from “new opportunities,” growth from export, innovation supporting growth, science enabling growth, education for growth and growth through smarter government.

The consultation document contains a nice, yet restrained, focus on the importance of satellite communications for driving the entire sector forward. For instance, it says that “continuing economic growth will depend on a strong [U.K.] presence in markets of the future — for example: satellite broadband, Earth observation and applications that integrate space and terrestrial data for new-high value uses.”

More should be said in the strategy about the role of satellite communications, in particular the fact that without communications satellites to create innovation and economies of scale for launch and delivery, the overall space market would be a small percentage of what it is today. The U.K. Space Agency could turn to a recent communication from the European Commission on European Union space strategy, issued on April 4 from Brussels. That paper identifies satellite communications as “a key space sector, generating the largest revenues in the space industry, in both Europe and the rest of the world.” It acknowledges that satellite communications have a “clear role to play” with respect to meeting European broadband objectives.

Translated into policy terms, this recognition should foster government support for the communications satellite industry. The United Kingdom is a center for some of the biggest satellite players. The proposed strategy should direct more attention to the contributions they make to overall space goals.

This support could be demonstrated in the last of the six focus areas on “smarter government.” The strategy consultation says that under this item it will encourage “work with [the national regulator] Ofcom and international bodies to ensure [that] appropriate radio frequencies and orbit slots are available for future space services and new ways of accessing space.”

At the latest count, the United Kingdom has submitted due diligence information on the launch and operation of 90 satellite networks listed in the International Telecommunication Union (ITU) space network list. This total is surpassed only by filings of the United States, Russia, China, France and Japan. The United Kingdom, thus, has a compelling interest in preserving the integrity of the ITU satellite registration system. Recent disputes before the ITU’s Radio Regulations Board demonstrate that the stakes are high and countries will go to great lengths to preserve rights to orbital slots and access to space. It is critical to ensure that the system works and is not distorted by unverified or simply fictitious ploys by other countries.

The proposed strategy refers both to orbital slots and “appropriate radio frequencies.” Radio spectrum is the lifeblood of the satellite sector. Decisions to allocate spectrum in one country can affect the ability of the satellite industry to use that resource across the entire footprint of a satellite. Thus, actions by Ofcom on spectrum can affect much more than the U.K.-based revenues of a satellite, but also can affect revenues from a far-wider service area.

In sum, we would like to see even more reference to the communications satellite sector in the U.K. Space Agency emphasis on growth. The agency consultation is available on the BIS website: http://www.bis.gov.uk. Comment early and often.

Gerry Oberst is a partner in the Hogan Lovells Brussels office.