Federal Aviation Administration

Federal AviationAdministration

By: Sherman Council

Date: 15 August 2011

Office of Commercial Space Transportation

Experimental Permit Program


Experimental Permit Overview

Federal AviationAdministration 22

Outline

Experimental Permit Process

General Information

Requirements to Obtain an Experimental Permit

Safety Requirements

Terms and Conditions of the Experimental Permit




Experimental Permit Process




Process: Permit Review and Evaluation

Introductory Meetings• Initial communications with the potential applicant

• Discussion is welcome in early phases of program

Pre-application Consultation• Encompasses discussions with prospective applicant prior to

submittal of a permit application

Permit Application Submittal• AST determines when an application is complete enough

Permit Evaluation and Determination• AST has 120 days after receipt of a complete enough application to

make determination

• AST may toll an application




Process: Evaluation Flow

SafetyReview

Environmental Review

Policy Review

Financial Responsibility Determination

PayloadReview

PermitApplicationSubmittal




Policy Review

To determine whether a proposed launch would jeopardize:• U.S. National Security

• International Obligations

• Foreign policy interests

Interagency review of launch proposal Department of Defense Department of State NASA FCC Other




Determine if a license applicant or payload owner or operator has obtained all required licenses, authorizations, and permits, unless the payload is exempt from review

Ensure payload does not jeopardize:• Public health and safety• Safety of property• U.S. National Security• Foreign policy interests• International obligations

Does not apply to payloads under the jurisdiction of any other government agency (e.g. FCC, NOAA, etc.)

Crew and passengers are not payloads

Payload Review




Proof of financial responsibility required• Usually fulfilled by purchase of liability insurance• Value based on Maximum Probable Loss Determination

AST performs Maximum Probable Loss (MPL) Determination• Government property ($100M maximum)

– The amount of insurance is based on a 1 in 100,000 chance of loss exceeding amount

• 3rd party ($500M maximum)– The amount of insurance is based on a 1 in 10,000,000 chance

of loss exceeding amount

Financial Responsibility Determination




Issuing a permit for a launch or the operation of a commercial launch sites constitutes a “Major Federal Action” and is therefore subject to National Environmental Protection Act (NEPA)

This process may take a significant amount of time, so its never too early to start

Environmental Review




Process: Experimental Permit Regulation – Part 437

Part 437:• Subpart A – General Information• Subpart B – Requirements to Obtain an Experimental Permit• Subpart C – Safety Requirements• Subpart D – Terms and Conditions of an Experimental Permit

Part 413 Application Procedures

Part 440 Financial Responsibility

Part 460 Human Spaceflight

National Environmental Policy Act (NEPA)

Part 414 Safety Approval




General Information




Eligibility

Experimental permits issued only for:• Research and development to

test new:– Design concepts– Equipment– Operating techniques

• Showing compliance with requirements for obtaining a license

• Crew training before obtaining a license for a launch or reentry




Scope

Experimental Permit authorizes:• Launch of reusable suborbital rocket

• Reentry of reusable suborbital rocket

Authorization includes• Pre-flight operations

• Post flight operations

NOTE: The Permit authorization applies to reusable suborbital rocket

operations ONLY.




Scope (continued)

Pre-flight operation includes each operation that• Takes place at a U.S. launch site

• Meets specific criteria– Closely proximate in time to flight– Entails critical steps before flight– Unique to space launch, and– Hazardous enough to warrant regulatory oversight

Post flight operations• Includes each operation necessary to return vehicle to safe

condition after landing or impact




Requirements to Obtain an Experimental Permit




General Requirements

Applicant must provide • Program description

• Flight test plan

• Operational safety documentation

Other regulations apply • Environmental

• Financial responsibility (part 440)

• Human spaceflight (part 460)




General Requirements

Inspection before issuing permit • Applicant must make each vehicle planned to be flown available to

FAA for inspection– Verify vehicle built as represented in application– Occurs before FAA issues permit

NOTE: No vehicle maintenance or certification requirements exist at this time.




Program Description

Applicant must provide • 3D drawings or photos of vehicle

• Gross liftoff weight

• Thrust profile

Thrust vs. Time

0

5,000

10,000

15,000

20,000

25,000

0 10 20 30 40 50 60 70 80 90 100

Time (sec)

Th

rust

(lb

)

Weight (lb)

Structure 1809 Thermal Protection 95 Landing System 286 Propulsion System 620 Power 259 Avionics 351 Environmental Control 234 Personnel Provisions 324 Dry Weight 3978 RCS Propellant 11 Landing Propellant 293 Residuals/Reserves 91 Ascent Propellant 5603 Propellant Weight 5998 Crew 250 Gross Weight 10226




Program Description (continued)

Applicant must describe • All reusable suborbital rocket systems

– Structural– Flight control– Thermal– Pneumatic– Hydraulic– Propulsion– Electrical– Environmental control– Software and computing systems– Avionics– Guidance




Program Description (continued)

Applicant must describe • Types and quantities of all propellants

• Types and quantities of any hazardous materials

• Purpose for which vehicle is to be flown

• Each payload or payload class planned

Identify any foreign ownership • For sole proprietorship

• For a corporation, any foreign ownership of 10% or more

• For joint venture, association, or other entity




Flight Test Plan

Describe flight test program • Estimated # of flights

• Key flight safety events

List of Key Flight-Safety Events

Main rocket engine ignition

Parachute deployment

RCS attitude control ignition sequence

Powered landing

Envelope expansion flight(s) from 40,000 ft to 328,000 ft.

Event Flight to 40,000 ft Flight to 328,000 ft

Latitude Longitude Latitude Longitude

Ignition32° 55’ 30” N 106° 57’ 00” W 32° 55’ 30” N 106° 57’ 00” W

Parachute Deploy 32° 55’ 30” N 106° 55’ 00” W 32° 55’ 30” N 106° 43’ 00” W

RCS Attitude Control

Ignition & Powered Landing

32° 55’ 30” N 106° 54’ 10” W 32° 55’ 30” N 106° 42’ 18” W




Flight Test Plan (continued)

Identify/describe geographic coordinates of the boundaries of one or more proposed operating areas

Must provide the planned maximum altitude

LatitudinalBoundary

Longitudinal Boundary

Max Height

Operating Area




Operational Safety Documentation

Pre-flight and post flight operations• Operator must demonstrate how it will meet requirements to:

– Establish a safety clear zone

– Verify public is outside the safety clear zone before/during any hazardous operations

Hazard analysis • Operator must perform all steps required by the regulation

• Provide all results of each step to FAA

Verification • Applicant must identify, describe, and provide verification evidence

of the methods and systems used to contain vehicle’s IIP within operating area and outside any exclusion area




Operational Safety Documentation (continued)

Landing and Impact • Demonstrate compliance for each location for:

– a nominal landing of vehicle– a contingency abort landing of vehicle– any nominal or contingency impact or landing of a component

Agreements • Must enter into other agreements and provide copy to FAA

Identify and describe each tracking method or system used

Provide• Flight rules • Mishap response plan




Safety Requirements




Rest Rules

Rest rules for vehicle safety operations personnel

No personnel may work more than • 12 consecutive hours

• 60 hours in the 7 days preceding permitted activity, or

• 14 consecutive work days

Personnel must receive• At least 8 hours of rest after 12 hours

of work

• Minimum 48-hour rest period after 5 consecutive days of 12-hour shifts




Pre-Flight and Post Flight Operations

Must protect public from adverse effects of hazardous operations and systems • Preparing vehicle for flight at a launch site in U.S.

• Returning vehicle and any support equipment to safe condition

Establish safety clear zone to contain adverse effects of each operation involving a hazard

Verify the public is outside the safety clear zone • Before hazardous operations

• During hazardous operations




Hazard Analysis

Permittee must• Identify and characterize each of the hazards

• Assess the risk

• Carry out the risk elimination and mitigation measures derived from its hazard analysis

• Ensure the continued accuracy and validity of its hazard analysis




Experimental Permit Hazard Analysis - Qualitative Severity Classifications

Description Category Environmental, Safety, and Health Result Criteria

Catastrophic (Catastrophic +

Hazardous in AC23.1309)

I Failure that may cause death [1 or more] or serious injury to the uninvolved public or safety-critical system loss.

Critical (Major in AC23.1309)

II Failure that may cause major property damage, major safety-critical system damage or reduced capability, decreased safety margins, or increased workload.

Marginal (Minor in AC23.1309)

III Failure that may cause minor injury to the uninvolved public or minor safety-critical damage.

Minor (No Safety Effect in

AC23.1309)

IV Failure not serious enough to cause injury to the uninvolved public or safety-critical system damage.




Experimental Permit Hazard Analysis - Qualitative Likelihood Classifications

Description Level Description

Frequent A Likely to occur often in the life of an item, with a probability of occurrence greater than 10-2 per mission.

Probable B Will occur several times in the life of an item, with a probability of occurrence less than 10-2 but greater than 10-3 per mission.

Occasional C Likely to occur some time in the life of an item, with a probability of occurrence less than 10-3 but greater than 10-4 per mission.

Remote D Unlikely but possible to occur in the life of an item, with a probability of occurrence less than 10-4 but greater than 10-6 in that life.

Extremely Unlikely

E So unlikely, it can be assumed occurrence may not be experienced, with a probability of occurrence less than 10-6 in that life.

Consistent with FAA AC 23.1309, Class I aircraft (highest acceptable aircraft risk)




Experimental Permit Hazard Analysis - Risk Acceptability

SeverityCatastrophic

I

Critical

II

Marginal

III

Minor

IVFrequency

Frequent - A 1 3 7 13

Probable - B 2 5 9 16

Occasional - C 4 6 11 18

Remote - D 8 10 14 19

Extremely Unlikely - E 12 15 17 20

High (1-9): Unacceptable - Controlling/mitigating actions should be taken to reduce risk

Low (10-20): Risk is acceptable




Experimental Permit Hazard Analysis - Example

Hazard Description

Target Risk BeforeSev. Prob. Risk

Mitigation measures Risk AfterSev. Prob. Risk

Engine shutdown system does not work with the potential for an uncontrolled crash in populated areas.

Public I C High Use redundant engine shutdown systems with different methods of operation, such as an automated system (valve with software-driven controller) and a manual system (manually operated valve).

I E Low




Hazard Analysis (continued)

Hazard analysis must• Demonstrate that the risk elimination and mitigation measures

achieve the risk levels through validation and verification

• Verification includes– Test data– Inspection results, or– Analysis




Operating Area Containment

Operating area • Must contain the vehicle’s instantaneous impact point (IIP)

• Must be large enough to contain each planned trajectory and all expected vehicle dispersions




Operating Area Containment (continued)

Operating area • Must contain enough unpopulated or sparsely populated area to

perform key flight safety events

• May not contain or be adjacent to a densely populated area or large concentrations of members of the public

• May not contain or be adjacent to significant

– Automobile traffic

– Railway traffic

– Waterborne vessel traffic




Operating Area Containment (continued)

FAA may prohibit IIP from traversing certain areas within an operating area • Designating one or more areas as exclusion areas

• Exclusion area may be confined to a specific phase of flight

Nuclear Power PlantsSport StadiumsHospitals

Examples of possible Exclusion Areas




Key Flight-Safety Event Limitations

Permittee must conduct any key flight-safety event so that the IIP, including expected dispersion, is over an unpopulated or sparsely populated area

Key flight-safety events include:• Ignition of any primary rocket engine;

• Any staging event, or

• Any envelope expansion

Permittee must conduct flight so that reentry impact point does not loiter over a populated area




Landing and Impact Locations

For nominal or any contingency abort landing of vehicle, or for any nominal or contingency impact or landing of a component, a permittee must use a location that:• Is big enough to contain impact, including debris dispersion; and

• At time of landing, does not contain any members of the public




Agreements with Other Entities

Must have an agreement in writing with: • Federal launch range operator

• Licensed launch site operator

• Any other party that provides access to or use of property and services required to support safe launch/reentry




Agreements with Other Entities (continued)

Must have an agreement in writing with: • US Coast Guard district

– For overflight of navigable water– For issuing a notice to mariners before flight

• Responsible Air Traffic Control authority – For airspace through which flight/reentry will

occur – For measures necessary to ensure safety of

aircraft




Collision Avoidance

Must obtain collision avoidance analysis: • From USSTRATCOM

• For planned maximum altitudes greater than 150 km

Analysis must establish each period during which permittee may not initiate flight • Ensure vehicle and jettisoned components do not pass closer than

200 km to manned or mannable orbital object

• Distance less than 200 km may be used if distance provides an equivalent level of safety, and distance accounts for all uncertainties in analysis




Tracking

Permittee must: • During flight, measure in real

time the position and velocity of its reusable suborbital rocket; and

• Provide position and velocity data to FAA for post-flight use




Communications

Must be in communication with Air Traffic Control during all phases of flight

Must record communication affecting the safety of the flight




Flight Rules

Must confirm that all systems and operations necessary to ensure that safety measures derived are within acceptable limits

Must (during all phases of flight)• Follow flight rules that ensure compliance

• Abort flight if it would endanger the public

May not operate vehicle in a careless or reckless manner that would endanger any member of the public during any phase of flight




Flight Rules (continued)

May not operate vehicle in areas designated in a NOTAM unless authorized • Air Traffic Control, or

• A Flight Standards Certificate of Waiver or Authorization

Comply with provisions of part 91 • For any phase of flight

• Where rocket operated like an aircraft in the NAS




Anomaly Recording

Permittee must:• Record each anomaly that affects a safety-critical system,

subsystem, process, facility, or support equipment

• Identify all root causes of each anomaly

• Implement all corrective actions for each anomaly

• Report to FAA any anomaly of any system that is necessary for complying with requirements

• Report to FAA the corrective action for each anomaly

• Implement each corrective action before the next flight




Mishap Reporting

Permittee must report, respond to, and investigate mishaps that occur during permitted activities

Reporting requirements• Immediately notify FAA WOCC if there is a launch or reentry

accident or incident or a mishap that involves a fatality or serious injury

• Notify within 24 hours FAA/AST if there is a mishap that does not involve a fatality or serious injury

• Submit within 5 days of the event a written preliminary report to FAA/AST if there is a launch or reentry accident or incident during permitted flight




Terms and Conditions of the Experimental Permit




Public Safety Responsibility

Permittee must ensure any launch or reentry under an experimental permit is safe, and must protect public health and safety and the safety of property




Allowable Design Changes

FAA identifies type of changes a permittee can make to the vehicle design without invalidating the permit

Permittee must ask FAA to modify permit if: • It proposes to conduct permitted activities in manner not authorized by

permit

• Any representation in permit application that is material to public health and safety or safety of property is no longer accurate or complete

NOTE: The type of changes allowable, without invalidating the permit, will be

explicitly identified in the Terms and Conditions of the Experimental Permit




Records

Permittee must maintain for 3 years all records, data, and other materials necessary to verify launch conducted in accordance with permit

Launch/reentry accident or incident • Preserve all records related to event

• Keep all records until after any Federal investigation and FAA advises permittee that they may dispose of them

Make all records available for inspection and copying




Pre-Flight Reporting

Provide information 30 days before each flight or series of flights • Any payload to be flown, including payload operations during flight

• When flight or series are planned

• Operating area for each flight

• Planned maximum altitude for each flight

Not later than 15 days before each flight • Planned trajectory for collision avoidance

• For each flight reaching 150 km or higher altitude

NOTE: Typically an applicant will submit a proposed flight plan early in the

process consisting of a series of flights covering an extended time frame; i.e.,

Company A plans 2 flights per month for the next 12 months




For-Hire Prohibition

No permittee may carry any property or human being for compensation or hire on a reusable suborbital rocket




For-Hire Prohibition (continued)

What is defined as compensation for hire?• Any form of payment or any non-monetary exchange of value

including the bartering of goods or services in exchange for the transportation

• The FAA does not consider the following compensation:– Goodwill– The winning of prize money– Advertising revenue from logos




Compliance Monitoring

Permittee must allow access by, and cooperate with:• Federal officers, or

• Employees, or

• Other individuals authorized by the FAA

to observe any activities of the permittee, or of its contractors or subcontractors, associated with the conduct of the permitted activities




Inspection of Additional Rockets

Permittee may launch or reenter additional vehicles of same design under the permit after FAA inspects each additional vehicle

X-1 X-1a X-1b X-1c




Further Information

• AST’s website http://ast.faa.gov

• In the menu on the left side of the page

• Click “Licenses & Permits”

• Then click “Experimental Permits”

• My contact information:

• Sherman Council

• AST-200 Licensing and Evaluation Division

• Experimental Permit Program Lead

• Email: [email protected]

• Phone: 202-267-8308




Questions




Definitions

Anomaly: Problem that occurs during verification or operation of a system, subsystem, process, facility, or support equipment

Envelope Expansion: Any portion of a flight where planned operations will subject a reusable suborbital rocket to the effects of altitude, velocity, acceleration, or burn duration that exceed a level or duration successfully verified during an earlier flight

Exclusion Area: An area, within an operating area, that a reusable suborbital rocket’s instantaneous impact point may not traverse

Key Flight Safety Event: A permitted flight activity that has an increased likelihood of causing a launch accident compared with other portions of flight




Definitions (continued)

Operating Area: A three-dimensional region where permitted flights may take place

Suborbital Rocket: A vehicle, rocket-propelled in whole or in part, intended for flight on a suborbital trajectory, and the thrust of which is greater than its lift for the majority of the rocket-powered portion of its ascent

Suborbital Trajectory: The intentional flight path of a launch vehicle, reentry vehicle, or any portion thereof, whose vacuum instantaneous impact point does not leave the surface of the Earth




Definitions (continued)

Validation: An evaluation to determine that each safety measure derived from a system safety process is correct, complete, consistent, unambiguous, verifiable, and technically feasible. Validation ensures that the right safety measure is implemented, and that the safety measure is well understood

Verification: An evaluation to determine that safety measures derived from a system safety process are effective and have been properly implemented. Verification provides measurable evidence that a safety measure reduces risk to acceptable levels




Other Definitions (continued)

Aircraft Buffer Zone: A three-dimensional region beyond the operating area in which hazardous debris could fall through aircraft altitudes in the event of a failure of the launch vehicle

Aircraft Hazard Area : A three-dimensional region made up of the operating area and aircraft buffer zone

Safety Clear Zone : A boundary designed to contain the adverse effects of each operation involving a hazard

NOTE: Restricting nonparticipating aircraft from entering the aircraft hazard

area prevents exposure of aircraft to unacceptable risk levels.

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