News Our Feedback to EC 14 April 2022

Have your say - EU satellites

You can also get involved in forming EU laws. The European Commission would like to hear your views on laws and policies currently in development. They offer a platform "Have your say" with the list of all new EU initiatives open for public consultation. You need to register to write your feedback.

There are always 5 stages of each EU initiative, each stage is open for public consultation for a specific time frame:

  1. In preparation

  2. Call for evidence

  3. Public consultation

  4. Draft act

  5. Commission adoption

EU space policy - space-based secure connectivity initiative

About this initiative: This initiative aims to better protect businesses, public authorities and the general public against cyber- and hybrid threats by ensuring:

- reliable, cost-effective, ultra-secure connectivity for governmental and commercial communications, critical infrastructures, external actions, crisis management, telemedicine, maritime and airspace surveillance, also covering Africa and the Arctic

- ubiquitous high-speed broadband across the EU for a fully functioning single market.

Feedback period: for stage 5 it was 17 March 2022 - 12 May 2022


Feedback from Europeans for Safe Connections

We "Europeans for Safe Connections" are very concerned with this initiative. The principle of minimization of objects in space must be instituted, limiting deployments to essential uses which will benefit humanity and not commerce and race.

Satellites are resource demanding, ozone depleting, environment polluting.

Page 5/77: There are mentioned "Consistency with other Union policies" in



We suggest adding this section below:

• Inconsistency with other Union policies

The proposal is inconsistent with a number of other Union policies. In particular

– a sustainability strategy is lacking and the European Green Deal
Background is provided on page 2/77: "Due to the limited lifespan of a satellite (approximately 15 years for geostationary orbit (GEO) satellites) several of the governmentally owned infrastructures ... will need to be replenished in the coming decade."

– the Article 191 of the TFEU stating that the Union policy "shall be based on the precautionary principle and on the principles that preventive action should be taken, that environmental damage should as a priority be rectified at the source and that the polluter should pay."

– the UN Guidelines for the Long-term sustainability of Outer Space Activities guideline 2.2 (c), requiring the use of outer space to be conducted “so as to avoid (its) harmful contamination and also adverse changes in the environment of the Earth” and “risks to people, property, public health and the environment associated with the launch, in-orbit operation and re-entry of space objects.”

– ECJ, Judgment of 11.04.2013 - C-258/11, NVwZ-RR 2013, 505 = NuR 2013, 343 = BeckRS 2013, 80740; ECJ, Judgment of 15.05.2014 - C-521/12, NVwZ 2014, 931 = NuR 2014, 487 = ZUR 2014, 418 = BeckRS 2014, 80961 (para. 26 - 28).
If an authority has to approve a plan or a project and there is uncertainty as to whether the plan or project will have an adverse effect on a habitat conservation area, the ECJ obliges the authority to apply the precautionary principle provided for in Art. 6 (3) p. 2 of the Habitats Directive 92/43 EEC and to effectively prevent the adverse effect on the conservation areas caused by the plan or project.

– ECJ, Judgment of 10.10.2019 - C 674/17, NVwZ 20219, 1827 = DÖV 2020, 33 = NuR 2019, 756 = ZUR 2020, 54 = BeckRS 2019, 23630 (para. 66).
The same applies insofar as a decision is to be made on exceptions pursuant to Art. 16 (1) Habitats Directive 92/43 EEC . If the examination of the best available scientific data reveals uncertainty as to whether the favourable conservation status of a population of a species threatened with extinction can be maintained or restored despite the derogation, the Member States are obliged under the precautionary principle enshrined in Article 191(2) TFEU to refrain from adopting or implementing such an exemption regulation.
Background is provided on page 4/77: "Such commercial services would ... removing dead zones and increasing cohesion across Member State territories, including rural, peripheral, remote and isolated areas and islands ..."

– International Astronomical Union (IAU) and UN Office of Outer Space Affairs (UNOOSA) organized a workshop on the topic of "Dark and Quiet Skies for Science and Society". Subsequently, the document "Recommendations to Keep Dark and Quiet Skies for Science and Society" was published.

– The participants of the International Conference in Defense of the Quality of Night Sky and the right to observe stars, jointly with the representatives of UNESCO, UNWTO, IAU and members of the academic community, published the Declaration in defence of the night sky and the right to starlight.

Europe should not get involved in this race and should be a leader in honouring values of humanity. Therefore, we ask the Union to invoke relevant international treaties and call for an immediate halt to mega-constellations of telecommunications satellites being launched worldwide pending satisfactory assessment of their environmental effects and consequent limitation/ban of artificial constellations.

A public-private partnership is seen as the most appropriate implementation model to ensure that the objectives of the programme can be pursued. But what does this mean for the indispensable independency of the government? In such a construction of a public-private partnership, how can the government develop pure independent policy and monitor compliance with legislation? The government should only serve the public interest.

Furthermore, the citizens of Europe and the World have not been involved in the decision regarding the deployment of communication satellites and their immense environmental impact. According to the Aarhus Convention EU citizens have a right to ensure that the most up-to-date scientific data is taken into account when the EU adopts policies for the protection of the environment. Citizens have a right to access environmental information, to public participation in environmental decision-making processes and to access to justice. Regarding the deployment of communication satellites the EU Citizens have not been asked whether we will accept the pervasive environmental consequences from them in the name of technological progress.


We are also concerned about the risk to data by being connected full-time to more or less the same network. In the event of hacking, all data will be compromised and vital services may be shut down for longer periods with no possibility of rapid repair. This could include vital facilities such as water pump and lock management, traffic management, electricity plants, water supply, etc. We propose that network access should be cabled and broken down into smaller manageable units that will not put the safety, security and operational reliability of vital systems in an entire country or region at risk.

It is stated that “The rise of quantum computers adds an additional threat. With their fundamentally improved capabilities, it is expected that quantum computers will be able to decrypt content that is currently encrypted. The European Quantum Communication Infrastructure (EuroQCI)10 initiative aims at developing future-proof cryptographic systems to offer unprecedented levels of secure communications by resisting future quantum computing attacks.” This “aims at developing...” does not sound safe or secure but more like advertising and empty promises. We have seen all too often that hackers are at the forefront and that public and private networks can be seriously compromised with leaks of medical data, personal ID numbers, insurance company data and much more.

Further, the proposed regulation sets out to change our society in a very serious manner. At the very least, a project involving such major changes should be submitted to the people, thoroughly analysed and debated with all available information, and should ideally trigger an EU-wide referendum on whether we want to live in such a fully automated and thoroughly digitised society. In the regulation, the 'machine' (digital connectivity) comes before the human being in every respect. Ways of working, processes and communication will be radically changed and will have a profound impact on our social structure and way of life. No section of the population has expressed a desire for that change, nor has any party stood for election on that agenda, so in that sense the introduction of this regulation is in effect a democratic assault, not to mention the indecency and the lack of basic ethics when rolling out the digital infrastructure over the heads of people who cannot escape the ubiquitous satellite radiation and digital surveillance.

Best regards
Petra Bertova Polovkova
on behalf of Europeans for Safe Connections

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