SAN FRANCISCO – A report delivered in October to the Federal Aviation Administration’s Office of Commercial Space Transportation recommends a streamlined approach to launch licensing aimed at significantly speeding up the process and reducing its complexity.
Instead of the current approach, where companies follow 350 pages of federal safety regulations and meet 2,845 specific requirements, the report, prepared under contract to the FAA by Safety Engineering and Analysis Center (SEAC), a division of APT Research Inc. of Huntsville, Alabama, suggests the government could attain the same level of public safety by auditing a company’s own safety program.
This approach, called Safety Case, puts the onus on the applicant to prove their planned operations offer the same level of public safety as the prescriptive approach, according to “A New Path to Launch Licenses,” the Oct. 22 report written by SEAC founder Tom Pfitzer and Katie Byers, an APT writer and regulatory specialist.
The Trump Administration has focused heavily on streamlining regulations. Space Policy Directive 2, published in May calls for the FAA to propose streamlined rules for commercial space launch licensing no later than Feb. 1, 2019. The streamlined rules are expected to follow a more traditional path to licensing, which the SEAC report calls Path A.
SEAC recommends the FAA create an additional path to commercial licensing, which it calls Path B. Following Path B, companies would work collaboratively with the FAA to obtain certification. Path B is similar to the approach the FAA follows when certifying airline operations.
Path B involves two main components. First, a launch safety expert would review a company’s safety program to evaluate its maturity. “A feature of the audit is that it is also instructive, clearly pointing to the steps needed to achieve a higher level of maturity,” according to the SEAC report obtained by SpaceNews.
Next, the firm applying for commercial launch certification would present its Safety Case, documentation showing that it has a “compelling, comprehensive and valid case” to prove its safety, according to the report. During the Safety Case review, the launch vehicle program manager would certify the vehicle and launch operations meet public safety requirements. Then, an independent third-party would review the evidence and evaluate its validity before the FAA decided whether to approve the commercial license application.
For companies already launching rockets, the streamlined process could be completed in as little as three months, the report said. Companies still planning their initial launch and flight operations may need more time to show they can meet public safety requirements, the report added.
Path B would require a significant cultural change for FAA Office of Commercial Space Transportation, known as FAA AST, according to the SEAC report.
“All indications are that the prior culture at FAA AST has been to stipulate multiple requirements and then work with applicants to ensure compliance with the requirements unless exempted,” the SEAC report said. “The preferred cultural approach says, ‘We are glad you want to launch. We are here to help ensure public safety. As soon as you can develop convincing evidence that your activities protect the public, we will grant the license.’ ”
Eric Stallmer, Commercial Spaceflight Federation president, said by email, “Many of the ideas contained in APT’s report echo recommendations made by the FAA’s Aviation Rulemaking Committee on Streamlining Launch and Reentry Licensing Requirements. So hopefully this report significantly informed the draft rulemaking that the FAA is planning to release on February 1st, 2019.”
James Muncy, Commercial Spaceflight Federation senior policy advisor on regulation and a space policy consultant, said by email, “APT’s report takes a ‘do no harm’ approach by allowing companies to use existing regulations and well-understood licensing processes or a new path using system safety processes. The latter one is different but likely to be simpler and better. In that way, it helps new entrants without upsetting the practices of established companies.”
APT works under contracts to support safety at more than 40 U.S. government agencies, including NASA’s Kennedy Space Center, the U.S. Missile Defense Agency and the Department of Defense Explosives Safety Board.