review of may 2012 actions & input to faa/ast

Federal AviationAdministrationFederal AviationAdministration

Presented to: COMSTAC

By: Debra Facktor Lepore, OWG Chair

Date: October 10, 2012

Report to COMSTAC of the Operations Working Group

(formerly known as the Space Transportation Operations Working Group, STOWG)

Federal AviationAdministration

OWG Working Group Report to COMSTACOctober 10, 2012

Review of May 2012 Actions & Input to FAA/AST

• May 2012 Utilized new meeting format, kicking off with FAA/AST priorities

• Positive response from FAA/AST on STOWG Observations, Findings, Recommendations

• Established new Working Group for On-Orbit Authority• Re-opened survey of Commercial Spaceport Licensing

approaches• Continued to participate in UN working groups on Long

Term Sustainability of Space• Held two telecons• New topic of ISO actions by China for Launch Standards

OWG Working Group Report to COMSTAC, October 10, 2012



FAA/AST Priorities related to Operations

• #1: On-Orbit Authority for FAA/AST• #3: Spaceport Licensing• Code of Conduct & Long Term Sustainability of

Space• Global Regulations• Range Commercial Investment• Standards crafted by Human Spaceflight Industry




On-Orbit Authority discussion from May (“Where we started”)• RECOMMENDATION (May): COMSTAC agrees that

On-Orbit Authority is worthy of consideration and discussion, given the uncertainties surrounding jurisdiction and regulation questions of on-orbit operations involving space transportation.

• Working Group Formed:– Tim Hughes -- Oscar Garcia– Brett Alexander -- Brad Cheetham– Jeff Greason -- Aaron Orsterle– Billie Reed -- Diane Howard– Chris Kunstadter -- Richard Rankin -- Mary Lynne Dittmar




On-Orbit Authority – Sub-Working Group Charter (Rev 1)

• Sub-Working Group Charter (articulated August 6):– Define problem and agree on definitions; – Identify use cases where regulatory authority appears to be

“missing;” – Identify which regulatory authority has primacy;– Define substance of what this authority should be.

• This was identified by the sub-group to be beyond the scope of the working group as it requires specific information about the solution to appropriately address.




On-Orbit Authority – Sub-Working Group Charter (Rev 2)

• Revisit COMSTAC Charter (as articulated by George Nield):– “AST requests that COMSTAC draft a recommendation on how

the US government should address on-orbit authority.”• As interpreted by the sub-working group this

charter primarily seeks to answer the question "what is the need for On-orbit authority" and “does the FAA play a role in satisfying this need”– This is what AST can expect to gain feedback on from

COMSTAC by October.




On-Orbit Authority: sub-WG Input• Is there a need for on-orbit authority?

– A need for on-orbit authority was identified in order to facilitate space traffic coordination. No other justification was identified for such on-orbit authority by this group at this time.

• Does FAA/AST play a role in this?– The group identified FAA/AST as an appropriate entity to lead the effort of

space traffic coordination. – With this conclusion, the sub-WG requests further information and definitions

in order to provide input on required scope and extent of such on-orbit authority to accomplish the mission of space traffic coordination. Future discussion identifying the specific approach or plan for such coordination must include key stakeholders representing on-orbit transportation and operations.

• Space Traffic Coordination– Defined here as the coordination between on-orbit operators both foreign and

domestic, spanning commercial, civil, and military missions to avoid physical or radiofrequency interference.




Discussion at OWG on October 9

• Input from FAA/AST on the problem, types of risk, international obligations, responsibility gap, indemnification, and desired input from COMSTAC

• Discussion included:– What other US federal agencies follow this problem (e.g., FCC)– Is this a solution looking for a problem– Is there a step between saying on-orbit authority is needed and

doing a study that investigates all the questions, and stakeholders

– What is the right input from the OWG to COMSTAC at this time• Agreed to accept the input of the sub-WG at this

time




On-Orbit Authority Observation & Finding

• OBSERVATION #1: COMSTAC observes that On-Orbit Authority is a complex issue, with many questions, numerous stakeholders, and no consensus on why or how to address such authority in the broadest sense.

• OBSERVATION #2: On-Orbit Authority involves international stakeholders and this issue may have interactions with other international issues (long term sustainability of space, standards, etc).

• FINDING #1: A need for on-orbit authority was identified in order to facilitate space traffic coordination. No other justification was identified for such on-orbit authority by this group at this time.




On-Orbit Authority Recommendations

• RECOMMENDATION #1: FAA/AST examine the use case of “space traffic coordination” and create a scenario and analysis addressing this issue.

• RECOMMENDATION #2: FAA/AST share the results of recommendation #1, and continue this dialogue with COMSTAC.




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Spaceport Licensing White Paper and Survey

• October 2011 - STOWG accepted task to develop white paper to recommend changes to regulations 14 CFR Part 420

• STOWG developed an online survey• Industry groups notified members• STOWG received 28 responses as of May 2012

and prepared draft white paper• Deliberations in May 2012 concluded more

input needed• Re-opened Survey and received 5 additional

responses• Final white paper prepared

THANK YOU to: Brian Gulliver (RS&H), Oscar Garcia (Interflight Global), and Jeff Greason (XCOR) and all who responded




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Summary of Survey Results• Difference in perspective of the relevance of launch site

licensing requirements between spaceports and consultants– Spaceports- Express more change needed– Consultants- Express less change needed

• The results lean toward the conclusion that current regulations are a better fit for vertical launch orbital launch sites than for horizontal suborbital launch sites– The latter can benefit from modular “right fit” approach

• The least relevant requirements were identified as:– Propellant Handling / Lightning Protection

• Some difference in opinion within spaceport/operator community (NEW)– This became more clear in the final analysis

See full white paper for details




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OWG Input to COMSTAC1) The White Paper should be accepted and submitted to FAA/AST2) White paper suggests 4 possible options, to review potential

methods for re-aligning the regulations with the commercial spaceflight industry. Views of which option to pursue depend on the viewpoint of the system and the spaceport.

3) FAA/AST is going to pursue a rule-making on this subject4) VOTE TO ACCEPT THIS WHITE PAPER

• Option 1 • No action

• Option 2 • Develop appendix to Part 420 or guidelines

• Option 3 • Modify Part 420 to be modular

• Option 4 • Start Over




Spaceport Licensing Observation & Recommendation• OBSERVATION: The Spaceport Licensing survey results

affirm that “one size does not fit all” with regards to spaceport licensing, as the perspective depends on the system and the spaceport. One way to handle this is create modularity in the regulations.

• RECOMMENDATION: COMSTAC recommends that FAA/AST accept the FINAL white paper and survey findings as input to the expected rule-making process and that the rule be amended or rewritten to include maximum flexibility with regards to emerging launch operations and sites. The dialogue with industry should continue.




International Developments in Space Operations• Long-Term Sustainability of Space (A United Nations COPOUS

Activity): Update– Dick Buenneke, State Dept (Update and Group B report)– John Sloan, FAA/AST (Update and Group D report)– Rachel Yates, COMSTAC (Group D rep)– Chris Kunstadter, COMSTAC (Group B rep)

• International dialogue continues on this subject, with political not legal commitments being discussed

• Goal is “best practice guidelines,” but this is hard!– Many guidelines are common sense but not common practice

• Various draft papers being worked, and private sector continues to have a voice

• Next formal UN meeting in February 2013




Long-Term Sustainability of Space (LTSSA)• United Nations Committee on the Peaceful Uses of Outer

Space (UN COPUOS)– Working group on long-term sustainability of space activities now

underway– Expert group reviews of “best practice” guidelines in four areas:

A. Sustainable space utilization supporting sustainable development on Earth

B. Space debris, space operations and tools to support collaborative space situational awareness

C. Space weatherD. Regulatory regimes and guidance for actors in the space arena

• LTSSA working group will guilds on ongoing work in existing international organizations and bodies, including:– Inter-Agency Space Debris Coordination Committee– Consultative Committee for Space Data Systems– International Organization for Standardization




Finding & Recommendation: International Code of Conduct and UN Long Term Sustainability of Space

• Finding (SAME AS MAY 2012)– Private sector engagement by COMSTAC and others is effective

and continues to be welcome. – The communication mechanisms being used by FAA/AST to keep

industry informed and engaged continue to work well. – COMSTAC participation in the UN COPUOUS process on Group B

and Group D should continue.• Recommendation (SAME AS MAY 2012)

– FAA/AST continue to play this facilitation role and keep COMSTAC informed of key issues and any key actions needed.




DOD Proposal to Enhance Commercial Interactions at Federal Ranges• Update by Maj Horne, SAF/AQSL• The proposed FY12 NDAA addition of Section 2275

“Commercial Space Launch Cooperation” to “U.S.C. Title 10 Armed Forces” will:– Synchronize Title 10 with Title 15 (Commerce) and Title 49

(Transportation)– Enable DoD partnerships with states and commercial users to

Increase capacity, Share resources, Combine resources, Enable commercial space augmentation

• Legislative updates in process as of October 2012• Once through the Hill, DOD will engage with industry for

further engagement




Finding: DoD Proposal to Enhance Commercial Interactions at Federal Ranges

• Finding (SAME AS MAY 2012)– It remains useful for COMSTAC and FAA/AST to remain

appraised of this process. The communication process is working. When the time is right, COMSTAC remains the right place to engage in industry dialogue on next steps.




Launch Vehicle International Standards and Best Practices (new topic)

• Speaker: Fred Slane, Executive Director, Space Infrastructure Foundation and head of US Delegation to ISO

• Report on at least 3 ISO standards proposals offered by China– Determining and communicating post deployment trajectories

of multiple payloads deployed from same launch vehicle– Launch vehicle failure mode analysis and booster burnout

state– Proposed by China Advanced Launch Vehicles Technology

Institute




ISO Standards Observation & Recommendations

• OBSERVATION #1: The international standards developments are interesting and worthy of following and continuing dialogue.

• OBSERVATION #2: This activity, plus the LTSSA and on-orbit authority, indicate that the international community will play an increasing role in space operations of the future.

• RECOMMENDATION #1: FAA/AST follow this subject and use COMSTAC as a venue for discussion and a mechanism to keep industry informed and seek responses as necessary. This would parallel the role that FAA/AST is playing on the international development topic. The international subjects should be addressed at a holistic level.




Additional Presentations

• Body of Knowledge for Commercial Spaceport Practices– Herb Bachner on behalf of the FAA/AST Center of Excellence

research team– Visit: http://contentdm.nmsu.edu– Refresh the page (or it won’t load the BoK info)– LOGIN USERNAME = libguest– PASSWORD: libguest23

• FastForward Project– Dominic DePasquale, Deputy Director, FastForward Project

Study Group– Visit: www.fastforwardproject.com


http://contentdm.nmsu.edu/

http://www.fastforwardproject.com/



OWG Telecons

• Dates to be organized and will be communicated

23OWG Working Group Report to COMSTAC, October 10, 2012



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OWG ContactSend your email to get on the STOWG distribution list

Debra Facktor Lepore, ChairPresident, DFL Space LLCIndustry Professor, Stevens Institute of

[email protected]

Sue Lender, FAA/[email protected]


mailto:[email protected]

review of may 2012 actions & input to faa/ast

Documents

group report

orbit authority discussion

orbit operations

regulatory authority

revisit comstac charter

powerpoint presentation

subwg inputis

owg chairdate