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Saturday, October 1, 2016

Why are Space Treaties Outdated?




Introduction: In 1609, When Hugo Grotius published Mare Liberum[1], he laid down the rules of the law of the seas for the very first time. Over the time, the rules for International Law (beyond the seas, especially Land) were consolidated. For a while, in twentieth Century, the mankind felt satisfied that, there is no lawlessness beyond their domestic frontiers anymore. However, the cold war did bring with itself certain welcoming surprises in Space Technology. And here we are, with a certain conception of space law loosely bound by a handful of treaties- 
·       Outer Space Treaty[2] (1967)
·       Rescue Agreement[3] (1968)
·       Liability Convention[4] (1972)
·       Registration Convention[5] (1975)
·       Moon Treaty[6] (1979)

And even these bare laws have been litigated upon in Courts of Law, successfully, one might add.
 Brief Overview of Present Space Law Framework: The Committee on the Peaceful Uses of Outer Space (hereinafter referred as COPUOS) was set up by the General Assembly in 1959 to govern the exploration and use of space for the benefit of all humanity: for peace, security and development[7]. The Committee was tasked with reviewing international cooperation in peaceful uses of outer space, studying space-related activities that could be undertaken by the United Nations, encouraging space research programmes, and studying legal problems arising from the exploration of outer space. The Committee was instrumental in the creation of the above mentioned five treaties and general principles of outer space.

The United Nations Office for Outer Space Affairs (UNOOSA) is the United Nations office responsible for promoting international cooperation in the peaceful uses of outer space and serves as the secretariat for the COPUOS at Vienna. UNOOSA also maintains the United Nations Register of Objects Launched into Outer Space.[8]

The five space treaties deal with issues such as the non-appropriation of outer space by any one country, arms control, the freedom of exploration, liability for damage caused by space objects, the safety and rescue of spacecraft and astronauts, the prevention of harmful interference with space activities and the environment, the notification and registration of space activities, scientific investigation and the exploitation of natural resources in outer space and the settlement of disputes.
The Moon Treaty must be treated as a universal failure, since none of the major space powers have ratified it and a mere 11 states have signed it till date. Perhaps, the United Nations jumped the gun when they introduced the much ambitious Moon treaty in the height of cold war. The right timing for the moon treaty could have been the recent years or even now, when. But a failed moon treaty changes the equation drastically, and makes the path of a new space treaty quite difficult. 
Each of the space treaties stresses the notion that outer space, the activities carried out in outer space and whatever benefits might be accrued from outer space should be devoted to enhancing the well-being of all countries and be treated as common heritage of humankind, with an emphasis on promoting international cooperation.
Outdated Space Law: Fast forward to 2016, the last one of the space treaties was formulated 37 years ago. The 1998 International Space Station Agreement can be ignored for our purposes, since it is not in nature of universal application. The humanity cannot expect the developments in space to be so stagnant that no amends in space law is required for such a long time. We now have at least a lot of major companies (non- governmental at that), Virgin Galactic, Blue Origin, SpaceX,  XCOR Aerospace, Lockheed Martin etc., competing for dominating Commercial Outer Space. Apart from governmental contracts, these companies consider their major business to be Space Tourism/ travel & Asteroid Mining. Apparently, these companies are very secretive in their activities & future business plans and lack transparency. They only reveal the bare minimum details (of their technological feats) required to create buzz for investors and attract much needed investment. Though, recently at 67th International Astronautical Congress, Guadalajara, Mexico, SpaceX did present its plan to cater to commercial travel to Mars by 2018. Be that as it may, one thing is evident that there are private companies entering space and are very close to making commercial suborbital spaceflight at least. Again, the space treaties are mum on commercial exploitation of space by private players, perhaps it never caught their imagination 37 years ago. We can clearly see that the law is still chasing the space technology, and unfortunately is lagging far behind.

Once there are human beings, and ordinary ones at that, in an uncharted territory, where hardly any civil, criminal or trade law exists, the rules of trading become extremely important. No one knows as to what laws an ambitious trader must look for as a guide to comply whilst in his endeavour to conquer outer space for commercial gains. It is a chilling question one must ask as to how would, say, a murder be dealt in space? Which criminal law would apply, or would that only be a civil law claim of wrongful death? Which Court of law would have the right jurisdiction over a contract negotiated and signed in space & to be executed in space? Would The United Nations Convention on Contracts for the International Sale of Goods be applicable in case of a goods sold? Where would the incidence of taxation lie, if at all? There are innumerable questions & only blank answers to them. It is therefore incumbent on the international community to look for the right answers for these questions which though seem improbable at present, but are undeniably possible in near future. Otherwise, we are alarmingly close to lawlessness with regard to trading in outer space.

The above-mentioned private companies have set monumental milestones in space technology such as taking- off of a spacecraft and landing it at the very same place successfully[9] and making the space crafts reusable[10]. It is important to note that even governments with all their might and most brilliant human minds have been unable to do so successfully, and that’s not for the lack of trying. This changes things. It makes space travel affordable & viable for private companies. Coming back to basics, these companies are here to make some money by trading. And where there is trade, there is a need for trade law. On national level, this assumes importance since ISRO has been making commercial sense of space technology by launching satellites for other countries at a fraction of cost, hence, India has a unique commercial/ trading advantage[11]. No developing Country is so far ahead in Space Technology as India, hence, it should be an important contributor to rules of trading in space. 
While our ignorance makes us feel safe that there are five treaties protecting and supporting the skeleton of space law, the leading economy & home to most private aerospace companies, United States of America has been passing sweeping legislations like the Space Resource Exploration and Utilization Act of 2015[12], which amongst others, authorizes the american companies to keep and sell any natural resources mined on planets, asteroids and other celestial bodies. According to one estimate, these Commercial operations could reap trillions of dollars from mining precious metals like platinum, common metallic elements such as iron, and water & the unknown mineral resources[13].


The US Law terms the companies under its jurisdiction as ‘United States Commercial Space Resource Utilization Entity’. The term ‘United States commercial space resource utilization entity’ means an entity providing space resource exploration or utilization services, the control of which is held by persons other than a Federal, State, local, or foreign government, and that is[14]-
(A) duly organized under the laws of a State;
(B) subject to the subject matter and personal jurisdiction of the courts of the United States; or
(C) a foreign entity that has voluntarily submitted to the subject matter and personal jurisdiction of the courts of the United States.
Additionally the US law also confers property rights unilaterally on the newly coined United States Commercial Space Resource Utilization Entity, in following terms[15]-
(a) Property rights- Any asteroid resources obtained in outer space are the property of the entity that obtained such resources, which shall be entitled to all property rights thereto, consistent with applicable provisions of Federal law and existing international obligations.

This flies in the face of Outer Space Treaty & other remaining international space agreements. The Outer Space treats outer space and the resources therein like asteroids, as the common heritage of mankind, to which even USA agreed more than 50 years ago, when the U.S.S.R. was a viable threat to its space monopoly. But at present, with U.S.S.R. out of picture, it has a technological and economic advantage in leading the space race by a huge margin if not completely monopolizing it. It can not be ignored that the principles governing space law as set out in Outer Space Treaty may very well be treated as jus cogens, and the USA can not escape from its obligations under the same. The problem here is, as is with most treaties, of lack of a judicial venue/ executing mechanism for the treaty to work in reality. 
While the Global Community is dozing off in ignorance, not only has the USA conferred property rights in outer space on mostly American- United States Commercial Space Resource Utilization Entities, but it has also made foreign investors subject to its own domestic laws and courts, for them to benefit from this Act. This effectively means that, in case of a dispute with regard to the rights on an asteroid, by an American party and a non- American party, the non- American party would be held to have no right under the controversial law.  On the other hand, if a non- American investor ‘voluntarily’ subjects itself to American law to take benefit of this law, then he is subject to the control of NASA and other security agencies for the technology he might exclusively possess. In a way, the USA confers on itself exclusive right on inclusive environment of Outer Space.

Though the USA asserts[16] that they are not claiming any sovereign rights on what is being mined, but one can’t help but notice that making laws on what is being mined in space, is making a sovereign claim on space, which according to basic space law is not be claimed upon by any state, and is left as common heritage of mankind. Additionally, the controversial law even makes elaborate arrangements for the suits to be tried in US Courts. That is a universally accepted sovereign function of states.

Since we are discussing space mining/ asteroid mining, and the possibility of the same cannot be ignored, and should not be discouraged once the area is regulated but globally accepted law. Evidently, the certainty of exhaustion fo Earth’s finite minerals and heightened environmental concerns to prevent the ecology of Earth would necessitate the space mining endeavours in well- knit rules. The space traders should not just worry about adapting their engineering tools to the fluctuating gravity, but also worry about the labour laws to guide the working conditions of Space Miners, and how to manage their factories and to treat the concept of time, day and night, working hours etc. Either National or International (space) law would control the increased activities in space, but as the law changes, the means to effectively communicate the laws to all concerned has to be made. Also, the law may be a dead letter if the control of mission is unitary and the ones actually in space are unable to approach courts/ tribunals due to lack of communication channels. Should the concept of virtual courts be promoted to counter that concern or holographic presence of the aggrieved be worked upon, are questions worth answering for the lawmakers. 

 And if we are to treat the whole of space as common heritage of mankind, then mankind also need to foot a part of the hefty bill that goes in conquering that heritage. If we do not, then we do give a certain amount of legitimacy to the space entrepreneurs, who are taking the risk at a great cost and paying the sizeable insurance amount for the still uncertain future business endeavours.

Bottomline: The neo- space race would continue no matter whether Global community forms consensus on the outer space laws or not. But prudence demands that the vacuum of lawlessness be filled with desired law than to wait for the situation to explode out of control and the law only arrives to diffuse the situation, which might come too late for the damage to be contained. The point being that we need to work towards globally accepted rules of trade  in space law, which should have some basis of international law, but not just a replication of international law, since the international law rests primarily on custom. Evidently, the customs in space law are dominated by a handful of States and would not suffice the conscience of the law. Hence we need universally accepted rules, which not only facilitate the space technology, but work towards advancement of human race on one hand & maintaining the earth’s organic balance on the other. 

If the Outer Space Treaty was a ‘Mare Liberum’ moment for the Space Law, all we need is an UNCLOS[17] moment very soon.


[This is an introductory and very comprehensive writing. A lot of important & interesting points has been left out and not been explained in detail it deserves. The author intends to fill the gap in times to come, with the hope that it is thought provoking.] 


[1] Grotius, Mare Liberum (1609)
[2] Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer Space, Including the Moon and Other Celestial Bodies, adopted Oct. 10, 1967
[3] Agreement on the Rescue of Astronauts, the Return of Astronauts and the Return of Objects Launched into Outer Space, adopted Dec. 3, 1968
[4] Convention on International Liability for Damage Caused by Space Objects, adopted Sep. 1, 1972
[5] Convention on Registration of Objects Launched into Outer Space, adopted Sep. 15, 1976
[6] Agreement Governing the Activities of States on the Moon and Other Celestial Bodies, adopted July 11, 1984
[14] Id.
[15] Id.
[17] The United Nations Convention on the Law of the Sea adopted on Nov. 16, 1994

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