Comment by dahart | Hacker News Reader

Comment by dahart | Hacker News Reader

It took me a minute to find the actual full proposal text: https://www.regulations.gov/document?D=FAA-2019-0229-0001

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?

Blue Origin's comments seem mostly to be concerned that the language of the proposal often doesn't meet the intent of the proposal, and that some things are undefined.

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...

I haven't read the comments, but a lot of the organizations you mentioned have made much more pointed statements elsewhere. The CEO of Blue Origin said that the "FAA’s proposed regulations will stifle the innovation that will lead to safer designs and operations". The head of the CSF testified that "Most current or prospective FAA space licensees have determined that the NPRM [notice of proposed rulemaking], in some ways, are worse than today’s obsolete rules."

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.

> that don’t look great for the FAA...

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.

The FAA waited for 2 catastrophic failures with the MAX before grounding all planes, risking the safety of thousands.

Even after those failures they seemed doggedly committed to keeping the MAX in the air, until the issue was forced by foreign regulatory agencies.

> I’d say the FAA has a pretty good track record

had

Boeing is an American company and the FAA declared the Boeing Max safe to fly in US airspace, and didn't require the re-certification it should have had after major structural changes to the 737 design. What many people learned after the crashes is that the FAA is essentially letting Boeing certify their own airplanes, in an effort to be pro-business and soft on regulation. We are only lucky a crash didn't happen in US airspace, those crashes do count against the American safety record.

> 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?

> Boeing is an American company and the FAA declared the Boeing Max safe to fly in US airspace, and didn't require the re-certification it should have had after major structural changes to the 737 design.

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.

> The crashes where in Indonesia and Ethiopia and those planes weren’t under the jurisdiction of the FAA

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.)

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