Draft CCT-REQ-1130 ISS Crew Transportation and Services Requirements

[beancounter]

http://waynehale.wordpress.com/2010/11/14/the-coming-train-wreck-for-commercial-human-spaceflight/

Doesn't look very promising if commercial was looking for reduced requirements and reduced paperwork costs!

(Note, post the direct link only, not every other blog site that points to the same original link).

[neilh]

http://waynehale.wordpress.com/2010/11/14/the-coming-train-wreck-for-commercial-human-spaceflight/

Doesn't look very promising if commercial was looking for reduced requirements and reduced paperwork costs!

Sigh. Is NASA -intentionally- trying to destroy its future?

[Proponent]

Sigh. Is NASA -intentionally- trying to destroy its future?

Or maybe to guarantee that the "back-up" capability of Orion/SLS to carry crew to the ISS will be "needed."

EDIT:  Added missing "to."

[MATTBLAK]

Sounds more plausible.

[notsorandom]

Lets not assume malice when none is needed to explain these requirements. Here is a quote from Mr. Hale's blog:

As with all good government bureaucracies, NASA believes that improved processes (read:  increased bureaucracy) is the answer to preventing future problems.  So NASA writes longer and longer specifications and requirements, and demands more and more documentation and proof.  Somewhere along the line, we have crossed over the optimum point to ensure safety and just added cost and delay

I think that this is much more likely an explanation then someone actively scheming to kill commercial spaceflight from within NASA.

[Lars_J]

The majority of it is not malice, that seems certain. But make no mistake - from the flak commercial crew efforts get in congress and from other places - there are elements out there (most of them with their hands in the CxP contracts) that do NOT want it to succeed.

Who else do you think is out there talking about commercial crew as "bailouts" and "unsafe"?

It is a minority for sure, but those elements should not be ignored.

[neilh]

Wayne Hale makes a really interesting point in his blog post about NASA's Launch Services program:

When Frank Bauer and I proposed a new model of doing business to the agency leaders, we patterned it on the NASA Launch Services organization which acquires expendable launch vehicles for scientific satellites.  NLS has much less oversight and far fewer requirements than usual NASA programs because the providers have a proven track record of success launching rockets for the DoD or for commercial users.  This model appeared to us to be the way to allow commercial entities to provide safe but much more cost effective space flight transportation.

Any thoughts on whether NASA Launch Services would be a good model for commercial crew?

[ugordan]

For a while I've had a feeling NASA "commercial crew" would be more trouble than its worth to the likes of SpaceX et al. This doesn't help dispel that feeling.

[docmordrid]

Lawyer -> Federal court -> Past Practices argument re: Soyuz

Not to mention that this kind of ISS restriction makes a good part of the business case for private space stations & private access to same. They can be either US outfits, Russian or whatever - but if not US our govt will have once again screwed us out of another market.

[Jorge]

Wayne Hale makes a really interesting point in his blog post about NASA's Launch Services program:

When Frank Bauer and I proposed a new model of doing business to the agency leaders, we patterned it on the NASA Launch Services organization which acquires expendable launch vehicles for scientific satellites.  NLS has much less oversight and far fewer requirements than usual NASA programs because the providers have a proven track record of success launching rockets for the DoD or for commercial users.  This model appeared to us to be the way to allow commercial entities to provide safe but much more cost effective space flight transportation.

Any thoughts on whether NASA Launch Services would be a good model for commercial crew?

Perhaps once a few commercial providers meet the condition I highlighted.

[Jim]

Wayne Hale makes a really interesting point in his blog post about NASA's Launch Services program:

When Frank Bauer and I proposed a new model of doing business to the agency leaders, we patterned it on the NASA Launch Services organization which acquires expendable launch vehicles for scientific satellites.  NLS has much less oversight and far fewer requirements than usual NASA programs because the providers have a proven track record of success launching rockets for the DoD or for commercial users.  This model appeared to us to be the way to allow commercial entities to provide safe but much more cost effective space flight transportation.

Any thoughts on whether NASA Launch Services would be a good model for commercial crew?

Perhaps once a few commercial providers meet the condition I highlighted.

there is the certification method for those with less flight experience.

[jongoff]

Wayne Hale makes a really interesting point in his blog post about NASA's Launch Services program:

When Frank Bauer and I proposed a new model of doing business to the agency leaders, we patterned it on the NASA Launch Services organization which acquires expendable launch vehicles for scientific satellites.  NLS has much less oversight and far fewer requirements than usual NASA programs because the providers have a proven track record of success launching rockets for the DoD or for commercial users.  This model appeared to us to be the way to allow commercial entities to provide safe but much more cost effective space flight transportation.

Any thoughts on whether NASA Launch Services would be a good model for commercial crew?

Perhaps once a few commercial providers meet the condition I highlighted.

Cause you know, those ULA schmucks have no experience launching billion dollar satellites... ;-)

Though I'm guessing you're probably referring more to the capsule side?  I have to agree with some of the other questioners--are these standards that any vehicle NASA has designed or used, ever met in their entirety?  I wonder if SLS/MPCV will be held to the same standards.

~Jon

[Namechange User]

Wayne Hale makes a really interesting point in his blog post about NASA's Launch Services program:

When Frank Bauer and I proposed a new model of doing business to the agency leaders, we patterned it on the NASA Launch Services organization which acquires expendable launch vehicles for scientific satellites.  NLS has much less oversight and far fewer requirements than usual NASA programs because the providers have a proven track record of success launching rockets for the DoD or for commercial users.  This model appeared to us to be the way to allow commercial entities to provide safe but much more cost effective space flight transportation.

Any thoughts on whether NASA Launch Services would be a good model for commercial crew?

Perhaps once a few commercial providers meet the condition I highlighted.

Cause you know, those ULA schmucks have no experience launching billion dollar satellites... ;-)

Though I'm guessing you're probably referring more to the capsule side?  I have to agree with some of the other questioners--are these standards that any vehicle NASA has designed or used, ever met in their entirety?  I wonder if SLS/MPCV will be held to the same standards.

~Jon

I love it how so many want to see an instant conspiracy and cry foul.  While Jorge clearly was not talking about ULA as you theorized, everything does not always have to be about them either. 

Clearly too many requirements can be a problem and something will likely have to be done about this.  As for NASA vehicle requirements, specifically the STS since it is really the only vehicle at this point, you should try to check out NSTS 07700 sometime. 

[jongoff]

I love it how so many want to see an instant conspiracy and cry foul.

And I love your ability to read stuff into what I wrote that wasn't there.  It's truly impressive.  Just for the record, I personally think Wayne Hale's point--that this is more well-intentioned bureaucrats than some intentionally malicious anti-commercial-space effort. 

While Jorge clearly was not talking about ULA as you theorized, everything does not always have to be about them either.

My point there (which was meant as a bit of friendly ribbing--I've known Jorge over the internets for almost half my life now) was that a lot of these companies, including Orbital and ULA have actually demonstrated prove track records of success in at least some parts of the commercial crew delivery parts--notice I followed up by pointing out that he was probably talking about the capsules.  And I admit that nobody in the US (including NASA) has a demonstrated a recent track record of success with crewed capsules.  I just agree with Wayne, that something's gotta give.

~Jon

[Namechange User]

I love it how so many want to see an instant conspiracy and cry foul.

And I love your ability to read stuff into what I wrote that wasn't there.  It's truly impressive.  Just for the record, I personally think Wayne Hale's point--that this is more well-intentioned bureaucrats than some intentionally malicious anti-commercial-space effort. 

While Jorge clearly was not talking about ULA as you theorized, everything does not always have to be about them either.

My point there (which was meant as a bit of friendly ribbing--I've known Jorge over the internets for almost half my life now) was that a lot of these companies, including Orbital and ULA have actually demonstrated prove track records of success in at least some parts of the commercial crew delivery parts--notice I followed up by pointing out that he was probably talking about the capsules.  And I admit that nobody in the US (including NASA) has a demonstrated a recent track record of success with crewed capsules.  I just agree with Wayne, that something's gotta give.

~Jon

Jon, you are the one who said you have to "agree with some of the other questioners".  Given this thread is 1 page long and the "other questioners" along your lines of thinking are saying what they are saying, then I believe it was appropriate for me to comment as I did. 

Thank you for commenting and clarifying you do not believe this to be a malicious anti-commercial effort.  Yet, you did throw MPCV/SLS into the mix too, possibly to imply a potential double standard so I will also assume that was not your intent. 

I'm also glad to know you and Jorge are internet buddies and that you agree with Wayne. 

[jongoff]

Jon, you are the one who said you have to "agree with some of the other questioners".  Given this thread is 1 page long and the "other questioners" along your lines of thinking are saying what they are saying, then I believe it was appropriate for me to comment as I did. 

You know what, OV, that's fair.  I had just gotten through reading discussion about this on several of the blogs as well as this, and I wasn't clear which questioners I was referring to.  My apologies for being a snarky pain in the neck.

Thank you for commenting and clarifying you do not believe this to be a malicious anti-commercial effort.  Yet, you did throw MPCV/SLS into the mix too, possibly to imply a potential double standard so I will also assume that was not your intent.

The MPCV/SLS comment was meant less as a belief in an intentionally malicious effort to use a double standard against commercial crew as a comment that as I understand it, NASA has often come up with "human rating" rules that were strict enough that all of their vehicles have had to fly with waivers to those rules.  If NASA (non-maliciously) came up with ridiculous rules for commercial crew, do you think they would hold their own systems to the same standards?  History, at least as I understand it, would suggest otherwise.  But maybe I'm wrong?

I'm also glad to know you and Jorge are internet buddies and that you agree with Wayne. 

:-)  I don't know if Jorge would call me an internet buddy. 

As for the other comment, you're not the only reader of NSF you know.  I do try to find common ground with people when I can, even if they're fun to argue with.

~Jon

[Jorge]

Wayne Hale makes a really interesting point in his blog post about NASA's Launch Services program:

When Frank Bauer and I proposed a new model of doing business to the agency leaders, we patterned it on the NASA Launch Services organization which acquires expendable launch vehicles for scientific satellites.  NLS has much less oversight and far fewer requirements than usual NASA programs because the providers have a proven track record of success launching rockets for the DoD or for commercial users.  This model appeared to us to be the way to allow commercial entities to provide safe but much more cost effective space flight transportation.

Any thoughts on whether NASA Launch Services would be a good model for commercial crew?

Perhaps once a few commercial providers meet the condition I highlighted.

Cause you know, those ULA schmucks have no experience launching billion dollar satellites... ;-)

Though I'm guessing you're probably referring more to the capsule side?

Absolutely... and I thought that was obvious enough that I did not say so explicitly.

[neilh]

http://waynehale.wordpress.com/2010/11/14/the-coming-train-wreck-for-commercial-human-spaceflight/

Doesn't look very promising if commercial was looking for reduced requirements and reduced paperwork costs!

Sigh. Is NASA -intentionally- trying to destroy its future?

Hmm, I'm being reminded of how poorly sarcasm transmits over the internet. Just to be clear, I don't -actually- think NASA is intentionally trying to destroy its future. It just seems that way sometimes.

Regarding NASA Launch Services, what's the certification process like? To what extent could that process be applied to commercial crew? How should launches of the rocket without a capsule and launches of the same rocket with a capsule contribute to the track record for certification purposes?

[beancounter]

So NASA determines the Human rating requirements for crew transport to and from the ISS. 

What about a private station like Bigelow's?  Would this be the FAA?  Could a commercial company, say Boeing, decide that it isn't interested in the ISS and try to get certification for providing crew services to and from private stations?

[Jim]

So NASA determines the Human rating requirements for crew transport to and from the ISS. 

What about a private station like Bigelow's?  Would this be the FAA?  Could a commercial company, say Boeing, decide that it isn't interested in the ISS and try to get certification for providing crew services to and from private stations?

NASA determines the Human rating requirements for crew transport to and from the ISS for NASA astronauts and no one else.

FAA jurisdiction is commercial spacecraft.  Certification isn't required for commercial spaceflight.

[Gravity Ray]

So NASA determines the Human rating requirements for crew transport to and from the ISS. 

What about a private station like Bigelow's?  Would this be the FAA?  Could a commercial company, say Boeing, decide that it isn't interested in the ISS and try to get certification for providing crew services to and from private stations?

NASA determines the Human rating requirements for crew transport to and from the ISS for NASA astronauts and no one else.

FAA jurisdiction is commercial spacecraft.  Certification isn't required for commercial spaceflight.

Well suddenly neilh's "sarcasm" about NASA intentionally destroying its own future becomes much more relevant. If NASA puts the commercial launchers like Boeing in a position that they say "forget NASA" lets just launch for other countries to some commercial Space Station, then all NASA has managed to do is make itself irrelevant. No?

[Norm Hartnett]

Hum, if I remember correctly both Orbital and SpaceX are taking advantage of onramps to the NASA Launch Services program. Further, the entire COTS/CRS program was patterned after the NLS program so the kinds of requirements that these programs have should provide a good baseline for evaluating this Draft proposal.

[Namechange User]

The MPCV/SLS comment was meant less as a belief in an intentionally malicious effort to use a double standard against commercial crew as a comment that as I understand it, NASA has often come up with "human rating" rules that were strict enough that all of their vehicles have had to fly with waivers to those rules.  If NASA (non-maliciously) came up with ridiculous rules for commercial crew, do you think they would hold their own systems to the same standards?  History, at least as I understand it, would suggest otherwise.  But maybe I'm wrong?

~Jon

Again, try to research NSTS-07700, like all 32 or whatever volumes.  See how that dovetails into OVEI specifications, OMRSD requirements and various volumes there, SODB constraints, LCCs, etc. 

I don't think its fair to say NASA is loose on requirements and that what's good for commercial is below NASA.  Sure it's possible to take waivers, and even makes practical sense to do so at times.

All that said, too many and too perscriptive requirements will kill everything.  I personally like the OSP level 1 requirements and think something like that is apporpriate for something like commercial that will be led by various companies, designs, etc.

[Danderman]

Can we assume that Lockheed must meet all of these requirements for Zombie Orion, as well, but the government (ie, we) will pay the costs of that work? Can we print enough dollars to pay for meeting those requirements?

[robertross]

Can we print enough dollars to pay for meeting those requirements?

There seems to be no end to that, so I guess one could say YES.
(smily face but in a concerned manner)

[Namechange User]

Can we assume that Lockheed must meet all of these requirements for Zombie Orion, as well, but the government (ie, we) will pay the costs of that work? Can we print enough dollars to pay for meeting those requirements?

Lets also be fair and not jump off the deep end.  The requirements are "draft".  They are not final.  You have not seen them presumably.

While Wayne did well to take a shot across the bow, the IG is looking at it, etc these are not set in stone yet either. 

[neilh]

Wayne Hale posted a follow-up today:

http://waynehale.wordpress.com/2010/11/17/trying-to-clean-up-a-mess/

Lots of really fascinating stuff in the post, but here's his recommendation from the end:

So, what is my recommendation?  Simple.  Do what the Launch Services Program does:  require that providers HAVE standards and follow them – don’t make them pick particular processes or standards, let the flexible, nimble, [your adjective here] commercial firms pick what suits their business best.  As long as they have standards and stick to them – that is what we should require.
...
Don’t throw the baby out with the bathwater.  A good system can be devised, examples exist.  Human spaceflight is important to our nation and to the world.  Whether or not commercial firms can actually succeed is still open; but NASA and the FAA must walk a careful tightrope of ensuring safety while not killing the enterprise with over regulation.

[Jorge]

Can we assume that Lockheed must meet all of these requirements for Zombie Orion, as well, but the government (ie, we) will pay the costs of that work? Can we print enough dollars to pay for meeting those requirements?

According to Wayne Hale:

http://waynehale.wordpress.com/2010/11/17/trying-to-clean-up-a-mess/

Now I have re-read it and have some additional thoughts.  It is clear that this is a vast scaling down from the requirements that say, Ares-1 and Orion had.

[Patchouli]

I read the story NASA does need to clean up the bureaucratic red tape all that paper work should not be needed.

Gemini only had two dozen pages of requirements yet was one of the safest vehicles NASA ever flew.

It does seem like there are some people within NASA who do not want commercial crew to succeed.

[Gravity Ray]

I read the story NASA does need to clean up the bureaucratic red tape all that paper work should not be needed.

Gemini only had two dozen pages of requirements yet was one of the safest vehicles NASA ever flew.

It does seem like there are some people within NASA who do not want commercial crew to succeed.

I don’t know. It does seem that way. I just can’t bring myself to say there is malice. It’s just standard operating procedure for our government right now to be much more bureaucratic than it needs to be. It’s not just NASA, its all of our government. I really wish/hope that the people at the upper leadership levels of NASA will move to make the requirements safe but streamlined.

[yg1968]

McAlister responds to Wayne Hall's comments:
http://www.spacenews.com/civil/101119-former-shuttle-manager-decries-nasas-commercial-crew-safety-regs.html

[yg1968]

From the CCDev-2 Questions and Answers:

Background: Requirement 3.3.1.5 states “The CTS shall provide an overall abort effectiveness of 0.95 (TBC) for all single abort events along the nominal and dispersed ascent trajectory profile.”
95% Abort Effectiveness seems to be a rather aggressive requirement given the fact that NASA’s own calculations for the Ares I (which was suppose to be one of the safest crew vehicles NASA had ever designed) showed that this vehicle had an abort effectiveness of about 80% to 85%. Enclosed is a transcript from one of the recent Augustine Committee public hearings where one of NASA’s safety & reliability experts (highlighted in the document) specifically says that “95% effectiveness is a very difficult thing to achieve” – the transcript is available at www.nasa.gov/doc/378830main_Huntsville_Transcript_part4b.doc

Question: If one of NASA’s own experts in this area has already stated publically that a 95% abort effectiveness is very difficult to achieve, is this requirement reasonable to be placed on commercial crew providers? Moreover, requirement 3.2.1.2 states “The mean LOC risk for any ISS mission ascent phase shall be no greater than 1 in 1000” so since the mean LOC risk is simply the probability of launch vehicle failure that ends the mission (also called Loss-of-Mission or LOM Risk) multiplied by 1 – abort effectiveness, why not let the commercial crew providers determine how best to meet the 1 in 1000 LOC risk regardless of how effective the abort portion of this equation is?

Answer: The requirement documents referenced in the Announcement are in draft form and are intended to inform participants on the development of NASA’s crew transportation certification requirements.  NASA will continue to openly develop these requirements for eventual use in development and use in an ISS crew transportation system.  NASA is not requiring compliance as part of CCDev 2 but is informing industry as early as possible the considerations being given by NASA as part of crew rating space systems.

See:
http://procurement.jsc.nasa.gov/ccdev2/Questions%20and%20Answers%20Round%202%20final.docx

[Wayne Hale]

On Friday, Dec 10, NASA released an announcement about the full plan of requirements documents that Commercial Human Spaceflight Providers must comply with.  You can read that announcement at:
http://www.nasa.gov/exploration/new_space_enterprise/commercial/cctscr.html

There will be 5 requirements documents apparently.  And in the announcement is a link to the overall management requirements document (a 6th document) here:
http://www.nasa.gov/pdf/504982main_CCTSCR_Dec-08_Basic_Web.pdf

Apparently in January all the drafts will be released for industry comment.  I wonder if anybody will comment on them?  Besides me, that is.

[jongoff]

On Friday, Dec 10, NASA released an announcement about the full plan of requirements documents that Commercial Human Spaceflight Providers must comply with.  You can read that announcement at:
http://www.nasa.gov/exploration/new_space_enterprise/commercial/cctscr.html

There will be 5 requirements documents apparently.  And in the announcement is a link to the overall management requirements document (a 6th document) here:
http://www.nasa.gov/pdf/504982main_CCTSCR_Dec-08_Basic_Web.pdf

Apparently in January all the drafts will be released for industry comment.  I wonder if anybody will comment on them?  Besides me, that is.

I think most of us here on NSF are looking forward to your comments.  Not being a manned spaceflight guy, I'd probably miss a lot of the implications of subtleties in the rules (even if I had the time to read through 6 volumes of rules--which I don't). 

Thanks Wayne!  We all appreciate your insights in these matters.

~Jon

[yg1968]

Here is an article on this topic:
http://www.spaceflightnow.com/news/n1012/16humanrating/

[yg1968]

On Friday, Dec 10, NASA released an announcement about the full plan of requirements documents that Commercial Human Spaceflight Providers must comply with.  You can read that announcement at:
http://www.nasa.gov/exploration/new_space_enterprise/commercial/cctscr.html

There will be 5 requirements documents apparently.  And in the announcement is a link to the overall management requirements document (a 6th document) here:
http://www.nasa.gov/pdf/504982main_CCTSCR_Dec-08_Basic_Web.pdf

Apparently in January all the drafts will be released for industry comment.  I wonder if anybody will comment on them?  Besides me, that is.

Here are some relevant quotes from the document on page 12 and 13:
http://www.nasa.gov/pdf/504982main_CCTSCR_Dec-08_Basic_Web.pdf

5.2.2 The CCTS shall safely execute the Loss of Crew (LOC) requirements specific to the NASA Design Reference Mission (DRM). The Programs shall determine and document the LOC risk when DRMs are specified. The following are current:

a. The LOC probability distribution for the ascent phase of a 210 day ISS mission shall have a
mean value no greater than 1 in 1000
b. The LOC probability distribution for the entry phase of a 210 day ISS mission shall have a mean value no greater than 1 in 1000
c. The LOC probability distribution for a 210 day ISS mission shall have a mean value no greater than 1 in 270

5.2.3 The CCTS shall limit the Loss of Mission (LOM) risk for the specified NASA DRMs. The Programs shall determine and document the LOM risk when DRMs are specified. The following are current:

a. The LOM probability distribution for a 210 day ISS mission shall have a mean value no greater than 1 in 55
b. A spacecraft failure that requires the vehicle to enter earlier than the pre-launch planned end of mission timeframe shall be considered a loss of mission

Rationale: These LOC and LOM requirements are flown down from the NASA ESMD Exploration Architecture Requirements Document (EARD) and are consistent with NASA’s defined goals and thresholds for crewed vehicles. The LOC values are part of the overall certification process for the commercial launch vehicle and spacecraft and establish a basis for decision-making relative to safety enhancing features in the design including failure tolerance.

[kraisee]

Will there be a specific procedure published, that everyone will have to comply with when determining these LOC/LOM numbers?

As we learned during the Ares-I project, it was pretty easy for L1 and L2 management to manipulate the process in order to make the LOM/LOC numbers say anything they wanted.

So I see these particular numbers as thoroughly "fluid" without some very open and clear published methods of quantification that everyone can measure, ahead of time.

In short, what's to stop someone saying "Here's my new rocket & spacecraft and here is our evidence that they meet all of NASA's LOM/LOC targets -- just as long as you calculate them my way" ?

Ross.

[Robotbeat]

Will there be a specific procedure published, that everyone will have to comply with when determining these LOC/LOM numbers?

As we learned during the Ares-I project, it was pretty easy for L1 and L2 management to manipulate the process in order to make the LOM/LOC numbers say anything they wanted.

So I see these particular numbers as thoroughly "fluid" without some very open and clear published methods of quantification that everyone can measure, ahead of time.

In short, what's to stop someone saying "Here's my new rocket & spacecraft and here is our evidence that they meet all of NASA's LOM/LOC targets -- just as long as you calculate them my way" ?

Ross.

Quite right.

[baldusi]

In short, what's to stop someone saying "Here's my new rocket & spacecraft and here is our evidence that they meet all of NASA's LOM/LOC targets -- just as long as you calculate them my way" ?

Quite right.

You have one of those problems that you can't really solve. You either use statistics methods over a frozen design (and thus you can only calculate after some amount of flights (5 to 30, depending on your confidence level) or you extrapolate from previous designs, in which case you can have the Ares I situation.
The main problem is that a model that had problems in the first launches, but were corrected might be more robust than a paper model based on existing technology but redesigned from the ground up. Ditto for the design, manufacturing and launch services crew. I'm sure the NPO Energia people will check their tank sensors next time 
I've seen statistics manipulated this way in all kinds of regulation ways. For example, to calculate the cost of the telephone network, they used data from when the "central switch" was human operators switching cables, and applied it to the fiber optic + IP network. So the extrapolation from Ares I is childs game (so were the amounts of dollars and jobs in game).

[yg1968]

CCT-REQ-1130, Draft 3 (April 29, 2011):
http://prod.nais.nasa.gov/eps/eps_data/146207-DRAFT-001-001.docx
https://www.fbo.gov/index?s=opportunity&mode=form&id=730eba96b04dcff5b91a115df825ac23&tab=core&_cview=1