The Mission Took Nineteen Days. The Paperwork Took Four Months.
ORC-V1 “Maud” completed a GEO disposal for a telecommunications operator retiring a legacy satellite from the Clarke arc. The object was transferred to graveyard orbit at GEO+300 km. The mission commenced on 14 July 2024. The mission was complete on 01 August 2024. Chain-of-custody documentation was issued. Maud returned to operational standby. The mission was a success in every sense relevant to the mission.
Upon completion of the mission, L. Sandhu began the post-disposal regulatory notification process with the Orbital Regulatory Secretariat. This process requires submission of ORS Form 17 (Post-Disposal Confirmation), ORS Form 22 (Graveyard Orbit Verification), and, in cases involving licensed GEO arc operators, the supplementary ORS Form 17A (Licensed Operator Confirmation Addendum).
Form 17 was submitted on 05 August 2024, four days after mission completion. The ORS acknowledged receipt on 12 August 2024. The ORS raised a query on 29 August 2024 regarding the disposal altitude calculation methodology. L. Sandhu responded on 02 September 2024. The ORS acknowledged the response on [REDACTED].
The ORS requested a revised Form 17A on 24 September 2024. L. Sandhu submitted the revised 17A on 25 September 2024. The ORS then requested Form 22B, which is a supplementary form to Form 22 that L. Sandhu had not previously been required to submit, as it was introduced in the ORS regulatory update of March 2024 and [REDACTED].
Form 22B was submitted on 08 October 2024. Final regulatory sign-off was received on 05 November 2024. The mission that ended on 01 August was administratively complete on 05 November. This is 127 days. The mission itself was 19 days. We are not drawing conclusions. We are publishing the numbers.
| Mission commencement | 14 July 2024 |
| Mission completion | 01 August 2024 · 19 days |
| First regulatory submission | 05 August 2024 |
| Forms submitted total | 5 · (17, 17A, 17A revised, 22, 22B) |
| ORS queries raised | 3 |
| ORS average response time | 12.4 working days · L. Sandhu: 1.2 working days |
| Form 22B existence (prior knowledge) | None. It was introduced in March 2024. Distributed to: some people. |
| Final regulatory sign-off | 05 November 2024 |
| Total paperwork duration | 127 days · 6.7× longer than the mission |
| L. Sandhu’s assessment | [REDACTED — CLICK TO READ] |
- L. Sandhu has compiled a complete annotated index of all current ORS post-mission forms including Form 22B. The index is accurate as of November 2024. The index will be updated whenever the ORS introduces new forms without telling us.
- The ORS has been notified that ORC intends to include regulatory processing timelines in future published mission reports. The ORS has acknowledged this notification. We have noted their acknowledgement. We have also noted how long the acknowledgement took.
- The client was informed of the regulatory timeline at the point of final sign-off. The client asked if this delay was normal. We said it was more normal than it should be. The client said they had been dealing with the ORS for fifteen years and this did not surprise them. We found this simultaneously reassuring and not reassuring.
- M. Hargreaves has formally raised the question of whether ORC should employ a dedicated regulatory affairs officer. L. Sandhu has said she is managing. M. Hargreaves has asked if L. Sandhu would like help managing. L. Sandhu has said she is managing. We are monitoring this.