FAA Considers Relaxing Licensing Requirements for Rockets
regulations.gov
regulations.gov
The link here is to the comments, and definitely take a minute to read some submitted comments from the space industry, congress, airlines & observers. They are enlightening. Having read about a dozen extremely well thought out letters so far, I’ve seen nothing but very serious concerns with the proposal.
Blue Origin, for example, created a diagram of the new licensing process, and detailed why it’s not likely to result in the monetary savings that the FAA is claiming.
https://www.regulations.gov/contentStreamer?documentId=FAA-2...
Many people commenting that the proposal isn’t adequately addressing the FAA’s mandate to public safety. To me it seems like a curious move to deregulate in the wake of the Boeing Max crashes that don’t look great for the FAA... but I don’t know how the FAA is structured, is it fair to draw any lines between rockets and airline regulation, or is rocket licensing a completely separate group of people?
I am not sure I understand. The crashes where in Indonesia and Ethiopia and those planes weren’t under the jurisdiction of the FAA: presumably they were inspected by the relevant aviation authorities in those countries. There weren’t any crashes in the US, so how does that make the FAA look bad? The US commercial aviation safety rate is unsurpassed and exceptionally good. I’d say the FAA has a pretty good track record. Just looking at the operational history of Indonesian airlines — it’s clear that their regulatory body has a serious problem. But the FAA? The American safety record is compelling.
had
> Just looking at the operational history of Indonesian airlines — it’s clear that their regulatory body has a serious problem
"Problems" there, or not, it seems like a bad idea to try and blame the Indonesian airlines for a known design flaw in a Boeing airplane that the Boeing company tried to hide and cover with yet another known design flaw, the sum of which are known to have been the cause of both crashes. Boeing tried this tactic of blaming others, and it hasn't worked out well for them.
Edit: I was having deja-vu and realized I've answered this very same question of you before. https://news.ycombinator.com/item?id=19837481 What is your reason for continuing to deny the role of the FAA in the 737 Max issue, and continuing to suggest that the crashes are the fault of the foreign operators that Boeing hid information from?
There's a pretty strong argument to be made that the 737-600 (first of the NextGen) was a far greater departure structurally from the 737 type certificate than the 737-Max was from the immediately preceding 737 aircraft. The Nextgen aircraft have a wingspan 16 feet wider, a wing area of 125% of the Classic 737, and a length as much as 44 feet longer (even slightly longer on the -Max).
Certification of derivative aircraft on a common type certificate is extremely common and generally has proven to be safe over the years. This specific certification has serious deficiencies, but that doesn't mean the practice in general is wrong (IMO).
In fact, the costs of certification from scratch are so high that it in some cases holds back development advances (because the optimization questions now include regulatory optimizations like "what can we certify under the old type certificate?" in addition to the actual physical engineering concerns.
To avoid requiring every plane be certified in every jurisdiction, regulators have agreements that let them rely on others' certifications. The 737 MAX wasn't independently by the Indonesian Ministry of Transportation; instead, they relied on the FAA to do its work. The failure is thus in the FAA's court.
(Note: I don't think you should be getting downvoted for your comment. It's naive, but an honest misunderstanding.)
Virgin Orbit also thinks that it remains too prescriptive.
ULA is generally supportive save for some definitional nitpicking.
Commercial Spaceflight Federation has same concerns as Blue.
Rocket Lab supports generally, with some technical objections.
SpaceX simply asks for more time.
Almost everyone thinks it's a bit rushed and feel like they have not had proper chance for input (except for ULA who urges more speed.)
While one might see "very serious concerns", they seem to be more with the implementation than the intent; transition to performance-based rather than prescriptive rules seems to be widely supported. If there's any flaw here, it's that the industry seems to be rather taken aback by the speed at which this has been done.
And, yes, the rocket side of the FAA is completely different; it was once a separate department under the Secretary of Transportation. https://en.wikipedia.org/wiki/Office_of_Commercial_Space_Tra...
Part of the problem is that the new rules are ~600 pages, and some of the details of the rules are contained in the 1,000 pages of supporting documents. A larger company like ULA may have an army of lawyers on staff to quickly figure out the changes and start figuring out how they need to adapt, while it would be more onerous and slower for some of the smaller companies.
It would be interesting to see a rewrite of hobby/amateur rocketry laws but this isn't it.
> This action would also enable flexible timeframes, remove unnecessary ground safety regulations, redefine when launch begins to allow specified pre-flight operations prior to license approval, and allow applicants to seek a license to launch from multiple sites.
I feel as though we do want careful and deliberate launches. After all, this IS rocket science.
> remove unnecessary ground safety regulations
Hmm.
Another way of looking at costs: eased regulations vs long time investigations and associated costs when something goes wrong due to eased regulations.
If the regulation requires hand-inspecting part X and someone invents a machine to inspect part X, you are now incurring costs solely due to regulation.
The above is somewhat orthogonal to my main point. If you inspect something 10 times, then it is marginally safer than if you inspect something 9 times, and so on and so forth. Everything can be made more expensive and safer or less expensive and less safe. If there are benefits of increased spaceflight that exceed the downsides of the reduced safety, and lowering the costs will encourage such increased spaceflight then it makes sense from a policy point of view to reduce the safety.
This is in addition to the point that regulatory compliance tend to increase costs by more than the amount needed to increase the safety (my example of hand-inspecting a part that could be machine inspected is one example; paying someone to check up that the regulations are actually being followed is another).
Prime directive is don't hurt innocent people uninvolved with your adventure. In the case of rockets this has to mean launch windows that don't intersect with air traffic and plans to avoid dropping burning boosters full of fuel into playgrounds.
Second directive is try not to kill your friends and employees.
After that, if it's just you, you can have a lot of leeway as long as the paperwork is in order.
Do what you want, but if you kill someone, you're gonna have to pay a big fine to the government, and you're going to have to have insurance to pay that fine if you go bankrupt.
Then the only question is how big should the fine be - and the FAA should set that to trade off safety vs progress.
Let's start at $250M per life lost. Insurance for that would probably work out to ~10 million per launch, given current accident rates.
And if the cars still do crash occasionally, I would expect the manufacturers to leave the seatbelts in for as long as that made sense.
Similarly, what if someone invents an airbag system that works significantly better than current setups, but requires that the user not be wearing a seatbelt because that leads to acceleration in the wrong direction? Should we have to wait for the government to update their standards, or should companies be allowed to improve things immediately?
This is all an incentives problem, and so the idea is to make the incentives align. If the manufacturer is penalized for your death by an amount equal to your value of your life, the incentives are aligned. If the manufacturer just has to make it have a seat belt and airbags, they'll make the flashiest system they can advertise regardless of how it works in the real world. We have independent testing to attempt to validate those claims, but the incentive structure is still all wrong.
> Contrary to popular belief, you can put a dollar value on human life. That dollar value is $5.8 million. Denying this leads to terrible consequences. Let me explain.
1. https://www.epa.gov/environmental-economics/mortality-risk-v...
2. https://en.wikipedia.org/wiki/Value_of_life#United_States
For example, the requirements for expendable and reusable rockets were written very independently, so if you want to re-license an existing expendable rocket to be reusable you basically have to start from scratch. The desire from a lot of the smaller launch providers is to have a set of generic "rocket" requirements, with specific addendums for where expendable and reusable vehicles differ.
There's also a lot of redundancies when you want to launch a vehicle from multiple locations. If you want a second launch site, there's reasonable things you have to do like showing the FAA that your flight termination system won't rain flaming hydrazine into someone's backyard. However, you also have to expend effort re-explaining things that are totally location independent, like your software development methodologies.