Author Topic: FAA Streamlined Launch and Reentry Licensing Requirements  (Read 30195 times)

Offline gongora

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Docket FAA-2019-0229

Attached files (also available at link above):
FAA-2019-0229-0001.pdf : The proposed regulations
Preliminary_Regulatory_Impact_Analysis--Streamlined_Launch_and_Reentry_Licensing_Requirements_Proposed_Rule_03-21-2019.pdf : Analysis of the changes
ARC_FINAL_REPORT_(4-30-2018) : Streamlined Launch and Reentry Licensing Requirements Aviation Rulemaking Committee (ARC) Recommendations : April 30, 2018

I haven't read these yet.  Just skimming through a few pages this caught my eye:
Quote
The largest quantified cost savings for industry would result from eliminating or relaxing
requirements for a flight safety system on some launches (about $11 million in present value
savings over 5 years at a discount rate of 7% or about $12 million at a discount rate of 3%) and
from reducing the number of personnel that would have to be evacuated from neighboring launch
sites (about $8 million in present value savings over 5 years at a discount rate of 7% or about $9
million at a discount rate of 3%). These cost savings are described in more detail below.

The FAA proposes to move from prescriptive flight safety system requirements to
performance-based requirements. As a result, the proposed rule would not require all launch
vehicles to have a full flight safety system. Launch vehicles that have a very low probability of
multiple casualties even if vehicle control fails would not be required to have a flight safety
system. In addition, vehicles that have moderately low probability of casualties even if vehicle
control fails would not be required to have robust flight safety systems. These performance-
based requirements would reduce costs for some vehicle operators, especially for small vehicles
or those operating in remote locations.

Quote
The FAA has limited data on the number of neighboring operations personnel that have
been evacuated during launches in the past. From the data, it is evident that the estimated gains
from the definitional and risk requirement changes will be highly sensitive to the number of
return to launch-site events (RTLS) in the future. The SpaceX Falcon Heavy demonstration
caused the evacuation of 1,550 employees (194 from the launch and 1,356 from reentry) that
would be able to stay on site under the provisions of this proposed rule.
« Last Edit: 04/17/2019 04:20 am by gongora »

Offline gongora

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #1 on: 05/07/2019 11:37 pm »
https://www.regulations.gov/document?D=FAA-2019-0229-0050
Quote
Comment from Michael Lopez-Alegria

As industry co-chair of the Streamlined Launch and Reentry Licensing Requirements Aviation Rulemaking Committee, I would like to draw your attention to some text in the NPRM - the final paragraph of Section II.D, regarding the ARC:

"During the course of the ARC, volunteer industry members formed a Task Group to provide draft regulatory text reflecting proposed revisions to the commercial space transportation regulations. The volunteer industry members of the Task Group were Blue Origin, Sierra Nevada Corporation, Space Florida, and SpaceX. The majority of the ARC opposed the formation of this Task Group and disagreed with including the proposed regulatory text into the ARCs recommendation report. The FAA will not specifically address the proposed regulatory text in this document because it did not receive broad consensus within the ARC."

To be rather blunt, the third sentence in the paragraph is factually incorrect. In fact, the MAJORITY of the ARC members supported the formation of the Task Group, and a majority of them voted in support of the draft regulatory text that the Task Group submitted. I can provide recorded voting data to support these statements. While it may be true that a handful of members were opposed to the formation of the Task Group, those members DID NOT reflect the majority opinion, as asserted in the text.

That the FAA chose to ignore the regulatory text proposed by the Task Group is a matter that should indeed have been addressed in the NPRM. But said disregard should NOT have been ascribed to a lack of consensus among the ARC members in support of the proposed revisions; that assertion is patently erroneous.
« Last Edit: 05/07/2019 11:37 pm by gongora »

Offline Lar

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #2 on: 05/08/2019 04:00 am »
Is that low level infighting or something that portends something ominous? That seems like a very provocative thing to say, at least potentially.

This change seems beneficial and I'm not just saying that because I always favor less regulation. So do these remarks suggest that it won't be adopted?

(that said, the savings seem quite small, if they are yearly, but really large, if they are per launch)

PS I assume this is the same person

https://en.wikipedia.org/wiki/Michael_L%C3%B3pez-Alegr%C3%ADa
« Last Edit: 05/08/2019 04:03 am by Lar »
"I think it would be great to be born on Earth and to die on Mars. Just hopefully not at the point of impact." -Elon Musk
"We're a little bit like the dog who caught the bus" - Musk after CRS-8 S1 successfully landed on ASDS OCISLY

Offline gongora

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #3 on: 05/08/2019 12:45 pm »
The remarks seem to be about the process that created these proposed rules, so shouldn't really have any effect on getting it through.  I confess I haven't actually gotten around to reading most of the 150 page proposal and 280 pages of supporting documents yet.

Offline FutureSpaceTourist

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #4 on: 08/03/2019 10:29 pm »
Quote
ULA and its launch industry competitors in pitched fight over regulations
by Sandra Erwin — August 3, 2019

United Launch Alliance on July 19 posted on the Federal Aviation Administration’s website a detailed comment in support of the agency’s proposed revisions of commercial launch and re-entry rules.

[...]

Commercial space launch players, meanwhile, continue to challenge the agency to make further changes, arguing that what the FAA has proposed amounts to a crushing blow to entrepreneurial companies that are trying to build cost-effective space transportation infrastructure.

https://spacenews.com/ula-and-its-commercial-competitors-in-pitched-fight-over-launch-regulations/

Offline FutureSpaceTourist

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #5 on: 08/03/2019 10:40 pm »
Attached are comments from Commercial Spaceflight Federation and Boeing/Lockheed/ULA etc covering letter.

CSF says (their emphasis)

Quote
FAA’s Draft Commercial Space Launch and Reentry Rules are not Streamlined or Performance-based and will Impede U.S. Space Safety, Growth, and Leadership. The FAA should issue a Supplemental NPRM.

ULA et al say:

Quote
Broadly speaking, we are supportive of AST’s efforts and the content of the NPRM. We do not support an indefinite rulemaking process, but would like AST to bring it to conclusion as soon as possible. It is our belief that any further improvements can be made to the current NPRM. We need to minimize regulatory uncertainty associated with an indefinite rulemaking process.

Update to add:

Comments from Blue Origin & SpaceX that, not surprisingly, are very much in the CSF view
« Last Edit: 08/03/2019 10:50 pm by FutureSpaceTourist »

Offline Star One

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FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #6 on: 08/04/2019 11:35 am »
Is that low level infighting or something that portends something ominous? That seems like a very provocative thing to say, at least potentially.

This change seems beneficial and I'm not just saying that because I always favor less regulation. So do these remarks suggest that it won't be adopted?

(that said, the savings seem quite small, if they are yearly, but really large, if they are per launch)

PS I assume this is the same person

https://en.wikipedia.org/wiki/Michael_L%C3%B3pez-Alegr%C3%ADa

What you favour less regulation even in circumstances where it impacts people’s health & safety for example?

The safety of people should always be paramount. You can always build another piece of hardware you can re-build a person.

After all it’s not as if the industry is anywhere near the levels of safety in the modern airline industry, in fact it is probably decades away from that.
« Last Edit: 08/04/2019 11:42 am by Star One »

Offline DistantTemple

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #7 on: 08/04/2019 01:32 pm »
Is that low level infighting or something that portends something ominous? That seems like a very provocative thing to say, at least potentially.

This change seems beneficial and I'm not just saying that because I always favor less regulation. So do these remarks suggest that it won't be adopted?

(that said, the savings seem quite small, if they are yearly, but really large, if they are per launch)

PS I assume this is the same person

https://en.wikipedia.org/wiki/Michael_L%C3%B3pez-Alegr%C3%ADa

What you favour less regulation even in circumstances where it impacts people’s health & safety for example?

The safety of people should always be paramount. You can always build another piece of hardware you can re-build a person.

After all it’s not as if the industry is anywhere near the levels of safety in the modern airline industry, in fact it is probably decades away from that.
It sounds as if that line "The safety of people should always be paramount." is being used to persuade the FAA to keep high cost flight safety systems (flight termination) even for rockets, small rockets and those in remote un-populated locations, in the hope that this expense will limit the growth of new entrants to the market.
However those words which you quote so confidently are just an attempt to stop an analysis of the situation.

In transport it is not true - or the car would be banned!, if we hold it as true for spaceflight  then human spaceflight should be banned. If we hold it as true for housing, (some poorer) parts of US cities would have to be bulldozed and rebuilt. If for heavy industries... Etc. It is blatantly untrue and is just a trope to stop questions and make anyone that questions ULA's position seem morally bankrupt!
Everything dangerous has a risk reward equation, and a compromise to be made to allow progress, whilst being sensibly careful.
 
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Offline Star One

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #8 on: 08/04/2019 06:00 pm »
Is that low level infighting or something that portends something ominous? That seems like a very provocative thing to say, at least potentially.

This change seems beneficial and I'm not just saying that because I always favor less regulation. So do these remarks suggest that it won't be adopted?

(that said, the savings seem quite small, if they are yearly, but really large, if they are per launch)

PS I assume this is the same person

https://en.wikipedia.org/wiki/Michael_L%C3%B3pez-Alegr%C3%ADa

What you favour less regulation even in circumstances where it impacts people’s health & safety for example?

The safety of people should always be paramount. You can always build another piece of hardware you can re-build a person.

After all it’s not as if the industry is anywhere near the levels of safety in the modern airline industry, in fact it is probably decades away from that.
It sounds as if that line "The safety of people should always be paramount." is being used to persuade the FAA to keep high cost flight safety systems (flight termination) even for rockets, small rockets and those in remote un-populated locations, in the hope that this expense will limit the growth of new entrants to the market.
However those words which you quote so confidently are just an attempt to stop an analysis of the situation.

In transport it is not true - or the car would be banned!, if we hold it as true for spaceflight  then human spaceflight should be banned. If we hold it as true for housing, (some poorer) parts of US cities would have to be bulldozed and rebuilt. If for heavy industries... Etc. It is blatantly untrue and is just a trope to stop questions and make anyone that questions ULA's position seem morally bankrupt!
Everything dangerous has a risk reward equation, and a compromise to be made to allow progress, whilst being sensibly careful.

The fact that we use cars as much as we do in spite of the high death rate is the perfect example of human irrationality. One of the big factors in favour of self driving cars is it removes possibly the most dangerous element from the equation the human. The same can be applied to space exploration hence why some scientists argue in favour of robot exploration rather than human.

Offline mlindner

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #9 on: 08/05/2019 07:09 am »
These rules have me seriously worried. Any great sprint of innovation can be killed by the hand of government regulation. It has happened time and time again in the history of the US.
LEO is the ocean, not an island (let alone a continent). We create cruise liners to ride the oceans, not artificial islands in the middle of them. We need a physical place, which has physical resources, to make our future out there.

Offline Star One

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FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #10 on: 08/05/2019 09:31 am »
These rules have me seriously worried. Any great sprint of innovation can be killed by the hand of government regulation. It has happened time and time again in the history of the US.

If there was much truth in your final sentence from a historical prospective America and it’s economy wouldn’t be where it is. Really can’t understand why people are getting so ‘hysterical’ about this as reading the article it sounds like the FAA are giving the new space companies more than enough opportunity to have their say.
« Last Edit: 08/05/2019 09:33 am by Star One »

Offline DistantTemple

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #11 on: 08/05/2019 03:21 pm »
These rules have me seriously worried. Any great sprint of innovation can be killed by the hand of government regulation. It has happened time and time again in the history of the US.

If there was much truth in your final sentence from a historical prospective America and it’s economy wouldn’t be where it is. Really can’t understand why people are getting so ‘hysterical’ about this as reading the article it sounds like the FAA are giving the new space companies more than enough opportunity to have their say.
As for the "truth of the final sentence", the following is about earth imaging, not launch but is an example of regulation driving business abroad, and reducing US industry from what it could have been.
https://www.wired.com/story/how-the-government-controls-sensitive-satellite-data/
Quote from: https://www.wired.com/story/how-the-government-controls-sensitive-satellite-data/
Meanwhile, other countries have figured out this whole space snapshot business, too—and they don't fall under the same US regulations. “All you’ve really done is drive business to those foreign companies,” says James Vedda, a senior policy analyst at the Aerospace Corporation, a federally funded research and development center.
Someone here must know the details and be able to quote them. I only heard about it when there was that concern with SpaceX's footage of Earth during the FH test flight. Bad judgements over regulation may well continue to impact US space businesses at the expense of those overseas and human progress.

Being "Seriously worried" and the allegation "Hysterical" are two different things, which you have conflated to the detriment of your reasoned argument. The words you use do not make the tone of this thread calmer.

Concern is a great word, as once these regulations are set, they will have consequences for all space companies. Anyone in or following the new space industry is rightly concerned, and it would be negligent not to be. DO you suggest a reduction in professionalism and diligence?

It is not good enough for new space companies just to "have their say" (as if once they have had it we can all go back to the status quo) rather their arguments need to be fairly and openly evaluated, in light of the governments directions about opening access and reducing regulation. Open discussion and justification of the details is needed.
 
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Offline Star One

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FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #12 on: 08/05/2019 05:55 pm »
These rules have me seriously worried. Any great sprint of innovation can be killed by the hand of government regulation. It has happened time and time again in the history of the US.

If there was much truth in your final sentence from a historical prospective America and it’s economy wouldn’t be where it is. Really can’t understand why people are getting so ‘hysterical’ about this as reading the article it sounds like the FAA are giving the new space companies more than enough opportunity to have their say.
As for the "truth of the final sentence", the following is about earth imaging, not launch but is an example of regulation driving business abroad, and reducing US industry from what it could have been.
https://www.wired.com/story/how-the-government-controls-sensitive-satellite-data/
Quote from: https://www.wired.com/story/how-the-government-controls-sensitive-satellite-data/
Meanwhile, other countries have figured out this whole space snapshot business, too—and they don't fall under the same US regulations. “All you’ve really done is drive business to those foreign companies,” says James Vedda, a senior policy analyst at the Aerospace Corporation, a federally funded research and development center.
Someone here must know the details and be able to quote them. I only heard about it when there was that concern with SpaceX's footage of Earth during the FH test flight. Bad judgements over regulation may well continue to impact US space businesses at the expense of those overseas and human progress.

Being "Seriously worried" and the allegation "Hysterical" are two different things, which you have conflated to the detriment of your reasoned argument. The words you use do not make the tone of this thread calmer.

Concern is a great word, as once these regulations are set, they will have consequences for all space companies. Anyone in or following the new space industry is rightly concerned, and it would be negligent not to be. DO you suggest a reduction in professionalism and diligence?

It is not good enough for new space companies just to "have their say" (as if once they have had it we can all go back to the status quo) rather their arguments need to be fairly and openly evaluated, in light of the governments directions about opening access and reducing regulation. Open discussion and justification of the details is needed.
 

That’s a poor example to pick as the main reason for the restrictions in that market sector were national security concerns, a complex conversation between multiple parties, including the numerous security agencies, had to be had before they could be changed. So in my opinion that proves nothing as it is too atypical an example.
« Last Edit: 08/05/2019 06:08 pm by Star One »

Offline DistantTemple

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #13 on: 08/05/2019 09:25 pm »
Agreed, not the best example.
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Offline FutureSpaceTourist

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #14 on: 08/07/2019 12:26 pm »
https://twitter.com/torybruno/status/1159059078817017857

Quote
Been asked about the FAA NPRM: activity to simplify bureaucracy:  single licences, simplified apps, fewer steps, faster approvals... NOT deleting sometimes challenging safety standards that were written in blood. FAA has done a good job balancing commercial ease with safety.

Offline mlindner

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #15 on: 08/07/2019 07:08 pm »
https://twitter.com/torybruno/status/1159059078817017857

Quote
Been asked about the FAA NPRM: activity to simplify bureaucracy:  single licences, simplified apps, fewer steps, faster approvals... NOT deleting sometimes challenging safety standards that were written in blood. FAA has done a good job balancing commercial ease with safety.

Tory is completely misrepresenting what these regulations are currently proposing. They are actually _increasing_ the amount of regulation, not _decreasing_ it. It also increases the bureaucracy. There is not even talk of deleting safety standards. He's becoming more and like Michael Gass all the time. Sad to see.
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Offline Star One

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #16 on: 08/08/2019 08:44 am »
https://twitter.com/torybruno/status/1159059078817017857

Quote
Been asked about the FAA NPRM: activity to simplify bureaucracy:  single licences, simplified apps, fewer steps, faster approvals... NOT deleting sometimes challenging safety standards that were written in blood. FAA has done a good job balancing commercial ease with safety.

Tory is completely misrepresenting what these regulations are currently proposing. They are actually _increasing_ the amount of regulation, not _decreasing_ it. It also increases the bureaucracy. There is not even talk of deleting safety standards. He's becoming more and like Michael Gass all the time. Sad to see.

I think you’re taking a particular spin on the proposals and running with it. Looking at the SN article I don’t really recognise your description of what is being proposed. At the very least I’d say you’re over simplifying things.

Offline Eer

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #17 on: 08/20/2019 11:04 pm »
edit: quote removed

Yes, we're all anxious to see Starhopper hop. But before blaming FAA for foot-dragging, let's take a short trip down memory lane, to the SpaceShipTwo crash in 2015, which rained debris dangerously close to the general public.
>

Space News has a story about FAA AST reorganization and increasing workloads

https://spacenews.com/faa/

Quote
The FAA office of commercial space transportation says its workforce has grown by 40% at the same time that its work load has grown 1,000%.

Good find, and highly appropriate given today's discussion of FAA.  I'm going to repeat one of the excerpts you quoted from the article and bold it, in case anyone misses it.

Quote
Since 2012, the FAA’s Office of Commercial Space Transportation, or AST, has increased staffing by 40 percent, according to Wayne Monteith, the associate administrator of that office. Its workload, in contrast, has grown tenfold, he said.

“While 40% seems really really good … when you’re looking at a 1,000% increase in the workload, something’s got to give,” Monteith told reporters during the Aug. 15 teleconference.

Interesting too that administrator Wayne Monteith is the same Brig. Gen. Wayne Monteith (USAF Retired) who ran the 45th Space Wing at Cape Canaveral until late last year. So he's the guy who was in charge of launching most of USAF's payloads and running the range at the Cape. No doubt he knows what he's doing.

Maybe the people who are complaining about FAA foot-dragging could also complain to Congress about the FAA being woefully understaffed in this area.

I'll put my comment on this here, since it involves my interpretation of the current administration's general approach to regulation.

Starvation of the bureaucracy is being used throughout the government to "deconstruct the state".  That's an explicit objective and the starvation, through lack of staffing and failing to appoint or nominate replacements.  It's working to hamstring many executive branch departments. 

I don't know if it is playing a role in the FAA issues with overloading or not.  Certainly, the kind of growth they're experiencing would stress any organization.

But tying up and incapacitating the bureaucracy is an end in itself, for some, not just a side effect.
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Offline Lar

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #18 on: 09/02/2019 04:38 pm »
What you favour less regulation even in circumstances where it impacts people’s health & safety for example?

False dichotomy. A detailed analysis of why more regulation does not always increase people’s health & safety and less regulation often does... is off topic.
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Offline FutureSpaceTourist

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Re: FAA Streamlined Launch and Reentry Licensing Requirements
« Reply #19 on: 10/09/2019 03:59 pm »
https://twitter.com/torybruno/status/1181920265774616576

Quote
Been asked several times about the FAA revised launch rules. They have achieved a good balance between cutting red tape and protecting public safety. Simplifying licensing is good. Lowering the reliability and testing rqmnts for flight termination systems is not.

twitter.com/alejandro_debh/status/1181923083537584128

Quote
So do you think everyone is now happier with it overall?

https://twitter.com/torybruno/status/1181923748309454848

Quote
Some parties continue to ask for technical and safety requirements to be eased.

twitter.com/robotbeat/status/1181934456946483206

Quote
Not sure that’s fair. Maybe they just don’t think exploding the rocket is the only way? It has its own risks. Current regs are biased towards rockets as munitions, not reusable vehicles. Imagine if passenger jets had to carry explosives to blow themselves up if divert is needed.

https://twitter.com/torybruno/status/1181937771922907136

Quote
New rules do allow new approaches. A flight termination system is used when everything else has gone wrong & the rocket is heading for people or property. It must be VERY reliable & able to survive fire and break up. Some of the toughest design problems I’ve ever had to solve.

twitter.com/robotbeat/status/1181938961511518208

Quote
Such things are not required on passenger jets. And they’re way safer.

https://twitter.com/kyle_m_photo/status/1181960224690688000

Quote
Passenger jets are usually a lot more controllable when they fail.  They are capable of gliding even without engines, and they can dump fuel before impact.  They also don't have pressurized fuel tanks like rockets.

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